ESPR Article 21 requires manufacturers to compile technical documentation before placing a product on the EU market. The documentation must demonstrate that the product meets all applicable ecodesign performance requirements. This guide covers every required document, the data it must contain, and how long it must be kept.
Technical documentation is the internal compliance record that manufacturers must compile and maintain to demonstrate ESPR compliance. It is not the same as the Digital Product Passport — the DPP is the public-facing data record accessible via QR code, while technical documentation is the internal record kept by the manufacturer and made available to market surveillance authorities on request.
ESPR Article 21 specifies the required content of technical documentation. The specific requirements vary by product category and are defined in the applicable delegated act. However, all technical documentation must include the elements listed in ESPR Article 21(1).
| Document | Required Content | Legal Basis |
|---|---|---|
| Product description | General description of the product, its components, sub-assemblies, and intended use; product model identifier; product category and applicable delegated act | ESPR Article 21(1)(a) |
| Design drawings | Design drawings or diagrams of the product and its components; bill of materials; assembly instructions | ESPR Article 21(1)(b) |
| Test reports | Test reports from accredited laboratories demonstrating compliance with all applicable ecodesign performance requirements; test methods used; test conditions | ESPR Article 21(1)(c) |
| Carbon footprint assessment | Lifecycle carbon footprint calculation per ISO 14040/14044 or EU Product Environmental Footprint (PEF) methodology; carbon footprint per lifecycle stage; carbon footprint class | ESPR Annex III(c) |
| Material composition declaration | Material composition by weight percentage; recycled content percentages by material; critical raw material content; bio-based content percentage | ESPR Annex III(b) |
| Hazardous substance declaration | SVHC substances present above 0.1% by weight threshold; REACH compliance declaration; RoHS compliance declaration (if applicable); location of hazardous substances in the product | ESPR Annex III(d); REACH Article 33 |
| Repairability data | Repairability score (if required by delegated act); spare parts list and availability period; repair manual; disassembly instructions | ESPR Annex III(a) |
| EU Declaration of Conformity | Formal declaration that the product meets all applicable ESPR requirements; reference to applicable delegated act; harmonised standards used; manufacturer identity and signature | ESPR Article 22 |
The carbon footprint assessment is one of the most technically demanding elements of ESPR technical documentation. ESPR Annex III(c) requires the carbon footprint to be calculated per lifecycle stage: raw material extraction and processing; manufacturing; distribution and transport; use phase; and end-of-life.
The carbon footprint must be calculated using a recognised methodology. The EU Commission is developing a mandatory methodology based on the Product Environmental Footprint (PEF) Category Rules. Until sector-specific PEF Category Rules are published, manufacturers should use ISO 14040/14044 (lifecycle assessment) or ISO 14067 (carbon footprint of products).
ESPR Annex III(b) requires the DPP to contain material composition data including recycled content percentages. Compiling accurate material composition data requires a detailed bill of materials and supply chain data from component suppliers. For complex products with many components (e.g., electronics, vehicles), this can be a significant data collection exercise.
Recycled content must be verified through a chain of custody certification (e.g., Recycled Claim Standard, Global Recycled Standard). Self-declaration of recycled content without third-party verification is unlikely to be accepted by market surveillance authorities.
ESPR Annex III(d) requires the DPP to declare Substances of Very High Concern (SVHC) present above 0.1% by weight threshold. This requirement mirrors REACH Article 33, which already requires suppliers to communicate SVHC information to downstream users. Manufacturers should use their existing REACH compliance data as the basis for the ESPR hazardous substance declaration.
The DPP must also identify the location of hazardous substances within the product — this is to enable safe disassembly and recycling at end of life. This is a new requirement that goes beyond REACH Article 33.
| Document | Retention Period | Legal Basis |
|---|---|---|
| Technical documentation | 10 years after last product of that model placed on market | ESPR Article 21(3) |
| EU Declaration of Conformity | 10 years after last product of that model placed on market | ESPR Article 22(3) |
| Digital Product Passport data | Product lifetime + minimum 10 years after last product placed on market | ESPR Article 8(4) |
Technical documentation is the manufacturer's evidence file — the collection of documents that proves a product meets all applicable ESPR requirements. It is not a public document — it is a private compliance record that is kept by the manufacturer and provided to market surveillance authorities on request. The technical documentation must be compiled before the product is placed on the EU market and must be kept for at least 10 years after the last product of that model is placed on the market.
ESPR Annex VI Section 1 lists the required contents of the technical documentation. The list includes: a general description of the product; design and manufacturing drawings; a list of harmonised standards applied; design calculations; test reports; a copy of the EU Declaration of Conformity; and a copy of or link to the DPP. The delegated act for each product category may add additional required documents — such as supply chain due diligence documentation for products containing critical raw materials.
| Best Practice | Rationale |
|---|---|
| Use a document management system | Ensures documents are version-controlled and retrievable on request |
| Link technical documentation to DPP | ESPR requires DPP to reference technical documentation |
| Maintain translations of EU DoC | EU DoC must be in official language of member state where product is sold |
| Set retention reminders | 10-year retention period starts from last product of model placed on market |
| Plan for business continuity | Technical documentation must remain accessible even if manufacturer ceases trading |
| Conduct regular document audits | Verify that all required documents are present and up to date |
Technical documentation may be maintained in electronic form. There is no requirement to maintain physical paper copies. Cloud-based document management systems are acceptable provided they meet the availability and security requirements. The documentation must be accessible on request from market surveillance authorities — which means it must be stored in a format that can be retrieved and transmitted quickly, and the manufacturer must have a process for responding to market surveillance requests within a reasonable time (typically 10 business days).
The technical documentation for an ESPR-compliant product must demonstrate that the product meets all applicable ecodesign requirements. For a typical consumer electronics product, the technical documentation would include: a product description with photographs and technical drawings, a bill of materials listing all components and materials with their weights and material compositions, energy efficiency test reports from an accredited laboratory, a carbon footprint calculation using the methodology specified in the delegated act, a recycled content calculation with supporting evidence from material suppliers, a repairability assessment using the methodology in the delegated act, a chemical substance declaration listing all substances of concern above the threshold concentrations, a DPP system description including the resolver URL and data format, and a copy of the EU Declaration of Conformity.
Managing technical documentation for a large product portfolio is a significant administrative challenge. Manufacturers with hundreds or thousands of product variants need a systematic approach to technical documentation management. A product information management (PIM) system that integrates with the DPP platform is the recommended approach — the PIM system stores the technical documentation for each product variant, and the DPP platform uses the PIM data to generate the DPP. This integration ensures that the DPP data is always consistent with the technical documentation, and that updates to the technical documentation (for example, when a component is substituted) are automatically reflected in the DPP. Manufacturers that do not have a PIM system should consider implementing one as part of their ESPR compliance programme.
The EU Commission has acknowledged that the technical documentation requirements of ESPR may be burdensome for SMEs (small and medium-sized enterprises). The ESPR regulation includes provisions for simplified conformity assessment procedures for SMEs, and the delegated acts for some product categories may include simplified technical documentation requirements for SMEs. Industry associations in some sectors are developing collective technical documentation templates that SME members can use as a starting point. Manufacturers that are SMEs should engage with their sector trade association to understand what simplified approaches are available for their product category, and should engage with the EU Commission's SME envoy if they believe the ESPR technical documentation requirements are disproportionately burdensome for SMEs.
ESPR Article 15(4) requires that technical documentation be kept available for at least 10 years after the last product of the model is placed on the market. For products with long production runs, this means the technical documentation must be retained for the duration of the production run plus 10 years. Manufacturers should implement a document management system that ensures technical documentation is retained for the required period and is accessible to market surveillance authorities on request. The technical documentation must be kept in a format that remains readable throughout the retention period — manufacturers should plan for technology migration to ensure that documentation stored in proprietary formats remains accessible as technology evolves.
ESPR Article 21 requires technical documentation that includes: product description and design drawings; test reports demonstrating compliance with performance requirements; carbon footprint calculations; material composition data; hazardous substance declarations; and the EU Declaration of Conformity. The specific requirements are defined in the applicable delegated act.
ESPR Article 21(3) requires technical documentation to be kept for 10 years after the last product of that model is placed on the market. For products with long lifetimes (e.g., industrial equipment, construction products), this can mean documentation retention periods of 20–30 years.
The manufacturer is responsible for compiling technical documentation. For non-EU manufacturers, the EU Authorised Representative may compile the documentation on behalf of the manufacturer. The documentation must be available to market surveillance authorities on request.
Existing product documentation (e.g., CE marking technical files, ISO certification documentation) can be used as the basis for ESPR technical documentation, but it will need to be supplemented with ESPR-specific data: carbon footprint calculations, recycled content data, SVHC declarations, and DPP data fields.
Technical documentation is the internal compliance record kept by the manufacturer. The DPP is the public-facing data record accessible via QR code. The DPP contains a subset of the technical documentation data — the data fields specified in ESPR Annex III. The full technical documentation is not publicly accessible.
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