Compliance and shipping
Product Safety Documentation for Apparel
Technical documentation under the General Product Safety Regulation is safety evidence, not a manufacturing specification. A tech pack describes how to build the garment; the documentation records what could go wrong with it, what was done about that, and what supports the conclusion. They share facts, and neither replaces the other.
Contents
Ask a brand for its product safety documentation and you will usually be handed a tech pack, a REACH report and an inspection certificate. All three are legitimate documents. None of them is what was asked for, and the gap between the pile and the requirement is where many first-time EU programmes discover they have a problem.
Agree who is responsible for the product assessment and documentation before production. The applicable legal role depends on how the product is supplied and placed on the market.
A tech pack is not technical documentation
The two documents get conflated because both are technical, both describe the product and both live in the same folder. They answer completely different questions.
Two documents, two purposes
Apparel tech pack
- A manufacturing specification
- Says how the garment should be built
- Materials, construction, measurements, artwork, labels, packing
- Written so a factory can make the product correctly
- Its audience is production
- Covered in what a factory actually needs
Product safety technical documentation
- Safety evidence required by the Regulation
- Says what could go wrong and what was done about it
- Product description, risk analysis, requirements applied, evidence, solutions adopted
- Written so an authority can see the basis for the conclusion
- Its audience is market surveillance
- Held by whoever carries manufacturer obligations
They overlap in facts. The composition, the construction, the trims and the decoration all appear in both. What differs is the reasoning wrapped around those facts: a tech pack states what to make, and the documentation states why what was made is safe for its intended and foreseeable use.
What the documentation contains
Before placing a product on the market, the manufacturer carries out an internal risk analysis and draws up technical documentation. At minimum that documentation contains a general description of the product and its essential characteristics relevant to assessing its safety. Where appropriate to the risks the product may present, it also contains an analysis of those risks and the solutions adopted to eliminate or mitigate them.
A conceptual structure
Conceptual only, and deliberately not a template. What a particular product's documentation contains depends on the product and the risks it actually presents.
How long it is kept
The technical documentation is kept and kept up to date for 10 years. Where an importer is involved, the importer keeps a copy for 10 years after the product is placed on the market and makes it available to authorities on request.
The practical consequence is easy to miss and expensive to discover: the retention obligation outlives the commercial relationship. A brand that changes supplier, or a supplier that archives a project folder when a programme ends, still needs the file. Deciding at the start who holds what, and how it is handed over, avoids reconstructing a safety assessment from memory four years later.
Risk analysis is not the same as lab testing
This is the second big misconception, and it runs in both directions. Some brands treat a laboratory report as the whole exercise; others treat the exercise as paperwork that testing has already covered.
The analysis is a reasoning step. It asks what this product is, who uses it, how it will be used and misused, and what could cause harm. Testing is one of several ways of evidencing an answer once the question has been identified. Running tests without the analysis produces evidence for hazards nobody established were relevant, and misses the ones nobody thought about.
How the reasoning runs
What foreseeable use means in apparel
Products are assessed on how they will actually be used, including use that is not intended but is reasonably predictable, and with regard to the consumers who will use them, including where a product is likely to be used by children or by people who are more vulnerable to a particular hazard.
For clothing this is rarely exotic. It is the difference between a decorative element assessed as an adult accessory and the same element on a garment a small child will put in their mouth, or between a drawcord on an adult jacket and one on a child's hooded top.
Where hazards tend to sit in garments
Offered as illustrations of the kind of reasoning involved, not as a list of tests every garment needs. Whether any of these applies depends entirely on the product.
- Detachable and small components. Applied badges, beads, buttons, cord ends and press studs, particularly where a garment is intended for or likely to reach small children. See children's apparel safety.
- Cords, drawstrings and ties. A long-established area of concern in children's clothing, with its own dedicated European standard. See EN 14682 cords and drawstrings.
- Sharp or protruding parts. Metal trims, broken fastenings, pins and needle fragments, which is also why needle control is an established factory discipline, covered in needle control and metal detection.
- Chemical content. Restricted substances in materials, dyes, prints, coatings and trims, covered in chemical compliance.
- Flammability, where a product's use or a specific rule makes it relevant.
- Information provided, where safe use depends on the consumer knowing something.
Two things this list is not. It is not a claim that every garment presents all of these, and it is not a testing matrix. Which requirements apply to a given product, and what standards or methods are appropriate, is part of the assessment rather than something a general guide can settle.
Who prepares it, and who contributes to it
The obligation sits with whoever holds manufacturer obligations for the product. That is a legal question about the arrangement, and it is answered in GPSR for apparel. What is not true is either of the two shortcuts.
The workable model is that the obligation sits with one party and the evidence flows to it. Which is a sourcing problem rather than a legal one, and it is solved by asking for the right things at the right time instead of requesting a certificate that does not exist.
What a factory can realistically supply
Production-side information that supports a safety file
Not a universal dossier, and not the file itself. This is the material a manufacturer holds that an assessment draws on.
- The final approved specification, at a stated revision.
- Material and component information: composition, construction, finishes, and what the trims actually are.
- Component and material supplier identification, to the extent the arrangement provides for it.
- Any test evidence that exists on materials or components, with the scope it actually covers.
- Production and batch identification, and how it maps to what shipped.
- Decoration details: method, inks or backing systems used, and any supplier documentation for them.
- Approved deviations and changes made during development, with dates.
- Confirmation of what was physically approved, and against which sample.
Asking for this at development stage costs almost nothing. Asking for it two years later, after a supplier change or a staff change, is a different exercise entirely, which is the same lesson as design ownership teaches about files, for the same reason.
What existing reports do and do not cover
Many apparel programmes already hold documents that feel like safety evidence. They are useful, and each has a scope worth being honest about.
| Document | What it evidences | What it does not |
|---|---|---|
| Chemical test report | A result for a submitted sample, by a stated method, against stated criteria | Physical hazards, foreseeable use, or anything outside the tested sample. See chemical test reports |
| Colourfastness or wash test | How colour and dimensions behave in use and laundering | Safety. It is a performance and care question. See colourfastness |
| Inspection report | Whether goods match the approved standard | Whether the approved standard was itself safe |
| Material certificate | That a material meets a scheme's criteria | Compliance with law, or the safety of the finished product. See certified materials |
| Supplier declaration | A supplier's stated position on a material | An analytical result, or the assessment itself |
The pattern is the same in every row. Each document answers a bounded question well. The documentation is the reasoning that decides which questions needed answering and records what the answers were.
Keeping it current
The documentation is kept up to date, which makes change control part of the obligation rather than good housekeeping. In apparel, the changes that matter are the ordinary ones.
- A material or supplier change, including a mill change that keeps the same specification on paper.
- A new colour, print, coating or decoration method.
- A trim change, particularly to anything attached, coated, plated or plastic.
- A construction change that alters how a component is secured.
- A change in the intended user, most obviously extending a range into children's sizes, which reopens more than the pattern. See children's apparel safety.
- New information from the market: complaints, returns with a pattern, or an incident.
None of these automatically means redoing the whole assessment. Each means asking whether the existing reasoning still holds, which is a short conversation when the file records reasoning and a long one when it contains only test results.
Questions buyers ask
Is a tech pack the same as GPSR technical documentation?
No. A tech pack is a manufacturing specification telling a factory how to build the garment. Technical documentation is safety evidence: a description of the product and its essential safety characteristics, and where appropriate an analysis of the risks and the solutions adopted. They share product facts and neither replaces the other.
What does product safety technical documentation contain?
At minimum a general description of the product and its essential characteristics relevant to assessing its safety, and where appropriate to the risks the product may present, an analysis of those risks and the solutions adopted to eliminate or mitigate them. The depth is proportionate to the risks, so a simple garment does not require the file a complex one does.
How long must the documentation be kept?
It is kept and kept up to date for 10 years. Where an importer is involved, the importer keeps a copy for 10 years after the product is placed on the market and makes it available to authorities on request. The obligation outlives most commercial relationships, so who holds what should be settled at the start.
Who prepares the technical documentation, the brand or the factory?
The obligation sits with whoever holds manufacturer obligations for that product, which depends on the arrangement rather than on a rule about brands or factories. In practice the party with the obligation compiles it while the production side supplies material facts: specification, materials, components, batch identification and any test evidence that exists.
Does a laboratory test report count as the technical documentation?
No. A test report evidences a result for a submitted sample against stated criteria, which can support the file. The documentation is the wider reasoning: what the product is, how it will be used and misused, which hazards apply, what was done about them and what supports the conclusion.
Does every garment need to be tested against a harmonised standard?
No. European standards can play a part in demonstrating that a product meets the general safety requirement, and other criteria can also be taken into account. Which requirements and methods are appropriate is part of the assessment, and testing everything against everything produces cost rather than reduced risk.
What should I ask a clothing factory for?
The approved specification at a stated revision, material and component information including trims and finishes, supplier identification where the arrangement provides for it, any existing test evidence with its actual scope, production and batch identification, decoration details, and a record of approved changes. Not a GPSR certificate, which does not exist.
When does a safety assessment need revisiting?
When something changes that the reasoning depended on: a material or supplier change, a new colour, print or coating, a trim change, a construction change affecting how a component is secured, an extension into children's sizes, or new information from the market such as a pattern in complaints or returns.
Ask for the evidence while the programme is running
Specification revisions, material and component detail, batch identification and existing test evidence are straightforward to supply during development and awkward to reconstruct afterwards. Tell us what your programme needs and when it needs it.
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