Lithium battery pack or cell
The EU Batteries Regulation now applies to every battery placed on the market as such or inside a product: safety and performance, labelling, due diligence, removability, and the transport test summary that every carrier asks for.
Regimes engaged, per market
Standing when pasted with its name: mapped
What the file has to hold
- Technical file (7 of the 11 regimes, including GPSR, Batteries Reg, REACH)
The technical documentation: design, drawings, bill of materials, the standards applied, the conformity assessment route, and the evidence that the requirements are met. Kept for the retention period the regime sets, typically ten years from the last unit placed on the market. - Declaration of conformity (Batteries Reg, UN 38.3, UKCA)
The EU or UK declaration of conformity (or the food-contact declaration of compliance), signed by the manufacturer, naming the product, the legislation and the standards, and the notified or approved body where one was involved. - Risk assessment (GPSR, CPSC, UK GPSR)
The documented hazard identification and risk assessment for the product across its lifecycle, updated when the design, the use or the field data changes. - Test reports (7 of the 11 regimes, including GPSR, CPSC, Batteries Reg)
Test reports from an accredited or accepted laboratory against the standards the technical file names, tied to the exact model and revision tested. - Labelling and instructions (8 of the 11 regimes, including GPSR, CPSC, Batteries Reg)
Markings on the product and packaging (conformity mark, identification, warnings, manufacturer and importer details) and the instructions and safety information in the language of the market. - Traceability records (GPSR, CPSC, UK GPSR)
Batch, lot or serial identification on the product, the records that tie a unit to its production and supply chain, and UDI where the device rules require it. - Third-party certificate (UL/NRTL)
A type-examination certificate, notified or approved body certificate, or listing from a recognised laboratory, with the scope and the expiry. - Substance declarations (REACH, UK REACH, Prop 65)
Safety data sheets for mixtures and supplier material declarations for articles: the trail that shows what is in the product against the restricted lists. - Registrations (Batteries Reg, UK Batteries)
Producer, establishment, device or product registrations in the databases the regime names (EUDAMED, EPREL, CPNP, the WEEE and battery registers, FDA registration and listing).
Duties that continue after sale
- Market surveillance cooperation (GPSR, CPSC, UK GPSR)
Answer an authority's request for the technical file, the declaration and the supply chain within the time it sets, in a language it accepts, and cooperate with any corrective measure it requires.
Licensed controls: GPSR Art.14, 15, 17 · GPSR Art.23, 24 · CPSC PM.4 · CPSC PM.3 - Incident reporting (GPSR, CPSC, UK GPSR)
Notify the authority when a product has caused, or could cause, an accident, injury or serious incident, through the channel the regime names (the Safety Business Gateway, the MHRA, the FDA, SaferProducts.gov) and within its clock.
Licensed controls: GPSR Art.20 · GPSR Art.25, 26, 27 · CPSC USCPSC 1 · CPSC PM.1 - Recall readiness (GPSR, CPSC, UK GPSR)
Be able to identify affected units, reach the customers who hold them, issue a notice in the required form, offer the remedy the rules require, and show the authority the effectiveness of the action.
Licensed controls: GPSR Art.35 · GPSR Art.36, 37 · CPSC USCPSC 3 · CPSC PM.2 - Traceability records (GPSR, UK GPSR)
Keep the records that identify which batch went to which customer, and the identification on the product that lets a unit be traced back, for the retention period the regime sets.
Licensed controls: GPSR Art.18 · GPSR Art.9 - Security updates and vulnerability handling (CPSC)
Provide security updates for the stated support period, run a coordinated vulnerability disclosure process, and report actively exploited vulnerabilities and severe incidents within the reporting clock.
Licensed controls: CPSC CS.4 · CPSC SW.3 - Producer responsibility for take-back (Batteries Reg, UK Batteries)
Keep producer registrations current in each market, report the quantities placed, and finance collection and treatment of the product and its batteries at end of life. - Substance list watching (5 of the 11 regimes, including Batteries Reg, REACH, UK Batteries)
Track additions to the restricted and candidate substance lists, re-check supplier declarations against them, and update customer communication and labels when a substance in the product is added.
This week
Get the UN 38.3 test summary for each cell and pack, because customs and carriers ask for it before any regulator does.
What holding one is evidence for
Requirement text and evidence artefacts from a human-verified corpus. Data licensed to Conformity Sheet by The Art of Service Pty Ltd, revocable, non-transferable.
GPSR: EU General Product Safety Regulation (Regulation (EU) 2023/988)
GPSR Art.9 Obligations of manufacturers (Article 9)Article 9 imposes the central manufacturer obligations: (a) carry out internal risk analysis and draw up technical documentation containing the analysis + identification of relevant European standards or risk-assessment elements (kept for 10 years); (b) place safe products on the market that comply with Article 5 + Art...
Common gap: Product placed on market without Article 9(2) risk analysis + technical documentation
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
GPSR Art.5, 6, 7, 8 General safety requirement and assessment criteria (Articles 5-8)Article 5 establishes the general safety requirement: economic operators shall place or make available on the market only safe products. Article 6 sets the criteria for assessing safety: the characteristics of the product including its composition, packaging, instructions for assembly and, where applicable, installatio...
Common gap: Placing on market without an Article 6 assessment file
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
GPSR Art.10, 11, 12 Authorised representatives, importers and distributors (Articles 10-12)Article 10 governs authorised representatives (written mandate; tasks include keeping the EU declaration / technical documentation available for 10 years + cooperation with market surveillance). Article 11 sets importer obligations: place safe products + verify Article 9 manufacturer compliance + place importer identit...
Common gap: Non-EU manufacturer placing products without an authorised representative + responsible person in the Union (Article 16)
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
GPSR Art.13, 16 Cases where manufacturer obligations apply to other persons + responsible person in the Union (Articles 13 and 16)Article 13 provides that an importer, distributor or other economic operator is considered to be a manufacturer + subject to Article 9 obligations where the operator places on the market under its own name or trademark, modifies the product in a way that may affect compliance with Article 5, or carries out other Articl...
Common gap: Non-EU manufacturer placing products on the Union market without an Article 16 responsible person
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
CPSC: US Consumer Product Safety Commission (CPSC) requirements, including connected product safety
CPSC RA.3 Lifecycle Risk AssessmentRisk analysis must cover every stage of the product lifecycle including software updates and end-of-life scenarios.
Common gap: OTA update integrity controls insufficient
US Consumer Product Safety Commission (CPSC) - Connected Product Safety on compliance.theartofservice.com
CPSC STD.3 Voluntary Standards ParticipationManufacturers should participate in development of voluntary safety standards with UL, ASTM, and other bodies.
Common gap: Section 15(b) report triage not aligned to connected hazards
US Consumer Product Safety Commission (CPSC) - Connected Product Safety on compliance.theartofservice.com
CPSC USCPSC 1 Section 15(b) Substantial Product Hazard ReportingPer US Consumer Product Safety Act Section 15(b): Substantial Product Hazard Reporting to CPSC within 24 hours of obtaining information including cybersecurity hazards.
Common gap: Sec 15(b) + connected product partial
US Consumer Product Safety Commission (CPSC) - Connected Product Safety on compliance.theartofservice.com
CPSC USCPSC 3 Recall, Corrective Action, SaferProducts.govPer CPSC: Voluntary Recall Notice + Corrective Action Plan + SaferProducts.gov Complaint Monitoring.
Common gap: Sec 15(b) + connected product partial
US Consumer Product Safety Commission (CPSC) - Connected Product Safety on compliance.theartofservice.com
Do this for every product you sell
Paste the list and get this classification for every product at once, per market, with the documents held and missing, the after-sale duties and the findings. Five products free, no account.
Build my conformity sheet