To get GPSR compliant your EU Authorised Representative needs to hold risk assessments for your products.

But what if you sell more than one thing?

What if you have a really large product range?

Suddenly the idea of creating a risk assessment for everything on your inventory can feel totally overwhelming.

At RepGuardia we're always looking for a way to make the process quick and simple and if you’ve found this blog, then so are you.

So… is it possible to write just one risk assessment to cover multiple products in your range, to save time and creating hundreds more pieces of documentation in your business?

The short answer is: it depends on how similar your products actually are.

Here's what the regulation says, and what it means in practice, with a few real life examples thrown in from our experience at RepGuardia as an EU Authorised Representative to over 100 small businesses.

What GPSR Requires

Article 9(2) of the GPSR requires a risk analysis to be documented in the technical file for every product. The scope of that documentation depends on the complexity of the product.

So the regulation does say "every product." But complexity and scope are where you have room to work efficiently.

When conducting a risk analysis, the factors you need to cover include general characteristics, appearance, presentation, the category of consumer the product is intended for and effects on other products.

If two products share all of those factors, you have a strong case for shared or templated documentation (more on templates later).

When products can share documentation

The GPSR does not define a "product family" or "product range" as a single unit for documentation purposes.

However the Commission guidance published in November 2025 does clarify that substantial modifications would include any changes to a product by physical or digital means that affect its nature and characteristics in a way not foreseen in the initial risk assessment.

Read that the other way: changes that do not affect the nature, characteristics, or safety profile of a product are not "substantial modifications." That gives you a practical test when considering whether you can group products together on the same Risk Assessment.

If two products differ only in colour, artwork, wording, or surface design, and they are made from identical materials, constructed the same way, and pose the same risks to the same type of consumer, one risk assessment can cover both. You document the shared characteristics once, and note the variations.

If a product differs in material, construction, intended age group, or use, it needs its own assessment. The safety profile has changed, even if it looks similar on the outside.

A practical way to think about it

Ask yourself: if something went wrong with this product, would the cause be different from the cause with the other version?

A greetings card in blue and a greetings card in red: same paper, same ink type, same construction. The risk profile is identical. One assessment, two variants noted.

A children's wooden toy and an adult version of the same toy: different intended user, potentially different size and therefore different choking risk assessment. These need separate documentation.

A board game where the base game and an expansion share the same materials and components: potentially covered together. A board game where one edition adds small metal miniatures and the original doesn't: the miniatures introduce new risk factors. Separate assessment for that edition.

What to include in the Technical File

As your EU Authorised Representative, RepGuardia holds your ‘Technical File’ for your products, which includes your Risk Assessment(s).

On your Risk Assessments (and at RepGuardia we supply all our clients with templates and examples from a multitude of different types of products, so you’re not starting with a blank page), you need to include:

• A description of the product and its essential characteristics
• The materials it's made from
• Who it's intended for
• Foreseeable hazards and how you've addressed them
• Any relevant standards you've applied

The honest reality for small business owners

Most small businesses with a range of similar products can work more efficiently than they fear.

If you sell ten greetings cards that are all printed on the same card stock with the same ink, you don't need ten completely independent Risk Assessments. You need one thorough assessment that covers the shared product type, with a clear record of each variant (keeping a spreadsheet and giving each card design an SKU – Stock Keeping Unit – number covers this).

Where businesses get into trouble is when they assume similarity without checking. Different materials, different age suitability, different packaging, or different end use all change the assessment.

Start with your product that has the most complex risk profile. Use that as your template. Then work through your range and identify which products genuinely share that profile, and which need their own.

We always find that once you’ve done a Risk Assessment for one product or group of products, the following ones are much easier and quicker to produce – you’ll have the template, you’ll have a lot of similar risks already covered and you’ll understand how to think through the hazards.

Let's talk you through an example.... 

One of RepGuardia’s clients sells crystals, all individual natural items, all different shapes and sizes. Could they all go on one Risk Assessment? Or does she have to write a completely separate Risk Assessment for every crystal? 

No, but we could create groups.

We recommended starting with a Risk Assessment for one group of crystals – large/heavy crystals over a certain measurement and weight. Hazards included things like the risk of dropping the item, small natural breakage and the crystals being a trip hazard.

Then the next Risk Assessment for small, handheld crystals became easier – similar hazards around natural breakage, but some different considerations for e.g. swallow hazard and so warnings to keep away from children.

Our client didn’t have to create 100 Risk Assessments for 100 unique crystals.

She ended up with 3 grouped assessments that were quick and easy to produce with our support. And her paperwork was all submitted and verified within days of working this through with us on a Done With You Live Call which we offer our clients every quarter. 

What this means if you're working with an Authorised Representative

Your EU Authorised Representative holds your technical documentation on your behalf and provides it to market surveillance authorities if requested.

EU authorities can request your documentation at any time, and your Representative must provide it within 10 days.

That means your documentation needs to be organised and retrievable, not just technically complete. Whether you have 5 products or 50, a clear, consistent structure to your files makes the whole process easier for you and your rep.

At RepGuardia we take that responsibility seriously and act as a partner.

We don't just take your documentation - we review it, feedback on how to improve it, and give you total peace of mind that what we have on file will pass with authorities if it gets requested. 

If you're unsure whether your product range qualifies for shared documentation, that's exactly the kind of question to work through before you submit, and that’s something we’re happy here at RepGuardia to do with small business owners that want human support through this piece of legislation, so selling into the EU feels possible.

Ready to get your documentation in order? Find out how RepGuardia works.