Record lots and Article 9 checks
Add a product's production lots, confirm each Article 9 duty with the evidence you checked, and keep the re-checks current.
A registered product's drawer is where you keep its record current: the production lots a recall would name, and a dated check of each Article 9 duty it owes under the GPSR. Open a product from the Product registry tab to record either.
Add production lots
- Under Production batches, click Add lot.
- Enter the Batch or lot code, the date it was Manufactured on and, if you know it, the number of Units produced. Each code can be recorded once per product.
- Click Add lot.
Article 9(5) counts the batch number among the elements that identify a product, and Article 36(2)(b)(ii) puts it in a recall notice, so a recall or withdrawal of a product with lots on record must name the lots it covers. Use Edit to correct a lot. A lot that a recall or withdrawal names can't be deleted, even after the measure is closed, and a lot under an open measure shows Under recall. While a product has lots on record it can't be deleted, only withdrawn.
Confirm each Article 9 duty
Article 9 obligations lists the duties the product owes and how many are confirmed. Which ones apply depends on Our role in this product's chain: importer identification applies only when you're the importer.
| Duty | Article |
|---|---|
| Product identifier | 9(5) |
| Manufacturer identification | 9(6) |
| Importer identification | 11(3) |
| Responsible person identification | 16(3) |
| Instructions and safety information | 9(7) |
| Technical documentation | 9(2) |
| Consumer contact channels | 9(11) |
| Complaints and corrective-measures register | 9(12) |
- Check the product against the duty.
- Click Confirm beside it, or Record a re-check if it was confirmed before.
- Enter the date it was Checked on and, under Evidence, what you looked at. Click Record check.
Article 16(2) requires the responsible person to check regularly that the product complies with its technical documentation and with Article 9(5), (6) and (7), and to provide documented evidence of those checks when a market surveillance authority asks. The regulation sets no interval, so the register asks for each duty again 365 days after its last check; that number is EU Presence's, not the statute's. Every check is kept with its date and evidence and written to the audit log.
What a product's status means
| Status | What it means |
|---|---|
| Obligations outstanding | At least one duty the product owes has never been confirmed. The registry's Status column shows how many are confirmed, such as 3/7. |
| Market-ready | Every duty it owes is confirmed, and none is near its re-check. |
| Re-check due | The oldest check is within 30 days of its re-check. |
| Re-check overdue | The oldest check is past its re-check date. |
| Harmonised scope | The product is covered by Union harmonisation legislation, so the register asks for no Article 9 checks. |
| Withdrawn | The product is off the market. |
The Market-ready tile counts exactly the products that show Market-ready.
Products covered by harmonisation legislation
For a product subject to Union harmonisation legislation, such as a toy or radio equipment, GPSR Article 2(1) disapplies Articles 9 to 18: its identification, documentation and traceability duties come from its own legislation. The registration sheet doesn't set this, so mark it yourself: open the product, choose Edit details, tick Covered by Union harmonisation legislation under Scope and click Save changes. The product then shows Harmonised scope and lists no duties. It can still be recalled.