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Technical compliance file: UK importer checklist

Request a file tied to the exact product revision: specifications, risk assessment, complete test evidence, applicable conformity documents, labels and instructions. Keep a controlled copy with batch links, an update owner and a retention plan. Cambridge China Bridge can help obtain factory documents through its staff in China.

Written by Bono Xu, Founder, Cambridge China Bridge · 3 min read · Updated 2026-10-04

A leather folder, notebooks and a pen laid out on a wooden desk

Agree the file contents before ordering

Start with the intended use, users, sales territory and exact product configuration. Ask the supplier to identify the applicable product requirements and assessment route, then agree a document index and delivery responsibilities before ordering. Our guide to UKCA, CE and ISO explains the different documents suppliers call certification.

Request the product specification, drawings, BOM, material and component specifications, risk assessment, test reports, conformity documents, label artwork and instructions. Add production controls and any relevant assessment-body documents. Treat this as a request checklist to adapt to the product, rather than a universal statutory contents list.

Ask for risk decisions, not just a pass result

Manufacturers remain responsible for assessing product risks, identifying relevant requirements and documenting how they address them. Ask for an assessment covering the actual product and intended use, rather than an unsigned template with the model name changed.

Look for identified hazards, who could be harmed, the design measures used, supporting evidence and remaining risks addressed in instructions. Ask the reviewer to explain gaps, including foreseeable misuse, installation, cleaning or maintenance where relevant. A report saying a sample passed does not explain every design decision.

Connect each test to the goods you will receive

Request complete reports, including sample descriptions, photographs, methods, results, limitations and attachments. Match the tested sample to the model, rating, materials, components and revision you ordered. Ask the laboratory to verify authenticity and explain whether any differences need further assessment or testing.

Keep a coverage register linking each identified requirement or hazard to its supporting evidence. Flag missing tests, unexplained exclusions and reports for related models. Record the reason for accepting evidence and who reviewed it. Keep conformity documents alongside the reports; use our declaration of conformity checks for the declaration itself.

Retain a retrievable record for each revision

Keep a controlled copy accessible to your business, with an index showing document titles, revisions, dates, owners and outstanding gaps. If the factory restricts access to confidential drawings, agree an access arrangement before ordering and check that it meets your product-specific obligations. Test retrieval rather than relying on a promise.

Record the applicable retention period and its starting event after checking the rules for your product. Link each released revision to the batches supplied, labels, instructions and approval records. Preserve superseded versions so you can reconstruct what supported goods already sold. Our factory-to-customer traceability guide covers the batch links.

Name the owner and control updates

Confirm with the relevant authority which conformity checks and record-access duties apply to you as importer, and whether selling under your own name or trade mark brings manufacturer responsibilities, alongside reviewing the certification guide. Assign a named person in your business to manage the file; confirm your responsibilities even when obtaining documents through an agent.

Agree that the factory will flag proposed changes to materials, components, software, production processes and suppliers before using them. Have a competent reviewer decide which risks, reports, declarations and instructions need updating, then retain the decision and released revision. Include complaints and newly identified hazards in reviews. Use our design revision guide to control changes.

Frequently asked questions

Is a test certificate enough for a technical file?

No. Request complete reports and the product details, risk assessment and applicable conformity documents that explain what was assessed. Check that they describe the configuration you will buy.

Must I keep the technical file myself?

Keep a controlled copy and agree access to any restricted documents. Check your product-specific duties before relying on the factory to hold the file. Confirm with the relevant authority whether own-brand sales bring manufacturer responsibilities.

How long should I keep product compliance documents?

Check the retention period and starting event under the rules for your product. Record both in your file index and link them to supplied batches. Do not use a customs-record retention policy without checking.

When should I update a product technical file?

Review it when the product, materials, components, software or relevant requirements change, and when complaints reveal new hazards. Record whether existing evidence still applies and retain the review decision.

Sources

  1. GOV.UK: Placing UKCA or CE marked products on the market in Great Britain

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