Quality control and traceability: what the importer must document

Since 13 December 2024, the EU General Product Safety Regulation (GPSR) requires every product to carry a type, batch or serial number and the importer’s details, and the importer must be able to say who supplied it. Your inspection and test reports, tied to the lots, prove your checks.

Suppliers and purchasing · By Guerric Laspougeas · Published 5 October 2026

Why traceability is a quality control matter

For an importer, traceability is the ability to link every product sold to a production lot, a supplier, a factory and the checks carried out. It serves three purposes:

• Limiting a recall: if you know which lots are affected, you only recall those, instead of the whole product line.
• Proving your diligence: with the authorities, your inspection and test reports show what you checked before putting the product on the market.
• Turning to the supplier: a defect tied to a specific lot, with the purchase order and the reference sample, makes a solid claim.

Recalls are not rare. Our Quality Observatory shows the product recalls published in France and the European Safety Gate alerts, updated every week: each recall notice lists the models and references concerned.

What the General Product Safety Regulation requires

Regulation (EU) 2023/988 on general product safety (GPSR) has applied since 13 December 2024 to non-food products sold to consumers in the Union, in shops and online. For traceability, remember:

• Identify the product: a type, batch or serial number, visible and legible to the consumer, or on the packaging or an accompanying document if the product is too small.
• State who places it on the market: the name, registered trade name or trade mark, postal and electronic address of the manufacturer, and those of the importer for a product made outside the EU.
• Designate a responsible person in the Union: a product made in China can only be sold if an operator established in the EU (manufacturer, importer, authorised representative or fulfilment service provider) answers for it to the authorities.
• Know your supply chain: every operator must be able to say who supplied the product and which businesses it sold it to, for six years.
• Make sure the manufacturer has done its job: before placing on the market, the importer checks in particular that the manufacturer has drawn up the technical documentation (the product’s risk analysis) and met these identification obligations.

Other legislation applies depending on the product: the Toy Safety Directive, electrical equipment, REACH for chemical substances. This summary does not replace reading the text of the regulation or legal advice.

The quality documents to tie to each lot

Regulation sets the minimum. To be able to answer any question about a lot, keep together:

One point often overlooked: the origin of the samples tested. A test report on pieces chosen by the factory says little about your lot. At LPI, the inspector draws the samples at the factory and the laboratory tests them: the test report is then tied to actual production.

What the inspection checks for traceability

A final random inspection does not only check appearance and function. It also checks markings and packaging, which includes the traceability elements, provided you have written them into your specifications:

• the presence and legibility of the type or batch number on the product or packaging;
• the label with your importer details, and those of the manufacturer;
• the regulatory markings (CE marking where it applies, warnings, age grading for toys);
• the shipping marks and the number of cartons, which link the lot to the container.

The report, with its photos, then becomes dated evidence of what left the factory. Container loading supervision completes the link between the lot and the container.

The importer’s checklist

• Require a batch number on the product or packaging in your purchase order, and have it checked at inspection.
• Give the factory the label with your importer details, before production.
• Keep the reference sample, signed and dated, for each version of the product.
• File by lot: purchase order, test reports, inspection report, shipping documents.
• Record which business customers each lot was sold to.
• Check the supplier before the first order: our guide how to verify a Chinese supplier explains how, for free.

Traceability links quality assurance and quality control: our guide quality assurance vs quality control explains the difference. For the big picture, read our complete guide to quality control in China.