What goes into the technical documentation?

Last reviewed 5 October 2026. Source: Regulation (EU) 2019/1009, consolidated text of 1 July 2026.

In simple words

The technical documentation is the set of documents that shows your product follows the rules. It must make a check possible and it must include an analysis of the risks. Annex IV lists what it must contain, where this applies.

Words in this article

Technical documentation: The set of documents that show the product follows the rules. It includes the product description, the materials, the production process, test reports and the label.
PFC (product function category): A group that says what the product does. There are 7 groups: fertiliser (PFC 1), liming material (PFC 2), soil improver (PFC 3), growing medium (PFC 4), inhibitor (PFC 5), plant biostimulant (PFC 6) and fertilising product blend (PFC 7).
CMC (component material category): A group of materials a product can be made from. There are 15 groups: virgin material substances and mixtures (CMC 1), plants, plant parts or plant extracts (CMC 2), compost (CMC 3), fresh crop digestate (CMC 4), digestate other than fresh crop digestate (CMC 5), food industry by-products (CMC 6), micro-organisms (CMC 7), nutrient polymers (CMC 8), polymers other than nutrient polymers (CMC 9), derived products (CMC 10), by-products (CMC 11), precipitated phosphate salts and derivates (CMC 12), thermal oxidation materials and derivates (CMC 13), pyrolysis and gasification materials (CMC 14) and recovered high purity materials (CMC 15).
Fertilising product blend (PFC 7): A product made by mixing two or more EU fertilising products that already follow the rules.
EU declaration of conformity (DoC): A signed document in which the manufacturer states that the product follows the rules.
Annex: An appendix of the regulation with detailed rules.

The list for Module A

A general description of the product. Include the PFC that fits its function and how it is meant to be used.
A list of all materials. Include the CMC of each material and where it comes from or how it is made.
For a blend: the declarations of conformity of the products in the blend.
Drawings, schemes and explanations of the production process.
A sample of the label or leaflet with the information that Annex III requires.
A list of the standards and other technical specifications that you used.
The results of calculations and examinations.
Test reports.
For by-products (CMC 11): evidence that they meet the criteria in the waste rules.
If the product has more than 200 mg/kg of total chromium (dry matter): the maximum amount and the exact source.

Modules B and D1

The lists for Module B and Module D1 are similar. Some materials need extra items. With Module B you send the technical documentation, samples and evidence to the notified body. With Module D1 the auditors read it during the audit of your quality system.

Why does it matter?

Authorities and notified bodies ask for these documents first. A complete, up-to-date file in the right language saves time.

Common questions

How long must I keep the technical documentation?

Keep it for 5 years after the product is first sold in the EU (Article 6(3)).