The technical documentation: who holds it, and for how long
Annex IV Part A is drawn up before the machine goes on the market and kept for at least ten years afterwards. Importers and authorised representatives carry their own versions of that duty, and none of it is the same as the manual.
The technical documentation is the file that proves the machine was designed and built to the essential health and safety requirements. It is the least visible document in the regulation, because unlike the instructions and the declaration it never travels with the machine and no customer ever asks for it. It is also the one with the longest tail.
“Before placing machinery or a related product on the market or putting it into service, manufacturers shall draw up the technical documentation set out in Annex IV, Part A and carry out the relevant conformity assessment procedure referred to in Article 25 or have it carried out.”
Before, not after
The sequence in that sentence is the point. The file is drawn up, then the conformity assessment is carried out against it, then the declaration is signed, then the CE marking goes on. A file assembled after the machine shipped, to answer a question from an authority, is not the thing the regulation describes.
Ten years at the disposal of authorities
“Manufacturers shall keep the technical documentation and the EU declaration of conformity at the disposal of the market surveillance authorities for at least 10 years after the machinery or the related product has been placed on the market or put into service. Where relevant, the source code or the programming logic included in the technical documentation shall, upon a reasoned request, be made available to the competent national authorities, if that source code or programming logic is necessary in order for them to be able to check compliance with the essential health and safety requirements set out in Annex III.”
"At the disposal of" is a lower bar than the instructions have to meet. This file does not go online and does not go to users; it has to be producible for market surveillance authorities on request. A locked cabinet satisfies it. A locked cabinet whose key left with an employee in 2029 does not.
The second half of that paragraph is easy to skim and worth re-reading: where relevant, source code or programming logic in the file has to be made available to competent national authorities on a reasoned request, if they need it to check the essential requirements. For a machine whose safety depends on software, the file includes things a drawing archive does not.
Three parties, three versions of the same duty
“Importers shall, for at least 10 years after the machinery or related product has been placed on the market, keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities and ensure that the technical documentation set out in Annex IV, Part A, can be made available to those authorities upon request.”
An importer does not have to hold the technical documentation. They have to keep a copy of the declaration and be able to make the technical documentation available on request - which in practice means a contractual route back to a manufacturer who may be on another continent, and who has no duty to you once the commercial relationship ends.
“keep the technical documentation and the EU declaration of conformity of machinery and related products or the EU declaration of incorporation of partly completed machinery at the disposal of the national market surveillance authorities for at least 10 years after the product has been placed on the market;”
An authorised representative does hold it. That is the core of the mandate and the one task that cannot be written out of it. Note what Article 12(1) excludes: drawing the file up is never part of a representative's mandate. Holding it is; producing it is not.
It is not the manual, and the clocks are not the same
Three documents, three retention rules, and they are routinely merged into one wrong idea of "keep everything for ten years". The instructions are online, for users, for the expected lifetime and at least ten years. The declaration is online if digital, on its own clock. The technical documentation is not online at all, is for authorities only, and runs ten years from placing on the market or putting into service. The guide on the ten year availability requirement takes the three apart properly.
What this guide does not cover
What goes in the file is Annex IV Part A, and for partly completed machinery Part B - a long list covering drawings, calculations, test results, the risk assessment and the standards applied. Building one is an engineering job, not a hosting job, and reproducing the annex here would help nobody. Read the official text or ask a notified body.
Everplate is where this documentation lives
Upload the manuals and declarations you already have and you get a QR code, plate artwork and a permanent address, in every language you sell into. Published revisions are never deleted, so what you served in 2027 is still provable in 2037.