Are photographs required in the Technical file?

Yes, photographs are required in a Technical File.

Regulatory authorities expect visual evidence to quickly identify the product, trace its variants, and verify its labels and testing conditions.

What Kind of Photographs Must Be Included?

1. Product Identification: High-quality, clear photos showing the entire product from multiple angles (front, back, sides).
2. Markings and Labels: Close-up, legible photos of the product tracking label, safety warnings, country of origin, CE/FCC marks, and the packaging.
3. Internal Components: For electronic or complex mechanical items, photos of internal circuit boards, critical safety switches, and wiring layouts.
4. Test Setups: Photographs showing how the product was positioned during laboratory testing (often embedded directly inside the lab test reports).

Why Regulators Require Them:

• Visual Match: If a market surveillance authority (like the CPSC or an EU agency) audits your file, they use photos to verify that the product sold in stores exactly matches the sample that passed the laboratory testing.
• Customs Inspections: Border agents use the product and packaging photos in the file to quickly clear shipments held at the port of entry.
• Traceability: Under the EU General Product Safety Regulation (GPSR), photos establish a clear link between the physical item, its digital listing, and its batch numbers.