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Product categories / Prams and pushchairs

GPSR technical documentation for prams and pushchairs — template and requirements

Prams and pushchairs are not covered by any CE legislation, so the GPSR applies in full. The manufacturer must carry out its own risk analysis and draw up technical documentation — and because EN 1888 is not cited in the Official Journal, the test report is supporting evidence rather than a presumption of safety.

Which rules apply?

No CE harmonisation legislation applies — the GPSR applies in full, including the manufacturer's internal risk analysis and technical documentation (Art. 9). The product must not bear CE marking. EN 1888 is not listed in the OJ and therefore gives no presumption, but it is the established basis for the safety assessment (Art. 8). EN 1466 for carry cots is listed.

LegislationRole
(EC) No 1907/2006
REACH — Annex XVII (restrictions)
PAHs, phthalates
(EC) No 765/2008
Regulation on accreditation and CE marking
No CE marking
(EU) 2023/988
General Product Safety Regulation (GPSR)
Primary legislation
(EU) 2026/901
Implementing Decision on European standards under the GPSR
List of standards giving presumption

Standards

  • EN 1466:2014 — Child care articles — Carry cots and stands
    Listed in (EU) 2026/901 (presumption under GPSR Art. 7), incl. EN 1466:2014/AC:2015.
  • EN 1888-1:2018 — Child care articles — Wheeled child conveyances (prams and pushchairs)
    Not listed in (EU) 2026/901 — gives no presumption of conformity, but is the established basis for the safety assessment under GPSR Art. 8. Check for the latest edition.
  • EN 1888-2:2018 — Child care articles — Pushchairs for children above 15 kg
    Not listed in (EU) 2026/901. Check for the latest edition.

Template: what the technical file must contain

This structure is the same as in the technical file generated by the tool. Requirements that only apply to some products show their condition.

Product details and economic operators

  • Economic operator in the EUCritical

    The product may not be placed on the market unless an economic operator established in the EU is responsible for it. Name and contact details must appear on the product, its packaging, the parcel or an accompanying document.

    GPSR Art. 16(1) / Reg. (EU) 2019/1020 Art. 4 · Information · Applies if “Is the manufacturer established outside the EU?” Yes

  • General product description and safety-relevant propertiesCritical

    The technical documentation must contain a general description of the product and its essential properties relevant for assessing its safety.

    GPSR Art. 9(2)(a) · Information

  • Manufacturer name, postal address and emailCritical

    The manufacturer's name, registered trade name or trade mark, postal address and electronic address must be indicated on the product or, where that is not possible, on the packaging or in an accompanying document.

    GPSR Art. 9(6) · Information

Risk analysis and assessments

  • Internal risk analysisCritical

    Before placing the product on the market, the manufacturer must carry out an internal risk analysis and draw up technical documentation analysing possible risks and the solutions adopted, including the results of tests.

    GPSR Art. 9(2) and 9(2)(b) · Document

Test reports and certificates

  • EN 1888-1 test reportCritical

    Shows stability, braking, locking devices, strength and protection against pinching and falls, among others. The standard is not listed in the OJ and therefore gives no presumption, but it is the established basis for the safety assessment.

    GPSR Art. 8 (European standard not cited under Art. 7) · Test report / certificate

  • EN 1888-2 test reportCritical

    Requirements for pushchairs intended for children weighing more than 15 kg. Not listed in the OJ.

    GPSR Art. 8 · Test report / certificate · Applies if “Is the seat unit intended for children above 15 kg?” Yes

  • EN 1466 test report (carry cot)Major

    Requirements on the carry cot's stability, handles and strength. EN 1466:2014 is listed in the OJ and gives a presumption of conformity with the general safety requirement for the risks it covers.

    GPSR Art. 7(1); (EU) 2026/901 Annex I no. 15 · Test report / certificate · Applies if “Is a carry cot included?” Yes

  • PAH test report for handles and rubber partsMajor

    Rubber and plastic parts in direct and prolonged or repeated contact with the skin, such as handles and bumper bars, must not contain more than 1 mg/kg of any listed PAH.

    REACH Annex XVII entry 50(5) · Test report / certificate

  • Phthalate test report for plasticised materialMajor

    Plasticised material in articles must not contain more than 0.1 % by weight of DEHP, DBP, BBP or DIBP, individually or in combination.

    REACH Annex XVII entry 51 · Test report / certificate · Applies if “Does the pram have plasticised parts (e.g. a PVC rain cover)?” Yes

Declarations, instructions and procedures

  • Product listing with mandatory informationMajor

    The listing must clearly show: the manufacturer's name, postal and email address; the responsible person in the EU if the manufacturer is outside the EU; a picture and identification of the product (type and other identifier); and warnings and safety information in a language consumers easily understand.

    GPSR Art. 19 · Document · Applies if “Is the product sold through a webshop or marketplace (e.g. Amazon)?” Yes

  • Accident reporting procedureMinor

    The manufacturer must ensure that accidents caused by the product are notified without undue delay to the competent authority via the Safety Business Gateway.

    GPSR Art. 20 · Document

  • Instructions and safety information in the target market languageMajor

    The product must be accompanied by clear instructions and safety information in a language consumers easily understand, as determined by the Member State where it is made available.

    GPSR Art. 9(7) · Document

Marking and warnings

  • Product identification (type, batch or serial number)Major

    The product must bear a type, batch or serial number or other element allowing its identification, easily visible and legible for consumers — or, where the size does not allow it, on the packaging or in an accompanying document.

    GPSR Art. 9(5) · Marking

  • Warnings and safety informationCritical

    Warnings on the product and in the instructions, including that the child must never be left unattended, that locking devices must be engaged before use, that the harness must be used and that loads on the handle affect stability. EN 1888-1 sets out the wording.

    GPSR Art. 9(7); EN 1888-1 (safety information) · Marking

  • Check: no CE markingMinor

    CE marking may only be affixed where Union harmonisation legislation provides for it. Prams are not covered, so any CE marking on the product or packaging must be removed.

    Reg. (EC) No 765/2008 Art. 30(2) · Marking

Start the gap analysis for your product

Answer 5 questions — you'll see straight away which of the 15 requirements apply and what is missing.

Is the manufacturer established outside the EU?
If yes, an economic operator in the EU is required (importer, authorised representative or fulfilment service provider).
Is the product sold through a webshop or marketplace (e.g. Amazon)?
GPSR Art. 19 sets out what the product listing must show.
Is a carry cot included?
Is the seat unit intended for children above 15 kg?
Pushchairs for children above 15 kg are covered by EN 1888-2.
Does the pram have plasticised parts (e.g. a PVC rain cover)?
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Reviewed by an expert. Rule set version 2, last reviewed 2026-10-10. This page helps you find gaps and does not replace an assessment by an expert or test laboratory.