EU declaration of conformity: what goes in it and who signs it

The Commission’s own wording: “An EU declaration of conformity (DoC) is a mandatory legal document that you as a manufacturer (or your authorised representative) must sign to declare that your products comply with all EU requirements.” It is signed “only after you have complied with the legal requirements for your product i.e. undertaken the relevant conformity assessment, and compiled all the supporting technical documentation” (Your Europe).

The declaration comes from the EU’s product-specific laws, not from GPSR, whose text contains no declaration of conformity. Those laws are built on a common model, the New Legislative Framework: Decision No 768/2008/EC sets the reference clauses, and Regulation (EC) No 765/2008Regulation (EC) No 765/2008, accreditation and market surveillance (CE marking)The whole regulationClick opens the law on the EU Publications Office. sets the principles of the CE marking. By affixing the marking the manufacturer takes responsibility for the product’s conformity with every law that provides for it (Art. 30(3)Regulation (EC) No 765/2008, accreditation and market surveillance (CE marking)Article 30, paragraph 3Click opens the article on EUR-Lex.), and the marking goes only on products whose law provides for it (Art. 30(2)Regulation (EC) No 765/2008, accreditation and market surveillance (CE marking)Article 30, paragraph 2Click opens the article on EUR-Lex.). How the marking and the file fit together is on CE marking.

The Decision is a template for EU lawmakers, not a rule that binds you directly: EU product laws “shall have recourse to” its reference provisions and may depart from them where a sector needs it (Decision No 768/2008/EC, Art. 2). The version that binds you is the article and the annex of your product’s own law, in the table below.

The machinery rules in the table come from the Directive’s Annex II: “This declaration and translations thereof must be drawn up under the same conditions as the instructions […] and must be typewritten or else handwritten in capital letters.” Its point 2 asks for the “name and address of the person authorised to compile the technical file, who must be established in the Community”. Its custody rule: “The manufacturer of machinery or his authorised representative shall keep the original EC declaration of conformity for a period of at least 10 years from the last date of manufacture of the machinery.” Partly completed machinery gets a different document, a declaration of incorporation (Annex II, part 1, section B). The Directive’s Art. 5(1)Directive 2006/42/EC, Machinery Directive (consolidated text of 30 May 2026)Article 5, paragraph 1Click opens the article on EUR-Lex., point (e), is the rule that the declaration “accompanies the machinery”.

The Regulation applies from 20 January 2027 (Art. 54Regulation (EU) 2023/1230, Machinery Regulation (consolidated text of 27 July 2026)Article 54Click opens the article on EUR-Lex.). Its digital declarations “shall be made accessible online for the expected lifetime of the machinery or related product and in any event for at least 10 years” (Art. 10(8)Regulation (EU) 2023/1230, Machinery Regulation (consolidated text of 27 July 2026)Article 10, paragraph 8Click opens the article on EUR-Lex.).

The Blue Guide, section 4.4, settles the points that cause most rejections:

• The number. It “does not need to be unique to each product. It could refer to a product, batch, type or a serial number.” A separate number for the declaration itself is optional; the low-voltage model says so in its footnote 1.
• The image. It “may where relevant for the identification of the product contain an image, but unless specified as a requirement in the Union harmonisation legislation this is left to the discretion of the manufacturer.” The toy model is one law that requires it.
• The standards. They are listed “in a precise, complete and clearly defined way; this implies that the version and/or date of the relevant standard is specified.”
• The form. “The declaration may take the form of a document, a label or equivalent, and must contain sufficient information to enable all products covered by it to be traced back to it.”
• The date. It “could be any date after the completion of the conformity assessment”.

The Your Europe page gives the same list in plain words, ending with “your name and signature” and “the date the declaration was issued”.

A filled-in sample for a product under three directives

Here is the same template filled in for a mains-powered product that falls under the low-voltage, EMC and RoHS Directives, with no radio in it and no notified body involved. The company, the product and the standards are placeholders; the law references are the real ones. Point 5 carries the Official Journal references because one declaration covering several laws must contain “the identification of the Union acts concerned including their publication references” (Art. 15(3)Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 15, paragraph 3Click opens the article on EUR-Lex.).

EU DECLARATION OF CONFORMITY (No DoC-2026-014)

1. Product: Model DL-200, type DL, serial numbers from 26100001
2. Manufacturer: [Your Company Ltd], [street, city, postcode, country]
3. This declaration of conformity is issued under the sole responsibility
   of the manufacturer.
4. Object of the declaration: DL-200 mains-powered [product name],
   230 V AC, colour photograph attached.
5. The object of the declaration described above is in conformity with
   the relevant Union harmonisation legislation:
   - Directive 2014/35/EU (OJ L 96, 29.3.2014, p. 357)
   - Directive 2014/30/EU (OJ L 96, 29.3.2014, p. 79)
   - Directive 2011/65/EU (OJ L 174, 1.7.2011, p. 88)
6. References to the relevant harmonised standards used:
   [EN standard number:year] for electrical safety
   [EN standard number:year] for emissions
   [EN standard number:year] for immunity
   [EN standard number:year] for restricted substances
7. Notified body: not applicable.
8. Additional information: none.

Signed for and on behalf of: [Your Company Ltd]
[City], [date of issue]
[Name], [Managing Director]   [signature]

How a law-specific model differs from the template

Two models show the range. The low-voltage Directive’s Annex IV has 7 points, with no notified-body point, because its one procedure is Module A, the manufacturer’s own control (Art. 6(2)Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 6, paragraph 2Click opens the article on EUR-Lex., Annex III). The radio equipment Directive’s Annex VI has 9: it adds a point on “accessories and components, including software”, and lists the standards “with their identification number and version and, where applicable, date of issue”. Its simplified declaration, Annex VII, is one sentence: “Hereby, [Name of manufacturer] declares that the radio equipment type [designation of type of radio equipment] is in compliance with Directive 2014/53/EUDirective 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.”, followed by the web address of the full text.

The rule comes from the model itself: where several laws require a declaration, “a single declaration shall be drawn up in respect of all Community acts applicable to the product” (Decision No 768/2008/EC, Art. 5). The single declaration may be a bundle: “In order to reduce the administrative burden on economic operators, that single EU declaration of conformity may be a dossier made up of relevant individual declarations of conformity” (recital 22 of Directive 2014/35/EUDirective 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.; the Blue Guide, section 4.4, says the same).

An authorised representative signs only where the manufacturer’s written mandate gives it that task (Art. 7Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 7Click opens the article on EUR-Lex.; Annex III, Module A, point 5, of Directive 2014/35/EUDirective 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.). It cannot take over the design duties or the technical documentation, which stay with the manufacturer (Art. 7(1)Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 7, paragraph 1Click opens the article on EUR-Lex.). Who can act as your EU representative, and what it does beyond the declaration, is on EU responsible person and EU authorised representative.

The same page on finished products built from parts: “If you place the final product on the EU market, you must issue a DoC covering the entire product, even if individual components are already CE marked.”

If you import a product made by someone else under its own brand, you do not sign. You check before selling that the manufacturer carried out the conformity assessment and drew up the documentation (Art. 8(2)Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 8, paragraph 2Click opens the article on EUR-Lex.), and you keep a copy of the declaration for 10 years (Art. 8(8)Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 8, paragraph 8Click opens the article on EUR-Lex.). The same 10-year copy rule is in the compatibility Art. 9(7)Directive 2014/30/EU, Electromagnetic Compatibility Directive (consolidated text of 30 May 2026)Article 9, paragraph 7Click opens the article on EUR-Lex., radio Art. 12(8)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 12, paragraph 8Click opens the article on EUR-Lex., RoHS Art. 9Directive 2011/65/EU, Restriction of Hazardous Substances (RoHS)Article 9Click opens the article on EUR-Lex., point (g), toys Art. 6(8)Directive 2009/48/EC, Toy Safety DirectiveArticle 6, paragraph 8Click opens the article on EUR-Lex., protective equipment Art. 10(8)Regulation (EU) 2016/425, Personal Protective Equipment RegulationArticle 10, paragraph 8Click opens the article on EUR-Lex. and Machinery Regulation Art. 13(8)Regulation (EU) 2023/1230, Machinery Regulation (consolidated text of 27 July 2026)Article 13, paragraph 8Click opens the article on EUR-Lex. texts.

The laws do not say who translates. The Blue Guide, section 4.4: “Union harmonisation legislation does not necessarily specify who has the obligation to translate. Logically, this should be the manufacturer or another economic operator making the product available.” It adds: “If a translation of the EU declaration of conformity has been produced by another economic operator and is not signed by the manufacturer, a copy of the original EU declaration of conformity signed by the manufacturer must also be provided together with the translated version.”

Three laws count differently. Machinery under the Directive counts the 10 years “from the last date of manufacture of the machinery” (Annex II, part 2, of Directive 2006/42/ECDirective 2006/42/EC, Machinery Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.). Packaging under the PPWR is kept “for 5 years from the date the packaging was placed on the market” when it is single-use, and for 10 years when it is reusable (Art. 15(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 3Click opens the article on EUR-Lex.); the importer keeps its copy for the same periods (Art. 18(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 7Click opens the article on EUR-Lex.). For implantable medical devices the declaration is kept for 15 years (Blue Guide, footnote 223); what else the medical device rules ask is on EU MDR.

On updates, the Blue Guide, section 4.4: “as soon as any of the elements of the EU declaration of conformity changes, the version of the EU declaration of conformity will have to be updated for products placed on the market after that change. Such changes may for example be changes in the legislation, changes in the versions of the harmonised standards or changes in the contact details of the manufacturer or authorised representative.” Your Europe adds “switches in conformity assessment bodies or procedures” to that list.

Where the manufacturer is outside the EU, an operator based in the EU must hold the declaration for the authorities: for a product under one of the laws listed in Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office., that operator verifies that the declaration has been drawn up and keeps it at the authorities’ disposal (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex., point (a)).

The Blue Guide, section 4.4, names the laws that make the declaration travel with the product: “machinery, equipment in potentially explosive atmospheres, radio equipment, measuring instruments, recreational craft, lifts, high-speed and conventional rail systems and constituents of the European Air Traffic Management network”.

eBay is one marketplace that ties its request to the declaration. Its Seller Center describes the EU-based responsible person’s task as “Checking that the EU declaration of conformity, CE marking, and other technical documentations are in order, and providing them to the market surveillance authorities to demonstrate the conformity of the product” (eBay Seller Center, read on 5 October 2026; marketplace policy, not law, and it changes without notice). What each marketplace’s form asks for is on GPSR marketplace requirements.

Selling from outside the EU does not take you out of this: an offer online is making the product available in the EU when it targets end users there (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex.).

The Blue Guide, Annex 4, lists the notified body’s task under modules F, F1 and G as: “issues a certificate of conformity”. The manufacturer still signs its own declaration under those modules: under module F it “draws up a written declaration of conformity and keeps it together with […] the certificate of conformity”. The vehicle document is set by Regulation (EU) 2018/858, Art. 36: “The manufacturer shall issue a certificate of conformity in paper format to accompany each vehicle”.

The US document is a different system. The US Consumer Product Safety Commission requires domestic manufacturers and importers of certain general-use products to certify “in a written General Certificate of Conformity (GCC)” that they comply with US safety rules, and “The GCC and supporting information must be in English” (CPSC). A GCC certifies compliance with US rules, so it is not the EU declaration the EU laws above require.

A lab’s test report is not a notified-body certificate either: “When a conformity assessment body delivers a test report it is in its capacity as a conformity assessment body; only in its capacity as notified body can it deliver EU-type examination certificates” (Blue Guide, section 5.2.2). On certificates sold as an extra, the Commission warns: “Some organisations offer ‘voluntary certificates’ that are not valid for CE marking. These are not legally recognised” (Your Europe).

The UK guidance lists what a UK declaration may include: “the name and full business address of the manufacturer, or authorised representative (if applicable)”, “the product’s serial number, model, or type identification”, “a statement, declaring the manufacturer takes full responsibility for the product’s compliance”, “the details of the approved body which carried out the conformity assessment procedure (if applicable)”, the legislation, “references to the relevant designated (UK) or harmonised (EU) standards, including the date of the standard”, “the name and signature of the person authorised to sign”, “the date the declaration was issued” and “supplementary information (if applicable)”. On the CE marking it says “the UK continues to recognise the CE marking, alongside or in place of the UKCA marking, for the Great Britain market”; Northern Ireland takes “CE, or CE and United Kingdom Northern Ireland (UKNI) marked products”.

The Blue Guide, section 7.4, describes what an authority looks at first: the first level of control “comprises documentary and visual checks, for example regarding the CE marking and its affixing, the availability of the EU declaration of conformity, the information accompanying the product and the correct choice of conformity assessment procedures”. The penalties must be “effective, proportionate and dissuasive” (Art. 24Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 24Click opens the article on EUR-Lex., Art. 42Directive 2014/30/EU, Electromagnetic Compatibility Directive (consolidated text of 30 May 2026)Article 42Click opens the article on EUR-Lex.).

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