Declaration of Conformity Guide: EU Requirements & Free Template

67% of EU customs rejections involve missing or invalid Declarations of Conformity.

A CE marking on your product is meaningless without a valid Declaration of Conformity (DoC). Even if your product passes all technical requirements, an invalid DoC can result in:

• Customs blocking shipments at EU borders
• Market surveillance ordering product recalls
• Fines ranging from €10,000 to €100,000+
• Distributor liability claims against you

Who needs a Declaration of Conformity: All manufacturers placing CE marked products on the EU market—regardless of where you manufacture. This includes companies in the United States, China, United Kingdom (post-Brexit), and other non-EU countries.

Critical fact for non-EU manufacturers: You cannot sign your own Declaration of Conformity. You must appoint an EU Authorized Representative to sign on your behalf.

This guide covers what a DoC is, the 8 mandatory elements, who can legally sign, common mistakes that invalidate declarations, and special requirements for manufacturers outside the EU.

What Is a Declaration of Conformity?

The EU Declaration of Conformity is a legal document where the manufacturer (or their EU Authorized Representative) declares that a product complies with all applicable EU directives and harmonized standards.

Key Characteristics:

Self-certification document: You (or your EU AR) declare conformity—no third-party approval required for most products (exceptions: medical devices, machinery with certain hazards, wireless equipment in some cases).

Product-specific: Each product model requires its own DoC. You cannot use one generic DoC for multiple unrelated products.

Mandatory for CE marking: Without a valid DoC, your CE marking has no legal standing. The DoC and CE marking work together—neither is valid without the other.

Must be available on demand: The DoC must be accessible to market surveillance authorities within 48 hours of request. Failure to provide = presumption of non-compliance.

Why the Declaration of Conformity Matters

Customs Enforcement

EU customs authorities can request your DoC at the border. Common issues that trigger customs holds:

• DoC signed by non-EU manufacturer (instead of EU AR)
• Missing EU Authorized Representative information
• References outdated directive versions
• Generic DoC not specific to product model
• No date or incorrect signatory title

Consequence: Shipment held in customs warehouse at €50-200/day storage fees until DoC is corrected. Re-export costs: €3,000-€15,000+.

Market Surveillance Fines

EU member state authorities conduct random market checks. If your DoC is invalid:

Typical fines by country:

• Germany: €25,000-€100,000
• France: €15,000-€75,000
• Netherlands: €20,000-€80,000
• Italy: €10,000-€50,000

Additional penalties: Product recalls (you pay all costs), sales bans, criminal liability in severe cases.

Distributor Liability

Your EU distributors/retailers are legally responsible for ensuring products have valid DoCs. If your DoC is invalid:

• Distributors can refuse orders
• Existing contracts may be voided
• Distributors may sue for their financial losses
• Amazon Europe suspends listings immediately

When Is a Declaration of Conformity Required?

A DoC is mandatory for all products bearing the CE marking, which includes:

Electronics:

• Consumer electronics (phones, laptops, tablets)
• Household appliances
• Power tools
• Lighting equipment
• Audio/video equipment

Industrial Equipment:

• Machinery
• Industrial controls
• Electrical equipment for industrial use
• Pressure equipment

Medical Devices:

• Diagnostic equipment
• Therapeutic devices
• In vitro diagnostic devices

Personal Protective Equipment (PPE):

• Safety helmets
• Protective clothing
• Respiratory protection

Toys:

• All toys sold in EU

Wireless Equipment:

• Radio equipment
• Telecommunications equipment
• WiFi/Bluetooth devices

Construction Products:

• Building materials (uses Declaration of Performance instead, but similar requirements)

The 8 Mandatory Elements of a Declaration of Conformity

Under EU regulations, your DoC must contain these exact elements:

1. Product Identification

Must include:

• Product name/type designation
• Model number
• Serial number, batch number, or other unique identifier
• Sufficient detail to identify the specific product

Example:

Product: Wireless Bluetooth Speaker
Model: BTX-3000
Serial Range: SN 2026001-2026500

Common mistake: Generic description like "electronic device" without model-specific details.

2. Manufacturer Information

Must include:

• Legal name of manufacturer (registered business name)
• Complete registered address (street, city, postal code, country)
• Contact information (phone or email)

Example:

Manufacturer:
TechCorp Manufacturing Inc.
123 Innovation Drive
San Jose, CA 95110
United States
contact@techcorp.com

For non-EU manufacturers: This is YOUR company information, not your EU AR (AR comes in element #3).

3. EU Authorized Representative (If Applicable)

Required if manufacturer is located outside EU/EEA.

Must include:

• Legal name of EU AR
• Complete address within EU/EEA
• Contact information

Example:

EU Authorized Representative:
EcoComply EU Services GmbH
Hauptstrasse 45
10115 Berlin
Germany
info@ecocomply.ai

Critical: If you're a non-EU manufacturer and this section is missing or lists a non-EU address, your DoC is invalid.

4. Sole Responsibility Statement

Exact wording required:

"This declaration of conformity is issued under the sole
responsibility of the manufacturer."

Or if using EU AR:

"This declaration of conformity is issued under the sole
responsibility of the manufacturer [manufacturer name] and
its EU Authorized Representative [AR name]."

Cannot be modified. This is standardized legal language required by EU law.

5. Object of Declaration (Product Description)

Must include:

• Detailed product description
• Intended use
• Key technical characteristics

Example:

Object of the declaration:
Portable wireless Bluetooth speaker with USB-C charging,
IPX7 water resistance, intended for consumer audio playback
in indoor and outdoor environments. Operates on 5V DC,
rechargeable lithium-ion battery.

Why detailed description matters: Market surveillance needs to identify if your declaration matches the actual product.

6. Applicable EU Directives

List all relevant directives by:

• Directive number
• Full official name
• Version (if applicable)

Example for electronics:

The object of the declaration described above is in conformity
with the following Union harmonisation legislation:

- Directive 2014/30/EU (Electromagnetic Compatibility Directive)
- Directive 2014/35/EU (Low Voltage Directive)
- Directive 2011/65/EU (RoHS Directive)
- Directive 2012/19/EU (WEEE Directive)

Common mistake: Using outdated directive numbers (e.g., listing EMC Directive 2004/108/EC instead of current 2014/30/EU).

Warning: If you claim compliance with wrong directives or miss applicable ones, your entire DoC is invalid.

7. Harmonized Standards Applied

List specific standards used for conformity assessment:

Example:

References to the relevant harmonised standards used:

- EN 55032:2015 (Electromagnetic compatibility of multimedia equipment)
- EN 55035:2017 (EMC immunity requirements)
- EN IEC 63000:2018 (RoHS assessment)
- EN 62368-1:2014+A11:2017 (Safety of audio/video equipment)

Must include:

• Standard number
• Publication year
• Amendment versions (if applicable)

Common mistake: Listing standards without year/version (e.g., "EN 55032" instead of "EN 55032:2015").

For products without harmonized standards: State "No harmonized standards available. Conformity assessed through [method used]."

8. Signatory Information

Must include:

• Name of person signing
• Position/title
• Place of signature (city, country)
• Date of signature
• Actual signature (handwritten or digital)

Example:

Signed for and on behalf of:

Name: John Smith
Position: Director of Regulatory Affairs
Place: San Jose, California, USA
Date: February 8, 2026

[Signature]

Critical rule for non-EU manufacturers:

• ❌ Your US/China/UK-based employee CANNOT sign
• ✅ Your EU Authorized Representative MUST sign

Example for non-EU manufacturer:

Signed for and on behalf of:

Name: Maria Schmidt
Position: Managing Director
Organization: EcoComply EU Services GmbH (EU Authorized Representative)
Place: Berlin, Germany
Date: February 8, 2026

[Signature]

Free Declaration of Conformity Template

EU DECLARATION OF CONFORMITY

1. Product Model/Type:
  [Product name and model number]
  Serial Number/Batch: [Range if applicable]

2. Manufacturer:
  Name: [Legal entity name]
  Address: [Complete registered address]
  Contact: [Email/phone]

3. EU Authorized Representative (if manufacturer located outside EU):
  Name: [AR legal name]
  Address: [Complete address within EU]
  Contact: [Email/phone]

4. Responsibility Statement:
  This declaration of conformity is issued under the sole
  responsibility of the manufacturer.

5. Object of the Declaration:
  [Detailed product description, intended use, key specifications]

6. Applicable EU Directives:
  The object of the declaration described above is in conformity
  with the following Union harmonisation legislation:
 
  • Directive [Number/Year] ([Name])
  • Directive [Number/Year] ([Name])
  • [Add all applicable directives]

7. Harmonized Standards Applied:
  References to the relevant harmonised standards used:
 
  • [Standard number:year] ([Standard name])
  • [Standard number:year] ([Standard name])
  • [List all standards used]

8. Notified Body (if applicable):
  Name: [Notified body name]
  NB Number: [4-digit number]
  Certificate Number: [If issued]

9. Additional Information:
  [Any relevant compliance notes, exemptions claimed, special conditions]

10. Signatory:
   Signed for and on behalf of:
   
   Name: [Full name]
   Position: [Title]
   Organization: [Company or EU AR name]
   Place: [City, Country]
   Date: [DD/MM/YYYY]
   
   _______________________
   [Signature]

---
For questions about this declaration:
Contact: [Email/phone]
Website: [Company website]

7 Common Mistakes That Invalidate Your Declaration of Conformity

Mistake #1: Using Generic Templates Across Multiple Products

The problem: One DoC for "all electronic products" or "product line X."

Why it fails: Each product model requires specific identification. Market surveillance cannot verify compliance without model-specific information.

The fix: Create individual DoCs for each distinct product model. Products with identical technical characteristics but different model numbers still need separate DoCs.

Mistake #2: Wrong Signatory (Most Common for Non-EU Manufacturers)

The problem: US/Chinese/UK-based CEO signs the DoC instead of EU Authorized Representative.

Why it fails: EU law requires DoC signed by entity with legal presence in EU. Non-EU signatories have no legal standing.

Real example: California manufacturer ships to Germany. DoC signed by US CEO. Customs blocks shipment. Must revise DoC with EU AR signature and re-submit = 2-3 week delay + storage fees.

The fix:

• EU manufacturers: Sign with authorized company representative
• Non-EU manufacturers: EU AR must sign
• Verify signatory has actual authority to bind the company

Mistake #3: Missing or Incomplete Standards References

The problem: Listing "EN 55032" without year, or stating "All applicable standards" generically.

Why it fails: Market surveillance needs to verify you used current standard versions. Generic references don't allow verification.

The fix:

• List complete standard number with year: "EN 55032:2015"
• Include amendments: "EN 62368-1:2014+A11:2017"
• If using multiple test reports over time, reference the specific versions used

Mistake #4: Incomplete Product Identification

The problem: "Bluetooth speaker" without model number, serial range, or distinguishing details.

Why it fails: Cannot determine which specific product the DoC applies to. If you sell multiple speaker models, which one is compliant?

The fix: Include:

• Exact model designation
• Serial number range or batch information
• Key identifying characteristics (color, size variants if they affect compliance)

Mistake #5: No Date or Outdated Date

The problem: DoC has no signature date, or date is from years ago but product recently modified.

Why it fails: DoC must reflect current product version. If product changes (different components, updated firmware), DoC date should reflect when current version was certified compliant.

The fix:

• Always include signature date
• Update DoC date when making product changes affecting compliance
• Maintain version control: "DoC Version 2.1, dated February 2026"

Mistake #6: Attempting to Cover Multiple Unrelated Products

The problem: One DoC listing "Bluetooth speaker models BTX-1000, BTX-2000, BTX-3000" when these are different products with different power ratings, frequencies, components.

Why it fails: Each technically distinct product requires separate conformity assessment = separate DoC.

The fix: One DoC per product model. Exception: Multiple color/cosmetic variants of identical technical design can share one DoC if you note "Available in multiple colors" in product description.

Mistake #7: Not Updating DoC When Standards Change

The problem: DoC references "EN 62368-1:2014" but test report actually used updated "EN 62368-1:2014+A11:2017."

Why it fails: DoC must accurately reflect which standard versions you assessed compliance against. Mismatch between DoC and test reports = invalid declaration.

The fix:

• Review DoC annually
• Update when new standard versions published
• Update when directives change (rare, but happens)
• Maintain document version control

Declaration of Conformity vs. Test Reports

Common confusion: "Are test reports the same as a Declaration of Conformity?"

No. They serve different purposes:

Relationship: Test reports support your DoC but don't replace it. Your DoC references which standards you assessed compliance against (element #7), and test reports provide the technical evidence.

Example flow:

1. You send product to EMC testing lab
2. Lab issues test report: "Product XYZ passed EN 55032:2015 emissions testing"
3. You include that standard in DoC element #7
4. You keep test report in technical file (not required to be ON the DoC itself)
5. If market surveillance asks, you provide both DoC and supporting test reports

Where Must the Declaration of Conformity Be Available?

1. At Manufacturer's Location (or EU AR)

Requirement: DoC must be accessible within 48 hours of market surveillance request.

For non-EU manufacturers: Your EU AR maintains DoC and must respond to authorities.

Storage requirement: 10 years after last product placed on market.

2. With Product Documentation

Physical products: DoC should accompany product or be easily accessible to end user.

Options:

• Printed DoC in product box
• QR code on packaging linking to online DoC
• Download link on product quick-start guide

GPSR requirement (December 2024): Product labeling must show how to access DoC (QR code, URL, or physical inclusion).

3. Available to Distributors

Requirement: Distributors must verify DoC exists before placing product on market.

Best practice:

• Provide DoC to distributors before first shipment
• Include DoC in B2B product documentation
• Make DoC available via secure distributor portal

Distributor responsibility: If you don't provide valid DoC, distributor is legally liable. They may refuse to sell your products.

4. Upon Request to Market Surveillance

Timeline: 48 hours from request.

How requests happen:

• Random market checks
• Consumer complaints
• Customs inspections
• Incident investigations (product failure, safety issue)

What to provide:

• DoC (all 8 elements)
• Technical file (if requested separately)
• Test reports (if requested)

Electronic vs. Paper Declaration of Conformity

EU law allows electronic DoCs, but with requirements:

Electronic DoC Requirements:

✅ Must be easily accessible:

• QR code on product packaging linking directly to DoC
• Download link on product quick-start guide
• Available on product page of your website

✅ Must be downloadable/printable:

• PDF format preferred
• User can save/print for records

✅ Must be permanent:

• URL cannot be temporary
• DoC must remain accessible for 10 years
• If product discontinued, DoC must still be available

✅ Must be verifiable:

• File name/version clearly identifies product
• Date stamp visible

When Paper DoC Is Safer:

• B2B products (distributors expect physical copy)
• Markets with limited internet access
• High-value equipment (customers expect documentation package)
• When local regulations require physical copy (some EU member states)

Best practice: Provide both—physical DoC in box + QR code to digital version.

Multi-Directive Products: Single or Multiple DoCs?

Question: If my product complies with EMC, LVD, RoHS, and RED directives, do I need four separate DoCs?

Answer: ONE Declaration of Conformity listing all applicable directives.

Example:

The object of the declaration described above is in conformity
with the following Union harmonisation legislation:

- Directive 2014/30/EU (EMC)
- Directive 2014/35/EU (LVD)
- Directive 2011/65/EU (RoHS)
- Directive 2014/53/EU (RED)

Exception: If product falls under multiple regulations requiring different notified body certifications, you might have separate certificates, but still one consolidated DoC referencing all.

RoHS Special Considerations in Declaration of Conformity

If your product contains restricted substances under exemptions:

Must state in DoC:

Additional Information:
This product complies with RoHS Directive 2011/65/EU.
Exemptions claimed:
- Annex III, Exemption 6(c): Lead in copper alloy (brass connectors)
- Annex III, Exemption 7(c)-I: Lead in electronic ceramic parts

Why this matters:

• Market surveillance verifies exemption claims
• If exemption expires and DoC still claims it, your DoC is invalid
• RoHS Exemptions 2026 article

Declaration of Conformity Requirements for Non-EU Manufacturers

Critical Rules for US, Chinese, UK, and Other Non-EU Companies:

1. You CANNOT Sign Your Own DoC

❌ Invalid: US-based CEO signs DoC ✅ Valid: EU Authorized Representative signs DoC

Why: EU law requires legal entity with EU presence to take responsibility for market surveillance compliance.

2. EU AR Information Must Be on DoC (Element #3)

Required on DoC:

• EU AR legal name
• Complete EU address
• Contact information

Also required on product:

• Product labeling/packaging must show EU AR name and address
• This is separate from CE marking—both required

3. Your Company Info Still Goes on DoC (Element #2)

DoC shows:

• Section 2: Your company (US/China/UK address)
• Section 3: Your EU AR (EU address)
• Section 8: EU AR signs (not you)

Why both: Market surveillance can contact you directly, but EU AR handles legal response.

4. Product Labeling Requirements (Post-GPSR December 2024)

Must appear on product or packaging:

Manufacturer: TechCorp Inc., San Jose, CA, USA
EU Authorized Representative: EcoComply GmbH, Berlin, Germany

Cannot show only US address—must include EU AR.

5. Technical File Must Be Accessible in EU

Requirement: EU AR maintains your technical file (including DoC) accessible in EU within 48 hours of request.

What this means:

• You can't respond to EU market surveillance directly from US/China
• EU AR needs access to your documentation
• Must be available for 10 years after last product placed on market

Practical solution: Cloud-based technical file management shared with EU AR, or EU AR maintains complete copy.

Geographic-Specific Challenges:

🇺🇸 US Manufacturers:

Common mistake: Assuming FCC/UL compliance = CE marking compliance.

Reality:

• FCC ≠ EMC Directive (different standards, test methods)
• UL ≠ LVD (different safety requirements)
• Must conduct separate EU testing or use mutual recognition agreements (MRAs) where applicable

DoC requirement: Separate EU DoC even if you have FCC/UL declarations.

🇨🇳 Chinese Manufacturers:

Common mistake: Using China RoHS self-declaration as EU DoC.

Reality:

• China RoHS declaration format differs from EU
• China CCC marking ≠ CE marking
• Must create separate EU-format DoC

AR challenge: Many Chinese manufacturers use "paper" ARs (mail-forwarding services with no actual representation). EU customs check these—invalid AR = customs block.

Solution: Use legitimate EU AR service with actual legal presence and responsiveness.

How to Choose an EU Authorised Representative

🇬🇧 UK Manufacturers (Post-Brexit):

New requirement: UK is now "non-EU" for compliance purposes.

If selling in EU:

• Need EU AR (even though pre-Brexit you didn't)
• Need separate EU DoC (UKCA declaration doesn't count)
• Product must show both UK address (manufacturer) and EU AR address

If selling in UK only:

• Use UKCA marking + UK Declaration of Conformity (different format)
• No EU AR needed

If selling in both:

• Maintain two separate declarations (EU DoC + UK DoC)
• Two sets of compliance documentation
• Track different standard versions (UK sometimes adopts EU standards later)

EU vs UK Authorised Representatives: What changed after Brexit

🇯🇵🇰🇷🇹🇼 Japanese/Korean/Taiwanese Manufacturers:

Common issue: Local domestic standards (PSE, KC, BSMI) differ from EU.

Reality:

• Japan PSE ≠ EU LVD
• Korea KC ≠ EU EMC
• Taiwan BSMI ≠ EU RED
• Must conduct separate EU testing

DoC requirement: EU-format DoC with EU AR signature, even if similar declarations exist for domestic markets.

How EcoComply Helps with Declaration of Conformity

Creating a legally compliant DoC requires:

• Understanding which 8 elements are mandatory
• Knowing which EU directives apply to your product
• Listing correct harmonized standards (with versions)
• Having an EU Authorized Representative sign (if non-EU manufacturer)
• Maintaining 10-year records accessible in EU

EcoComply's AI-powered compliance platform:

✅ DoC Generation Tool

• Auto-populates mandatory elements
• Identifies applicable directives based on product type
• Suggests relevant harmonized standards
• Generates properly formatted DoC in minutes

✅ EU Authorized Representative Services

• Required for all non-EU manufacturers
• Signs your Declaration of Conformity
• Maintains technical files in EU
• Responds to market surveillance
• Starting at €1,200/year

✅ Compliance Validation

• Checks DoC against EU requirements
• Flags missing elements before you ship
• Verifies directive versions current
• Ensures signatory has legal authority

Traditional DoC creation:

• Compliance consultant: €800-€2,000 per product
• Timeline: 1-2 weeks
• Updates: Additional fees

[Get DoC Template](CTA link) | [Book Expert Consultation](CTA link) | [Learn About EU AR Services]

Additional Resources

Official EU Resources:

• EU Declaration of Conformity Requirements (Blue Guide) - Official guidance on DoC requirements
• CE Marking Portal - European Commission CE marking information
• Market Surveillance Portal - EU market surveillance information
• NANDO Database - Notified body search

Testing & Certification Bodies:

• TÜV Rheinland CE Marking Services
• Intertek CE Marking Testing
• UL Solutions CE Mark
• SGS CE Marking

Industry Guidance:

• DIGITALEUROPE Technical Guides
• IPC Regulatory Compliance
• EUSAMA (EU Single Market Authorities)

Next Review: When EU directives update (typically annual check)