EU Declaration of Conformity: what it must contain

The model structure, point by point

Annex III of Decision No 768/2008/EC defines the following elements. The legislation for your product may add details (for example the Machinery Directive), but these are always there:

1. Unique identification of the product: a product, type, batch or serial number that ties the declaration to a specific product. A declaration that could apply to "any power adapter" identifies nothing.
2. Name and address of the manufacturer or its authorised representative. The full postal address of the legal entity, not just a brand name or a website.
3. The statement "This declaration of conformity is issued under the sole responsibility of the manufacturer." It must be there in substance; it is the legal core of the document.
4. Object of the declaration: a description that allows traceability, such as product name, model numbers and variants covered. A photograph may be added where appropriate.
5. The statement that the object of the declaration is in conformity with the relevant Union harmonisation legislation, followed by the list of that legislation: every directive and regulation that applies, and none that does not.
6. References to the harmonised standards used, or to the other technical specifications against which conformity is declared, each with its year and any amendments.
7. Where applicable, the notified body: its name and four-digit number, what it did (for example EU type-examination) and the certificate it issued.
8. Additional information, where needed.
9. Signature block: "signed for and on behalf of" the manufacturer, place and date of issue, name and function of the person signing, and the signature.

By drawing up the declaration, the manufacturer assumes responsibility for the compliance of the product (Article R10 of Decision 768/2008/EC).

Which legislation to list

The declaration must list every piece of CE legislation that applies to the product. Where a product falls under several acts, the current directives require one single declaration covering all of them, not one declaration per directive.

Just as important is what not to list. Radio equipment is covered by the Radio Equipment Directive 2014/53/EU, which already includes safety and EMC, so the Low Voltage and EMC Directives are not cited next to it. A battery-powered device below 75 V DC is not within the Low Voltage Directive at all. Listing legislation that does not apply is not "extra safety"; it shows the declaration was built from a template.

Always cite the current acts. Declarations still citing Directive 2006/95/EC (old LVD), 2004/108/EC (old EMC), 1999/5/EC (R&TTE) or 2006/66/EC (Battery Directive) are out of date.

Standards: numbers, years and amendments

Each harmonised standard should be cited with its full reference, for example EN 55032:2015 + A11:2020. The presumption of conformity is linked to the version cited in the Official Journal of the EU; a withdrawn version no longer provides it.

If a standard was only partly applied, the technical documentation must say which parts. And every standard on the declaration must be backed by evidence in the technical file, usually a test report.

Language, updates and how long to keep it

• Language: the declaration must be translated into the language or languages required by each Member State where the product is placed or made available. English alone is accepted in some countries, not all.
• Updates: the declaration must be kept up to date, for example when the product changes or a cited standard is replaced.
• Retention: the declaration is kept together with the technical documentation, typically for 10 years after the product was placed on the market.
• Accompanying the product: some legislation requires a copy with the product. Under the Radio Equipment Directive each product must come with the full declaration or a simplified declaration with an internet address for the full text; machinery instructions must include the declaration or its contents.

Mistakes that make a declaration invalid

• A laboratory test report or "certificate of conformity" issued by a test lab is presented instead of a declaration. Only the manufacturer (or its authorised representative, where allowed) can declare conformity.
• The product cannot be identified: no model numbers, or numbers that differ from the label and listing.
• No signature, or no name and function of the signatory.
• Template text left in: placeholders, another company's name, a different product.
• The declaration is issued by a distributor or reseller that is not the manufacturer and has no mandate.
• Legislation or standards that are repealed, withdrawn or irrelevant to the product.

Frequently asked questions