// GLOSSARY
Conformity Assessment
Conformity assessment is the process by which a manufacturer demonstrates that a product meets the applicable ESPR requirements before placing it on the EU market. The conformity assessment procedure for ESPR products is specified in the relevant delegated act and may involve self-declaration, third-party testing, or certification by a notified body.
Truth Anchor: This definition is based on Regulation (EU) 2024/1781 (ESPR) and related EU legislation. Source: EUR-Lex CELEX:32024R1781
Conformity Assessment Procedures Under ESPR
ESPR Annex VI and Annex VII specify the conformity assessment procedures available for ESPR products. Annex VI covers internal production control (Module A), which allows manufacturers to self-declare conformity based on their own testing and documentation. Annex VII covers management system-based conformity assessment, which requires manufacturers to have a quality management system that covers the ESPR requirements.
When Third-Party Assessment Is Required
For most consumer products, Module A (self-declaration) is sufficient. However, the delegated act for a specific product category may require third-party assessment by a notified body for higher-risk products or for specific performance claims. Manufacturers should check the conformity assessment requirements in the relevant delegated act.
EU Declaration of Conformity
After completing the conformity assessment, the manufacturer issues an EU Declaration of Conformity (EU DoC) that states that the product meets all applicable ESPR requirements. The EU DoC must be kept on file for ten years after the last unit of the product is placed on the EU market and must be made available to market surveillance authorities on request.
CE Marking
Products that have completed conformity assessment and meet all applicable requirements must bear the CE marking. The CE marking indicates that the product meets all applicable EU legislation, including ESPR requirements. The CE marking must be affixed to the product or its packaging before the product is placed on the EU market.
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Conformity Assessment Modules Under ESPR
ESPR Annex VI describes the conformity assessment modules available to manufacturers. The modules are: Module A (Internal Production Control — manufacturer self-declaration, no notified body involvement), Module D1 (Quality Assurance of the Production Process — notified body approves the quality management system for production), Module H (Full Quality Assurance — notified body approves the quality management system for design, production, and final inspection). The delegated act for each product category specifies which modules are available. For most consumer product categories, Module A is expected to be the standard module. For higher-risk product categories, Module D1 or H may be required.
Conformity Assessment and the EU Declaration of Conformity
The conformity assessment process results in the EU Declaration of Conformity (EU DoC), which is the legal document attesting that the product meets the applicable ESPR requirements. The EU DoC must be drawn up by the manufacturer (or the EU Authorised Representative for non-EU manufacturers) and must contain the information specified in Annex VII of ESPR. The EU DoC must be available throughout the product's lifetime and must be provided to market surveillance authorities on request. For products where a notified body has been involved in the conformity assessment, the EU DoC must include the notified body's identification number and the reference to the notified body's assessment report.
Conformity assessment under ESPR follows the New Legislative Framework (NLF) modules established by Decision 768/2008/EC. The NLF provides a menu of conformity assessment modules ranging from Module A (internal production control — manufacturer self-declaration) to Module H (full quality assurance — notified body assessment of the quality management system). The ESPR delegated act for each product category specifies which module or modules the manufacturer may use. For most product categories, Module A will be available — this is the least burdensome option and is appropriate for products where the ecodesign requirements can be verified through product testing and documentation review. For product categories with more complex requirements (such as recycled content claims or carbon footprint claims that require supply chain verification), Module D1 or H may be required.