EU Declaration of Conformity Format Under ESPR
The EU Declaration of Conformity (EU DoC) is the formal document by which a manufacturer declares that their product complies with all applicable EU legislation, including ESPR Regulation (EU) 2024/1781. The EU DoC is a legal document — signing it creates legal liability for the signatory. Every ESPR-regulated product must have an EU DoC before it can carry the CE marking and be placed on the EU market.
Required Contents of the EU Declaration of Conformity
ESPR Article 30 and Annex VI, Section 2 specify the mandatory contents of the EU Declaration of Conformity. The document must include: the product name, model, type, batch, or serial number; the name and address of the manufacturer (or EU Authorised Representative for non-EU manufacturers); a statement that the EU DoC is issued under the sole responsibility of the manufacturer; the object of the declaration (product description); references to the relevant harmonised standards or technical specifications applied; references to the applicable ESPR delegated act; the name and address of any notified body involved (if Annex VII was used); the date of issue; and the signature of the authorised signatory.
| Element | Content Required | ESPR Reference |
|---|---|---|
| Product identification | Name, model number, type, batch/serial number | Annex VI, Section 2(1) |
| Manufacturer details | Full name, address, contact details | Annex VI, Section 2(2) |
| Sole responsibility statement | "This declaration of conformity is issued under the sole responsibility of the manufacturer" | Annex VI, Section 2(3) |
| Object of declaration | Description of the product and its intended use | Annex VI, Section 2(4) |
| Harmonised standards | List of EN standards applied, including version numbers | Annex VI, Section 2(5) |
| Applicable legislation | Reference to ESPR and applicable delegated act | Annex VI, Section 2(6) |
| Notified body (if applicable) | Name, address, and notification number of notified body | Annex VI, Section 2(7) |
| Date and signature | Date of issue and signature of authorised person | Annex VI, Section 2(8) |
Who Can Sign the EU Declaration of Conformity?
The EU DoC must be signed by a person authorised to bind the manufacturer legally. For EU-based manufacturers, this is typically the CEO, Managing Director, or a person with delegated authority (such as a Quality Manager or Compliance Officer with a written delegation of authority). For non-EU manufacturers, the EU DoC may be signed by the EU Authorised Representative — but only if the Authorised Representative has been explicitly granted this authority in the mandate agreement with the manufacturer.
The signatory takes personal legal responsibility for the accuracy of the EU DoC. Signing a false EU DoC — for example, declaring compliance with a standard that was not actually applied — is a criminal offence in most EU member states and can result in personal liability for the signatory, not just corporate liability for the manufacturer.
Language Requirements for the EU DoC
The EU DoC must be available in the official language(s) of the EU member state(s) where the product is placed on the market. If a product is sold in Germany, France, and Spain, the EU DoC must be available in German, French, and Spanish. An English version is not sufficient on its own for products sold in non-English-speaking EU member states, although English is widely accepted for B2B products where the buyer is a business rather than a consumer.
EU DoC and the Digital Product Passport
Under ESPR, the EU Declaration of Conformity must be linked to the product's Digital Product Passport. ESPR Annex III specifies that the DPP must contain a link to the EU DoC. This means the EU DoC must be hosted at a stable URL that is accessible throughout the product's lifetime — not just at the time of first sale. A PDF of the EU DoC stored on a manufacturer's website is acceptable, provided the URL remains stable and the document remains accessible for at least 10 years after the last product of that model is placed on the market.
The EU Declaration of Conformity: What It Is and Why It Matters
The EU Declaration of Conformity (EU DoC) is the legal document by which a manufacturer declares that a product meets all applicable EU regulatory requirements. It is the manufacturer's formal statement of compliance — signed by a responsible person within the manufacturer's organisation (or by the EU Authorised Representative for non-EU manufacturers). The EU DoC must be drawn up before the CE marking is affixed to the product, and it must be kept available for market surveillance authorities for at least 10 years after the last product of that model is placed on the market.
The EU DoC is not a certificate issued by a third party — it is a self-declaration by the manufacturer. For products requiring Annex VII assessment, the EU DoC references the notified body's certificate of conformity, but the DoC itself is still drawn up and signed by the manufacturer. The notified body issues a certificate; the manufacturer issues the EU DoC.
Required Contents of the EU Declaration of Conformity
| Required Element | Description | Legal Basis |
|---|---|---|
| Product identification | Product name, model number, GTIN, batch/serial number range | ESPR Article 29(3)(a) |
| Manufacturer details | Name, address, country | ESPR Article 29(3)(b) |
| EU Authorised Representative | Name and address (non-EU manufacturers only) | ESPR Article 29(3)(c) |
| Applicable legislation | List of EU regulations the product complies with | ESPR Article 29(3)(d) |
| Harmonised standards applied | List of harmonised standards applied with publication references | ESPR Article 29(3)(e) |
| Notified body details | Name, ID number, certificate number (Annex VII only) | ESPR Article 29(3)(f) |
| DPP reference | Product passport identifier or DPP URL | ESPR Article 29(3)(g) |
| Signatory details | Name, title, date, place, signature | ESPR Article 29(3)(h) |
Simplified EU Declaration of Conformity
ESPR Article 29(4) allows manufacturers to draw up a simplified EU DoC that contains only the product identification and a reference to the full EU DoC (which must be available at a URL). The simplified EU DoC can be included in the product documentation or printed on the product packaging. The full EU DoC must be available at the URL referenced in the simplified DoC. This option is useful for products where including the full EU DoC in the product documentation would be impractical due to the length of the document.
Language Requirements
The EU DoC must be drawn up in the official language(s) of the EU member state where the product is placed on the market. For products sold in multiple EU member states, the EU DoC must be available in all relevant official languages. English is widely accepted for B2B products in most EU member states, but for consumer products sold in Germany, France, Italy, Spain, or other large member states, the EU DoC should be available in the local language.
EU Declaration of Conformity vs Declaration of Performance
The EU Declaration of Conformity (EU DoC) and the Declaration of Performance (DoP) are two different documents that serve similar but distinct purposes. The EU DoC is required under ESPR and most EU product safety directives (including the Low Voltage Directive, Machinery Directive, and Radio Equipment Directive). It declares that the product meets the requirements of the applicable EU legislation. The Declaration of Performance (DoP) is required under the Construction Products Regulation (CPR) and declares the performance of a construction product against its essential characteristics, referenced to the relevant harmonised standard. For construction products that are subject to both CPR and ESPR, manufacturers must prepare both a DoP (for CPR compliance) and an EU DoC (for ESPR compliance). The two documents can reference each other but cannot be combined into a single document.
CE Marking and the EU Declaration of Conformity
The CE marking and the EU Declaration of Conformity are inseparable — a product cannot bear the CE marking without a corresponding EU DoC, and an EU DoC is meaningless without the CE marking on the product. Article 18 of ESPR specifies that the CE marking must be affixed before the product is placed on the EU market. The CE marking must be at least 5 mm in height, be visible, legible, and indelible, and be affixed to the product, its nameplate, or its packaging. Where the CE marking cannot be affixed to the product due to its nature or size, it must be affixed to the packaging and to the accompanying documents. The CE marking must be followed by the identification number of the notified body where a notified body has been involved in the conformity assessment procedure.
Technical Documentation and the EU Declaration of Conformity
The EU Declaration of Conformity references the technical documentation that supports the conformity assessment. The technical documentation must be prepared before the CE marking is affixed and must be kept available for market surveillance authorities for at least 10 years after the last product is placed on the market. The technical documentation must contain: a general description of the product, a conceptual design and manufacturing drawings, a list of harmonised standards and/or common specifications applied, a description of the solutions adopted to meet the ESPR requirements where harmonised standards have not been applied, the results of design calculations and examinations, test reports, and a copy of the EU Declaration of Conformity. For products subject to a notified body procedure, the technical documentation must also include the notified body's assessment report and certificate.
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Register Your Digital Product Passport →EU Declaration of Conformity Under ESPR
The EU Declaration of Conformity (DoC) is the legal document in which the manufacturer (or their authorised representative) declares that the product meets all applicable EU legal requirements. Under ESPR, the DoC must confirm that the product meets the requirements of the applicable delegated act(s). The DoC is a key compliance document — it is the manufacturer's formal legal commitment that the product is compliant, and it is the document that market surveillance authorities will request when investigating potential non-compliance.
The ESPR DoC must contain the following information: the product identification (name, model number, batch or serial number); the name and address of the manufacturer (or authorised representative); a statement that the DoC is issued under the sole responsibility of the manufacturer; the object of the declaration (the product to which the DoC applies); a reference to the applicable delegated act(s) and any harmonised standards applied; the name and identification number of the notified body (if Annex VII conformity assessment was used); the date and place of issue; and the signature of the person authorised to sign on behalf of the manufacturer.
The DoC must be drawn up in the official language(s) of the EU member state(s) where the product is placed on the market, or in a language accepted by those member states. In practice, most manufacturers draw up the DoC in English and provide translations as required. The DoC must be kept available for inspection by market surveillance authorities for a minimum of 10 years after the last unit is placed on the market. The DoC does not need to be physically attached to the product, but it must be accessible on request.
Frequently Asked Questions
The ESPR implementing regulations are expected to require a reference to the EU Declaration of Conformity in the DPP, and may require the DoC itself to be accessible via the DPP. This would allow market surveillance authorities and customs officials to access the DoC directly from the DPP QR code, without needing to contact the manufacturer separately.
Yes. A single DoC can cover a range of products (such as a product family or a range of models) if all the products in the range meet the same requirements and the DoC clearly identifies all the products it covers. However, if the products in the range have different compliance profiles (for example, if some models meet higher efficiency requirements than others), separate DoCs may be needed.
The DoC must be signed by the manufacturer or their authorised representative. The person signing the DoC must be authorised to make legal commitments on behalf of the manufacturer. In practice, this is typically the CEO, the compliance officer, or a person with a specific delegation of authority from the CEO. The DoC must include the name and position of the signatory.
Providing false information in the EU Declaration of Conformity is a serious offence under EU law. Market surveillance authorities can impose financial penalties, require product withdrawal, and refer the case to national enforcement authorities for prosecution. In some member states, providing false information in a DoC can result in criminal prosecution of the responsible individuals.
Yes. If the product design changes in a way that affects the product's compliance with the applicable requirements, the DoC must be updated to reflect the change. The updated DoC must be dated and signed, and the previous version must be retained for the required retention period. Manufacturers should have a change management process that triggers a DoC review whenever a product design change is made.