EU Declaration of Conformity (DoC): Which Products Need One, What It Must Contain, Template

What a DoC is: the manufacturer's declaration under CE law

The EU declaration of conformity comes from the EU's New Legislative Framework. Reference Article R10 in Annex I of Decision 768/2008/EC says the DoC states that fulfilment of the requirements has been demonstrated, follows the model structure in Annex III of that Decision, and is kept up to date; and that by drawing it up the manufacturer assumes responsibility for compliance. Each sector law copies these rules into its own text, for example Article 15 of the Low Voltage Directive 2014/35/EU, Article 15 of the EMC Directive 2014/30/EU and Article 18 of the Radio Equipment Directive 2014/53/EU.

The order matters: the manufacturer prepares the technical documentation and completes the conformity assessment procedure set by the law, and only then draws up the DoC and affixes the CE marking. Section 4.4 of the Commission's Blue Guide (2022) explains that the manufacturer or its authorised representative in the EU draws up and signs the DoC, which states that the product meets all relevant requirements.

The GPSR itself has no DoC. Products covered only by the GPSR, such as clothing, furniture or ordinary homeware, show safety through a risk analysis and technical documentation (see GPSR technical documentation). The CE marking may be affixed only where a law provides for it (Article 30(2) of Regulation (EC) No 765/2008), so a “CE DoC” and CE mark on a GPSR-only product are wrong.

Which products need a DoC

Construction products use a “declaration of performance” instead. “On request” means the law does not require the DoC in the box, but you must supply it to authorities when asked, and marketplaces may ask for it too. From 1 August 2030, the digital product passport under Article 19 of the Toy Safety Regulation (EU) 2025/2509 replaces the toy DoC (see toys and GPSR). Electronics usually fall under several laws at once (see electronics and GPSR).

Mandatory content: the eight Annex III items

The model in Annex III of Decision 768/2008/EC (sector annexes are nearly identical, some with extras), with notes from Blue Guide section 4.4:

The Blue Guide adds: with several laws, the single DoC may be a dossier of the individual declarations; the DoC may be a document, a label or equivalent, but all products it covers must be traceable to it; and once any element changes (legislation, standard edition, manufacturer or representative address), products placed on the market afterwards need an updated version.

Example template: Bluetooth speaker (fictional)

Brand, model, company and address are fictional, and the standards are deliberately left blank: fill them from your test reports and the applicable harmonised standards. Radio equipment follows the structure of RED Annex VI:

If the product contains a battery, check the Batteries Regulation (EU) 2023/1542 separately for its own DoC and labelling rules.

Who signs, which language, how long to keep it

• Signatory: the manufacturer or its authorised representative (Blue Guide 4.4). If you sell under your own brand, you are the manufacturer and the DoC should name your company, not the factory. The factory may help draft it, but a DoC in the factory's name will not match your label.
• Language: every sector law requires translation into the language(s) required by the member state of sale, e.g. LVD Article 15(2), RED Article 18(2), Toy Safety Directive Article 15(2). Laws do not always say who translates; the Blue Guide says that if another operator translates and the manufacturer does not sign the translation, a copy of the signed original must be provided with it.
• Retention: the manufacturer keeps the DoC and technical file for 10 years (e.g. LVD Article 6(3); at least 10 years under the Machinery Regulation); the importer keeps a copy for 10 years (e.g. LVD Article 8(8)).
• EU Responsible Person: Article 4(3)(a) of Regulation (EU) 2019/1020 requires the EU-based operator to verify that the DoC has been drawn up and keep it available for the required period, so your representative will ask for a copy (see who is the EU Responsible Person).
• Stamp: the models ask for name, function and signature; no company stamp is required.

The Commission's May 2025 simplification proposals COM(2025) 503 and 504 include an electronic DoC. They are still proposals; see GPSR timeline and updates.

DoC vs test report, certificate and technical file

When a marketplace or customer asks for a “CE certificate”, they usually mean the DoC plus test reports. For reading reports, see GPSR testing, standards and presumption of conformity.