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EU declaration of conformity — template, mandatory fields and how to keep it current

The model structure from Decision No 768/2008/EC, all eight mandatory elements field by field, the single-declaration rule for multiple acts, language requirements, ten-year retention and the mistakes auditors find most often.

Author: myDPP Team

EU declaration of conformity — template, mandatory fields and how to keep it current

The EU declaration of conformity is one of the shortest documents in product compliance and one of the most frequently got wrong. It is usually a single page with eight numbered points. Market surveillance nonetheless keeps finding the same defects in it: a standard cited without its year of issue, a directive that was repealed three years earlier, a notified body number entered where no notified body was ever involved, a signature from someone who left the company long ago.

The cause is not carelessness. The declaration looks like a document, so it gets treated like one: a file you write once, sign and file away. In reality it is a set of product data fields, each with its own source system and its own change cycle. Newer EU product law now says this outright — under the Toy Safety Regulation the digital product passport takes the declaration’s place, and under the Machinery Regulation the declaration may be a machine-readable code. This article is about the fields themselves: where the model comes from, what belongs in each point, and what keeps the content true after the first signature.

Key takeaways

  • The model structure comes from Decision No 768/2008/EC, Annex III. Individual harmonisation acts repeat it in their own annexes, sometimes adding a sector-specific field — which is why the template looks nearly identical from toys to machinery.
  • There are eight mandatory elements plus the signature block. None is optional, but point 7 (notified body) is filled in only where a third party was actually involved in the assessment.
  • The declaration is issued under the sole responsibility of the manufacturer. That sentence is part of the model, not a courtesy formula.
  • Where several Union acts apply to a product, you draw up one declaration covering all of them, with the publication references of each. Not a set of separate declarations per directive.
  • References to harmonised standards must identify a specific dated edition. “EN 60335-1” with no year identifies nothing that can be checked.
  • The declaration must be translated into the language or languages required by the Member State in which the product is placed or made available on the market.
  • It must be kept at the disposal of market surveillance authorities for the period the applicable act requires — as a rule ten years from the date the product was placed on the market.
  • The declaration must be continuously updated. A new standard, a new company address or a change to the product means a new declaration, not an annotation on the old one.
  • myDPP is not a notified body, does not perform conformity assessment and neither issues nor signs declarations of conformity. It stores, versions and serves the product data from which a declaration’s content can be reconstructed.

Where the model comes from

Until 2008 every directive described the declaration in its own way, and a manufacturer selling across several regimes kept several incompatible templates. Decision No 768/2008/EC on a common framework for the marketing of products closed that gap: it set out common conformity assessment modules and a common model declaration in Annex III. Subsequent product legislation was aligned to that framework, so today the declaration annex in the Low Voltage Directive, the EMC Directive, the Toy Safety Regulation and the Machinery Regulation looks nearly the same.

Two consequences are worth carrying through the rest of this article.

First, the model is a minimum, not a maximum. The applicable act may add a field — the Construction Products Regulation requires declared performance, the Batteries Regulation requires its own identifiers. Always read the annex of the specific act, not Decision 768/2008/EC alone.

Second, the declaration is static by design: it describes the product as at the date of issue. Yet the law requires it to be kept current, so a static document has to be replaced every time anything it refers to changes. The tension between those two sentences is the source of most of the practical problems described below.

The eight elements, field by field

NoElementWhere the content comes from
1Declaration numberthe manufacturer’s own numbering system
2Name and address of manufacturer or authorised representativecompany registration data
3Statement of sole responsibilityfixed wording from the model
4Object of the declarationproduct data: model, type, batch, serial number
5List of applicable Union legislationthe product’s regulatory analysis
6Harmonised standards or other technical specifications usedtechnical documentation, test reports
7Notified body and certificate (where applicable)the body’s certificate
8Additional informationsector-specific requirements of the applicable act
—Place, date, name, function, signaturea person authorised by the manufacturer

Four of them cause trouble routinely.

Point 1: a number that has to be unique

The model provides for a declaration number and does not prescribe its format. That freedom is deceptive. The number is the only handle by which two declarations for the same product, issued in different years, can be told apart — and that is precisely what an authority will ask about when it wants to know the compliance status of a unit shipped in a particular quarter. Numbering like “DoC-2026-01” that gets overwritten on every correction destroys that information.

A workable rule: the declaration number identifies the version of the declaration, not the product. The product is identified by point 4.

Point 4: object of the declaration, meaning traceability

Here the model is demanding in a way that is easy to miss: the product identification must allow traceability, that is, it must link the declaration to a specific unit or production batch. A trade name alone does not do that if four variants with different equipment are sold under it. The model expressly permits including a colour image of sufficient clarity where that is needed to identify the product.

This is the closest link between the declaration and the passport. A persistent, unique product identifier is a precondition in any passport regime, and it is already a requirement in the declaration — just less often read that way.

Point 5: Union legislation and the single-declaration rule

Point 5 lists the acts against which conformity is declared, together with their publication references. The key rule sits outside the model itself: where more than one Union act applies to a product, you draw up a single declaration covering all of them, containing the information needed to identify each.

A typical mains-powered product with a radio module falls under the EMC Directive, the Radio Equipment Directive, the RoHS Directive and — once a delegated act arrives — under the ESPR. That is one declaration with four entries in point 5, not four documents. The most common error here is a list inherited from a template and never reviewed: a directive that has since been repealed, or an act that never applied to the product, added just in case. Declaring conformity with an act that does not apply is not caution; it is an untrue statement.

Point 6: standards with a year of issue

This field attracts the most formal errors. The reference must identify the specific, dated edition of the standard applied: not “EN ISO 12100” but “EN ISO 12100:2010”. Without the year, the reference does not show which version of the requirements the manufacturer actually used, and versions differ materially.

This field also carries the most common reason a declaration quietly stops holding up. Harmonised standards get superseded, and their references are published in the Official Journal — usually with a transition period after which the old edition no longer confers presumption of conformity. A declaration citing a withdrawn edition after that period looks correct and no longer supports what it claims. Nobody notifies the manufacturer; this has to be monitored.

Where conformity was declared without fully applying harmonised standards, point 6 cites the other technical specifications used — and the weight on the technical documentation usually grows, because the presumption of conformity does not operate.

A template to fill in

The skeleton below reflects Annex III of Decision No 768/2008/EC. Always compare it against the annex of the act applicable to your product, which may add a field.

EU DECLARATION OF CONFORMITY
No [declaration number]

1. Product model / product:
   [model, type, batch or serial number designation]

2. Name and address of the manufacturer or his authorised
   representative:
   [full legal name, postal address, country]

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

4. Object of the declaration:
   [identification of the product allowing traceability;
    a colour image of sufficient clarity where necessary]

5. The object of the declaration described above is in conformity
   with the relevant Union harmonisation legislation:
   [title, number and publication reference of each act]

6. References to the relevant harmonised standards used, or
   references to the other technical specifications in relation
   to which conformity is declared:
   [standard designation with year of issue, e.g. EN 60335-1:2012]

7. Where applicable: the notified body
   [name, four-digit identification number] performed
   [description of intervention] and issued the certificate
   [number, date].

8. Additional information:
   [fields required by the applicable sectoral act]

Signed for and on behalf of:
[place and date of issue]
[name, function]        [signature]

Three obligations that outlive the document

Drawing up the declaration is the smallest part of the job. Three obligations run on afterwards, and they decide whether the document still means anything five years later.

Languages. The declaration must be translated into the language or languages required by the Member State in which the product is placed or made available on the market. For a manufacturer selling across the Union that is not a one-off translation order but a standing commitment attached to fields that change: every correction to point 5 or 6 has to reach every language version.

Retention. The declaration is kept at the disposal of market surveillance authorities for the period the applicable act specifies — unless stated otherwise, ten years from the date the product was placed on the market. Under Regulation (EU) 2019/1020, many product categories require an economic operator established in the Union who has verified that the declaration and technical documentation have been drawn up, keeps the declaration at the authorities’ disposal for the required period, and can make the documentation available on request. For importers and sellers from third-country markets, that obligation rather than the declaration itself is the bottleneck.

Currency. The model requires the declaration to be continuously updated. The company name or address changed, an applied standard was superseded, a variant was added, a notified body certificate expired — each of those produces a new declaration, while the previous one stays in the archive as the state that applies to units placed on the market earlier. A handwritten note on an old declaration is not an update.

When the declaration stops being a sheet of paper

The same document has been moving towards digital form in EU law for some time. The Radio Equipment Directive introduced a simplified declaration back in 2014: a short statement that the equipment type conforms to the directive, plus an internet address where the full text of the declaration is available. The simplified version must also be translated into the required languages, and the full text must be available at that address in the same languages. It is the oldest example in this regime of a declaration that lives at a URL rather than in a box.

Newer acts go further, each by a different route:

  • The Machinery Regulation (EU) 2023/1230, applicable from 20 January 2027, allows the declaration to be provided digitally — through an internet address or a machine-readable code — with an obligation to keep it accessible for the expected lifetime of the machinery and in any case at least ten years.
  • The Cyber Resilience Act (EU) 2024/2847 has its own declaration model in Annex V and permits the simplified form in Annex VI, following the radio equipment approach. More in our article on the Cyber Resilience Act.
  • The Construction Products Regulation (EU) 2024/3110 merges the declaration of performance with the declaration of conformity and allows the merged document to be issued through the digital product passport.
  • The Toy Safety Regulation (EU) 2025/2509 goes furthest: the passport does not accompany the declaration but replaces it, from 1 August 2030.

Under the ESPR the declaration is untouched: a product covered by a delegated act goes through one of the conformity assessment procedures the regulation provides, the manufacturer draws up the declaration and affixes the CE marking, and the passport is a separate obligation alongside. Our article on when the passport replaces the declaration of conformity compares those routes in full.

It is also worth noting what digital form does not change. Whether the declaration must accompany the product depends on the applicable act — for machinery it does; for many other categories it is enough that it is at the authorities’ disposal. Publishing online does not by itself discharge an obligation to supply the document where such an obligation exists.

Seven places declarations go wrong

Standards cited without a year of issue

The most common formal defect and the easiest to fix. Without the year, the reference does not identify the requirements that were actually applied.

An inherited list of legislation

A template copied from a similar but not identical product. Sometimes it lists an act irrelevant to the product; sometimes it omits one that has just come into force. The list in point 5 should follow from a regulatory analysis of the specific product, reviewed at every design change.

A notified body entered where none was involved

Point 7 is filled in only where the applicable act required third-party involvement and the body actually performed that task. Entering a test laboratory that ran tests under contract as a notified body is a substantive error — a laboratory need not be a notified body at all, and a notified body’s identification number is four digits and comes from the list the Commission maintains.

Not updated after a standard changes

Once the transition period ends, a superseded edition of a standard no longer confers presumption of conformity. A declaration citing it looks correct and no longer supports what it claims. Nobody sends a notice; monitoring is the manufacturer’s obligation.

A signature without authority

The signatory must be authorised to commit the manufacturer and must state their function. Declarations signed by someone who has since left remain valid for the units placed on the market at the time — but new declarations issued under a stale signature are a problem that surfaces only during an inspection.

When market surveillance asks about a specific batch, what is needed is the declaration that applied to that batch, not the current one. If the file was overwritten, that information is gone. Versioning with retained history is the only protection, and it costs little if set up from the start.

Drift between the declaration and other channels

The declaration says one thing, the shop’s product sheet another, the label a third. With a single document in a folder, the drift can stay invisible for years. When the same data is served behind a QR code it becomes visible immediately — to a customer, a competitor and an authority. We develop that argument in DPP and PIM.

From document to data fields — five steps

  1. Decompose your last signed declaration into fields. For each of the eight points, name the source system and the responsible person. The fields nobody can trace to a source are exactly the ones that stall the work later.
  2. Sort out numbering and identifiers. The declaration number identifies its version; point 4 identifies the product. If your product identifiers are internal to the ERP today and change between systems, that is the first thing to fix — and a precondition for any passport regime.
  3. Set up standards and legislation monitoring. Decide who tracks changes to harmonised standards references and the entry into force of new acts, and which event triggers a new declaration. Without this step the other four keep tidy data that has quietly gone out of date.
  4. Version, do not overwrite. Every declaration with a change history: who changed which field, when, and on what basis. Fixing the state as at the date of placing on the market is far cheaper now than reconstructing it in five years.
  5. Treat languages as part of the data model. Establish which fields are language-dependent and how a change in the source text reaches every language version. Points 1, 4 and 7 usually are not; points 3, 5 and 8 are.

Our DPP implementation checklist covers the wider programme this sits inside.

Frequently asked questions

Is there an official EU declaration of conformity template to fill in?

The model structure is in Annex III of Decision No 768/2008/EC, and every harmonisation act repeats it in its own annex, sometimes with an extra field. The Commission does not publish a single universal form — the binding template is the annex of the act applicable to your product, and that is where the final list of fields should be checked.

Do I need a separate declaration for each directive?

No, the opposite. Where several Union acts apply to a product, you draw up one declaration covering all of them, with their publication references in point 5. Separate declarations per act are acceptable only in the exceptional cases where a specific provision requires it.

How long must a declaration of conformity be kept?

Unless the applicable act says otherwise, ten years from the date the product was placed on the market, at the disposal of market surveillance authorities, together with the technical documentation. Some sectoral regimes set different periods, so check the act that applies to the product.

Can the declaration be made available only through a QR code?

It depends on the act. The Radio Equipment Directive has long allowed a simplified declaration with an internet address for the full text, the Machinery Regulation allows digital form from 20 January 2027, and the Cyber Resilience Act provides its own simplified form. Where an act requires the declaration to accompany the product, publishing online does not by itself satisfy that.

Who should sign the declaration?

A person authorised to commit the manufacturer or its authorised representative, stating name and function. Responsibility for the content stays with the manufacturer regardless of who physically signed and who prepared the data.

Can a software vendor issue the declaration for me?

No. The declaration is issued under the sole responsibility of the manufacturer, and the manufacturer signs it. A vendor can store, version and serve the data the declaration’s content is built from — myDPP does exactly that and nothing beyond it. Conformity assessment, issuing and signing stay with the manufacturer and, where the law requires it, with a notified body.

Sources

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