Who signs the EU Declaration of Conformity for non-EU makers

What the EU Declaration of Conformity is, and what it is not

The EU Declaration of Conformity (DoC) is the manufacturer's written statement that a product meets the EU acts that apply to it, for example the EMC Directive 2014/30/EU (Article 15(1)). The General Product Safety Regulation (EU) 2023/988 does not provide for a DoC; there, the technical documentation under Article 9(2) GPSR carries the evidence.

A declaration is not a certificate. Test reports are evidence in your technical documentation (Decision No 768/2008/EC, Annex II, Module A, point 2). Certificates come from notified bodies, for example the EU-type examination certificate or, in Modules F and G, a “certificate of conformity” (Annex II). Even then, the manufacturer issues its own declaration.

Who signs the EU Declaration of Conformity: the default rule

The manufacturer draws up the declaration once the conformity assessment has shown compliance (Article 7(2) of Directive 2014/30/EU; Article R2(2) of Decision No 768/2008/EC). The model ends with “Signed for and on behalf of”, place and date, name, function and signature (Annex IV).

Who signs is a question of authority, not of location. The Commission's Blue Guide names the managing director or another representative to whom this responsibility has been delegated (section 4.4, footnote 230). The signatory need not live in the EU: a manufacturer established outside the EU may sign the declaration itself, unless the relevant act provides otherwise (footnote 231).

When your Authorized Representative may sign instead

An Authorized Representative is established in the EU and acts under your written mandate (Article 8(1) of Directive 2014/30/EU). The acts in the table keep two duties out of any mandate: designing and manufacturing the product, and drawing up the technical documentation.

The declaration is not among them. The conformity assessment modules let the representative fulfil the DoC duties “on his behalf and under his responsibility, provided that they are specified in the mandate” (for example Annex II, point 6, Directive 2014/30/EU). The Blue Guide confirms this (section 3.2).

Without such a clause, your representative may not sign. With one, it signs “for and on behalf of” you, under your sole responsibility. Machinery details: Machinery Regulation checklist.

Declaration of Conformity template: what each field needs

Use the model annexed to your act; Annex III of Decision No 768/2008/EC is the common basis (Blue Guide, section 4.4). The model structure is binding (Article 15(2) of Directive 2014/30/EU).

Where several acts require a DoC, issue a single declaration naming all of them (Article 15(3) of Directives 2014/30/EU and 2014/35/EU). Keep it current (Article 15(2)): a new standard version or new contact details require a new version for products placed on the market afterwards (Blue Guide, section 4.4).

Languages, copies and 10 years of storage

• Language: as each member state requires (Article 15(2) of Directive 2014/30/EU); a translation not signed by the manufacturer needs a copy of the signed original (Blue Guide, section 4.4).
• With the product: usually only on request; radio equipment comes with a copy or a simplified declaration with the internet address of the full text (Article 10(9) of Directive 2014/53/EU).
• Storage: manufacturer and representative keep declaration and technical documentation for 10 years after placing on the market (Articles 7(3) and 8(2)(a) of Directive 2014/30/EU), the importer a copy (Article 9(7)). The period runs per unit (Blue Guide, sections 4.3 and 4.4): count from a model's last unit.

What your EU Authorized Representative does with the declaration

For most CE products, Article 4 of Regulation (EU) 2019/1020 requires an economic operator in the EU. If that is your representative, it verifies that the DoC and technical documentation have been drawn up, keeps the declaration available to authorities (Article 4(3)(a)), provides documents on reasoned request (Article 4(3)(b)) and provides a copy of its mandate on request (Article 5(2)).

None of this makes it the issuer; signing needs a mandate clause.

Edge cases: own brand, EU subsidiary, importer

• Own brand in the EU. An importer or distributor selling under its own name or trade mark counts as manufacturer and issues the declaration (Article 11 of Directive 2014/30/EU).
• EU subsidiary. Like a sales agent or distributor, it becomes your representative only by written mandate (Blue Guide, section 3.2).
• Importer. It does not sign. It ensures that you carried out the conformity assessment and keeps a copy for 10 years (Article 9(2) and (7)).

Step by step: issuing the declaration from outside the EU

1. 1.List every act requiring a DoC, with its Official Journal reference.
2. 2.Complete conformity assessment and technical documentation first; the declaration comes last (Article 7(2)).
3. 3.Fill in the model of your act, including dated standards.
4. 4.Decide who signs: an authorized person in your company, or your representative only with a mandate clause.
5. 5.Translate, file and share it with your EU operator, and update it after changes to standards, contact details or the product.

Practical example: an Asian toy maker selling online

An Asian maker of wooden stacking toys sells to EU consumers through its own online shop and has appointed an EU Authorized Representative. It applies harmonized standards covering all relevant safety requirements of the Toy Safety Directive 2009/48/EC, so internal production control applies (Article 19(2)).

• The declaration follows Annex III of the Directive, with a color image of each toy; field 7 does not apply.
• The managing director signs at the head office in Asia; manufacturer and representative both appear with name and address.
• After an office move, the maker issues a new version for toys placed on the market afterwards and keeps the old one on file.

Common mistakes with the Declaration of Conformity

• Signing without a mandate clause. A representative needs one.
• Sending a test report instead. Reports and lab certificates do not replace the declaration.
• One declaration per directive. Acts requiring a DoC share one.
• Undated standards, old addresses. Both need correcting or a new version.
• English only. Each member state decides on the language.

Conclusion: your declaration, your responsibility

The EU Declaration of Conformity is the manufacturer's document. Sign it through an authorized person, or let your EU Authorized Representative sign where the act and a clear mandate clause allow it; the responsibility stays with you.

As your EU Authorized Representative, Representa GmbH acts under a written mandate: we provide our name and address for packaging and the Declaration of Conformity, validate your technical files and keep your technical documentation for 10 years. Our CE marking service identifies the applicable directives and harmonized standards and helps you prepare a clear and accurate Declaration of Conformity.

Frequently asked questions