EU Declaration of Conformity: DoC Guide (2026)
An EU Declaration of Conformity (DoC) is the manufacturer's signed legal statement that a product complies with the EU legislation identified in the declaration. It is required only when the applicable product-specific EU law requires it. The General Product Safety Regulation (GPSR) alone does not create a universal DoC for consumer products.
Do I need a DoC for my product?
Start with the product's legal scope, not with a generic template.
| Product situation | Is an EU DoC required? | Main evidence |
|---|---|---|
| Product governed only by GPSR for the relevant safety risks | Not because of GPSR alone | Internal risk analysis and technical documentation under GPSR Article 9(2) |
| Product covered by EU harmonisation legislation that requires a DoC, such as many toys, electrical and lithium-battery products or personal protective equipment | Yes, under that product-specific legislation | The applicable conformity assessment, technical file and EU DoC |
| Product covered by several EU acts that each require a declaration | Usually one declaration can identify all applicable acts, subject to their rules | One current declaration plus the supporting records required by each act |
| Cosmetic product governed by Regulation (EC) No 1223/2009 | No CE-based EU DoC under the Cosmetics Regulation | The product information file, safety report, notification and other cosmetics-specific records |
The words “GPSR Declaration of Conformity” are often used commercially, but the document's title does not create a legal requirement. First identify every EU act that applies to the exact product and risk.
GPSR technical documentation vs EU Declaration of Conformity
These are different records.
- GPSR Article 9(2) requires an internal risk analysis and technical documentation for products within its scope.
- An EU DoC is required only by product-specific legislation that expressly calls for one.
- A DoC does not replace the GPSR risk analysis, traceability, labelling or corrective-action duties.
- GPSR technical documentation does not replace a DoC where another EU act requires the declaration.
For the evidence behind a GPSR file, see our GPSR technical documentation guide and risk-assessment method.
What should an EU Declaration of Conformity contain?
The applicable product legislation is decisive. The common model in Annex III to Decision No 768/2008/EC provides this practical starting structure:
- the declaration or product identification number, where applicable;
- the manufacturer's name and address and, where the model permits it, the authorised representative's details;
- a statement that the declaration is issued under the manufacturer's sole responsibility;
- an unambiguous description of the product, model, type, batch or serial reference, with an image where useful or required;
- every applicable EU harmonisation act covered by the declaration;
- the harmonised standards or other technical specifications used, with current references;
- notified-body name, identification number, activity and certificate details where that procedure applies;
- any additional information required by the relevant product act; and
- the place and date of issue, signatory's name and function, and signature.
This is not a universal copy-and-paste form. Toy, radio equipment, machinery, PPE and other regimes can prescribe their own wording, annex or additional fields. Do not list a standard, certificate or EU act that was not actually used for the product.
Who signs the DoC?
The manufacturer assumes responsibility for product conformity by drawing up the declaration. The document is signed by a natural person authorised to act for the manufacturer.
An authorised representative can perform declaration-related tasks only where the applicable product legislation permits it and the manufacturer's written mandate expressly covers those tasks. An importer, fulfilment provider or distributor does not gain signature authority merely from appearing in the supply chain.
The same distinction applies to the EU Responsible Person under GPSR Article 16: that role provides an EU-established economic operator for specified product-safety tasks, but it does not automatically make the operator the manufacturer or authorise it to sign a DoC.
Which language and delivery rules apply?
There is no single GPSR language rule for every DoC. The relevant product act determines:
- which Member State language or languages are required;
- whether the complete declaration must accompany the product;
- whether a simplified declaration may accompany it with a link to the full text; or
- whether it must instead be kept available for market-surveillance authorities.
Confirm the rule for each country in which the product is placed or made available. A translation must preserve the meaning of the signed declaration and match the technical records.
When should the declaration be updated?
Keep the DoC current whenever a change can affect the declared conformity, including:
- a material product, component, software or manufacturing change;
- a change to the manufacturer or product identification;
- a revised applicable EU act, harmonised standard or conformity-assessment result; or
- a change to the notified-body or certificate information recorded in the declaration.
There is no universal annual renewal rule. Review frequency and retention periods come from the applicable product legislation and the product's change controls.
Pre-signature DoC check
Before signing, verify that:
- the product and every relevant variant are identified unambiguously;
- the legal manufacturer named in the declaration matches the product and technical file;
- all applicable—and only applicable—EU acts are listed;
- standards, reports and certificates are current and actually support the declared product;
- the signatory has documented authority;
- the language and availability rules for each target market are met; and
- the declaration is consistent with the label, instructions and technical documentation.
Grüner Baum GmbH can review the product scope, GPSR records and the relationship between a DoC and the other applicable EU product rules. We do not turn a generic template into proof of compliance; the declaration must be supported by product-specific evidence. Request a product review.
Frequently asked questions
Does GPSR require an EU Declaration of Conformity?
No. GPSR Article 9(2) requires an internal risk analysis and technical documentation. A DoC is required only where separate product-specific EU legislation expressly requires one.
Who signs an EU Declaration of Conformity?
The manufacturer assumes responsibility for the declaration. An authorised natural person signs for the manufacturer; an authorised representative can act only where the applicable law and written mandate permit it.
Must the GPSR Responsible Person sign the DoC?
No. A GPSR Article 16 role does not automatically grant signature authority or transfer the manufacturer's responsibility.
What information belongs in a DoC?
The exact fields come from the applicable product act. The common model identifies the product, manufacturer, applicable legislation, standards, any notified-body involvement and the authorised signatory.
Is a DoC the same as a certificate?
No. A DoC is the manufacturer's legal declaration. Independent test reports or certificates can support it when the applicable conformity-assessment route requires them.
Official sources
- Regulation (EU) 2023/988, Article 9
- Decision No 768/2008/EC, Article 5, reference Article R10 and Annex III
- European Commission Blue Guide 2022, section 4.4
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