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.

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.

• The GPSR requires the manufacturer to carry out an internal risk analysis and draw up 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 decides. The EU’s common model declaration gives you a practical starting structure:

1. the declaration or product identification number, where applicable;
2. the manufacturer's name and address and, where the model permits it, the authorised representative's details;
3. a statement that the declaration is issued under the manufacturer's sole responsibility;
4. an unambiguous description of the product, model, type, batch or serial reference, with an image where useful or required;
5. every applicable EU harmonisation act covered by the declaration;
6. the harmonised standards or other technical specifications used, with current references;
7. notified-body name, identification number, activity and certificate details where that procedure applies;
8. any additional information required by the relevant product act; and
9. 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 applies to the EU Responsible Person under the GPSR. That role gives your product an EU-based economic operator for certain product-safety tasks. It does not make the operator the manufacturer, and it does not 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. The GPSR does not create a general duty to issue an EU Declaration of Conformity. It requires manufacturers to carry out an internal risk analysis and draw up technical documentation. You need a DoC only where separate product-specific EU law requires one.

Who signs an EU Declaration of Conformity?

The manufacturer takes responsibility for the declaration. A natural person authorised to sign for the manufacturer signs it. An authorised representative may act only where the applicable product law allows it and the written mandate covers the task.

Must the GPSR Responsible Person sign the DoC?

No. Acting as the EU-based responsible operator under the GPSR does not automatically give authority to sign a DoC. Signature authority depends on the applicable product law and a suitable written mandate from the manufacturer. The role also does not transfer the manufacturer's responsibility.

What information belongs in a DoC?

The applicable product law sets the exact format. The common model covers product identification, manufacturer details, a sole-responsibility statement, the applicable EU laws, the standards or specifications used, notified-body details where relevant, and the place, date, name, function and signature of the signatory.

Is a DoC the same as a certificate?

No. A DoC is the manufacturer's own legal declaration, not a certificate issued by an independent body. Test reports and notified-body certificates can support it where the applicable conformity-assessment procedure requires them.

Official sources

This guide is general information, not legal advice for your specific product.