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Comprehensive analysis of the Declaration of Conformity (DoC)

When the Amazon platform requires supplementary information for category review, the seller may often be requested to submit a document called the Declaration of Conformity, which is a very important product compliance document. If not, the product may not pass the review. So today, we will analyze the Declaration of conformity thoroughly.

What is the Declaration of conformity (DoC)?

Declaration of Conformity (DoC) is the declaration from the manufacturer or its authorized representative in the European Union, who declares that the product put on the EU market meets all the basic health and safety requirements of the relevant directives applicable to this machine. DoC is one of the necessary steps of CE certification.

After the Declaration of Conformity is signed, the manufacturer of the product has the right to affix the CE mark to the machine.

The Declaration of Conformity is a formal declaration made by the manufacturer or the authorized representative of the European Union. This declaration proves that the manufacturer’s product meets all the requirements of a safe product. According to the harmonized standards under the directive, it applies to all the requirements of this product.

Therefore, the Declaration of Conformity is usually a legal document that is used by supervisory agencies and customs to confirm that products comply with responding regulations. If the Declaration of Conformity does not meet the requirements, it often leads to the ruthless detention of the product by the customs and the questioning of the end-user or the supervisory authority.

Common problems with incompliant Declaration of Conformity

Most directives specify the content of the Declaration of Conformity.  For example, the Machinery Directive 2006/42/EC detailed the content that the DoC needs to include in Appendix II. There are still deficiencies in the interpretation of various clauses and related implementation in actual projects, and common problems in terms of missing content in the Declaration of Conformity often include:

The name and address of the manufacturer and its authorized representative do not correspond to the CE nameplate/label;

The description of the product does not include the generic name, function, model, category, serial number, and its commercial name;

The relevant directives and their coordination standards that this product complies with are not listed;

The signature of the customer or authorized representative is inconsistent with the inscription;

Therefore, it is recommended to implement a complete CE process and issue a compliant Declaration of Conformity through a professional compliance consultancy.

What exactly does the Declaration of Conformity contain

The declaration can take the form of a document, label or equivalent, and must contain enough information to be traceable to all products it covers.

For example, a reference statement of Decision No. 768/2008/EC contains:

  • Product identification number. The number need not be unique for each product. It can refer to product, batch, type, or serial number. This is determined by the manufacturer.
  • The name and address of the manufacturer or authorized representative that issued the statement.
  • Statement is issued by the manufacturer solely.
  • The identification of the product can be traced back. This is basically an addition to point 1, which describes the product and allows its traceability. Where relevant to product identification, images may be included, but unless specified as a requirement in the EU harmonized regulations, it is at the manufacturer’s discretion to apply this.
  • Comply with all relevant EU regulations. Quote reference standards or other technical specifications (such as national technical standards and specifications) in a precise, complete and clearly defined manner. This means specifying the version and/or date of the relevant standard is necessary.
  • The name and identification number of the notified body (if applicable) when it participates in the conformity assessment procedure.
  • All supplementary information (i.e., grade, category) that may be required (if applicable).
  • The date of publication of the declaration; the signature and title or equivalent mark of the authorized person. This can be any date after the completion of the conformity assessment.