EU Required DoC Compliance Declaration

Recently, the TEMU platform has released new regulations requiring that goods subject to CE control not only upload CE certification documents but also provide (DoC or CoC) compliance declaration materials.

For non-compliant products, TEMU will issue risk warnings to buyers, remove the products, notify buyers or other related parties to destroy/return the products, etc.

Previously, Amazon also required relevant sellers to submit EU Declaration of Conformity (DoC) documents; otherwise, product listings would be restricted or removed.

In essence, CE certification and Declaration of Conformity (DoC) serve as the passports to the European market. But what exactly is the DoC, and how is it related to CE certification? How can one provide a DoC?

What is a DoC?

The EU Declaration of Conformity (DoC) is a part of the conformity assessment procedure required by EU harmonized legislation. It is a declaration drafted and signed by the manufacturer or their authorized representative within the EU.

The DoC is a self-declaration model within CE certification, asserting that the product complies with all relevant product safety requirements before entering the European market.

The DoC compliance declaration is a mandatory document. Additionally, the EU Declaration of Conformity must be translated into one or more languages required by the country/region where the product is sold.

What Products Require a DoC?

Generally, in the EU market, products that require the CE safety certification mark need a Declaration of Conformity. These products must be tested to ensure safety and complete technical documentation before obtaining CE certification and entering the EU market for production and sales.

Applicable to all harmonized legislation under framework directives, including but not limited to toys, electronic products, personal protective equipment, machinery, construction products, gas appliances, recreational and private watercraft, pressure equipment, and measuring instruments. For more information, refer to the EU website:https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards_en

DoC Compliance Process

For imported products, the importer must ensure that the product comes with a Declaration of Conformity (DoC) and keep a copy for 10 years after the product is placed on the market (unless other periods are specified by relevant CE directives).

Notably, one DoC can cover all sales models of a product.

Steps to obtain an EU Declaration of Conformity:

1. Identify the product type and applicable EU harmonized legislation.

2. Check if the product meets specific requirements.

3. Determine if the product needs testing by a notified body.

4. Test the product and perform the necessary conformity assessment as per regulations.

5. Fill in the conformity declaration template as per regulations and sign the declaration.

When drafting the Declaration of Conformity, ensure all required information is included, and if multiple harmonized legislations apply, all requirements must be met.

Contents of the DoC

A Declaration of Conformity must include the following information:

1. Manufacturer’s details: name, address, etc.

2. Product details: name, trademark, model, etc.

3. Relevant product safety directives and information from safety reports.

4. Compliance declaration.

5. Authorized representative’s details: name, address, etc.

6. Responsible person’s signature.

7. Date of declaration issuance.

For example, for toys, a sample declaration and marking might include:

1. Unique product identification (name/model#).

2. Manufacturer or authorized representative’s name and address, with traceable product identification (possibly including clear color images for identification).

3. Purpose of the declaration in compliance with relevant EU harmonized legislation (e.g., 2009/48/EU: Toy Safety Directive).

4. References to relevant harmonized standards (e.g., EN71-1: Mechanical xxx).

5. If applicable, the notified body (name, number) performed the standard and issued a certificate, with a signature from the general manager/quality manager.

Who Can Sign the EU DoC?

The EU Declaration of Conformity must be signed by the manufacturer or importer, not by a notified or testing body. For products imported from non-EU countries/regions, the importer must ensure the product meets all legal requirements and that the technical documentation (including the declaration) is accurate and available.

Besides the manufacturer, the authorized representative can also sign the declaration. The authorized representative is an individual or legal entity established in the European Economic Area.

Common mistakes include:

- Incorrect title (e.g., “certificate” instead of “declaration”).

- Using “CE Declaration” instead of “EC Declaration” or “EU Declaration”.

- Incomplete standards and directives.

- Missing signature.

- Signer not working at the company or in an appropriate position.

- Declaration date earlier than some specified standards or directives.

- Misleading or confusing declarations (e.g., including unrelated standards).

- Incorrectly or incompletely written standards.

Manufacturers or distributors inexperienced with CE certification should seek professional help.

Relationship Between CE Certification, DoC, and Authorized Representatives

CE certification: Before obtaining DoC certification, products must comply with all necessary EU directive standards, which means passing relevant tests and obtaining test certificates/reports (CE certification). However, the CE certificate does not replace the Declaration of Conformity (DoC) and valid laboratory test reports.

Authorized Representative: Collects product DoC, informs authorities of potential product risks, and collaborates with market surveillance authorities to ensure corrective actions by the manufacturer or brand owner. Additionally, if issues arise within the EU, the authorized representative must assist in resolving them.

Declaration contents should include: manufacturer information, authorized representative information, product name, trademark, model, EN standards or directives list, compliance declaration, signature, CE mark, etc.

Simple relationship hierarchy: CE certification -> Authorized Representative -> DoC

Although the EU Declaration of Conformity (DoC) is a compliance document, it is as important as CE certification. In the EU market, products with the CE safety certification mark typically require a Declaration of Conformity.