Overview and Purpose.

The EU Declaration of Conformity is an official document that manufacturers must create. This document states that their products meet all accessibility requirements in the European Accessibility Act. When making this declaration, the manufacturer takes full responsibility for the product's compliance.

This document is an important part of the conformity assessment process. It serves as the manufacturer's official statement that their product follows the legal requirements. The document helps authorities, distributors, and end-users check that the product has gone through the needed assessment steps.

Structure and Content.

According to Article 16 of the EAA, the EU Declaration of Conformity must include:

  • The structure format set out in Annex III to Decision No 768/2008/EC.
  • All the elements listed in Annex IV of the EAA.
  • Updates when any changes are made to the product.
  • Translations into the languages required by the country where the product is sold.

The declaration must clearly identify the product it covers. This typically includes:

  • Product name, type, batch or serial number.
  • Name and address of the manufacturer and their representative, if they have one.
  • References to the relevant standards or technical specifications used.
  • Date when the declaration was issued.
  • Signature of the responsible person.

Exceptions and Special Rules.

When manufacturers use the exception for fundamental alteration or disproportionate burden under Article 14, they must clearly state which accessibility requirements have exceptions.

The EAA states that technical documentation requirements should not create too much work for very small businesses and SMEs. However, the documentation must still show compliance clearly.

Single EU Declaration.

When a product must follow more than one EU law requiring a Declaration of Conformity, manufacturers can create just one declaration that covers all applicable laws. This approach:

  • Reduces paperwork for businesses.
  • Makes information easier to find for market surveillance purposes.
  • Must list all the relevant laws, including their publication references.

This option lets manufacturers include all relevant individual declarations in one document. This is especially helpful for products that must comply with multiple directives or regulations.

Keeping and Sharing Documents.

Manufacturers and importers have specific responsibilities regarding the EU Declaration of Conformity:

  • Manufacturers must keep the declaration for five years after the product is placed on the market.
  • Importers must keep a copy of the declaration for five years for market surveillance authorities.
  • A copy of the declaration must be provided to relevant authorities when they ask for it.
  • Distributors must check that the product comes with all required documentation, including the declaration when needed.

Connection to CE Marking.

The EU Declaration of Conformity is closely linked to the CE marking:

  • The CE marking is the visible sign that a product complies with EU laws.
  • The EU Declaration of Conformity is the document that proves this compliance.
  • A manufacturer must create the EU Declaration of Conformity before adding the CE marking to a product.
  • Together, they complete the conformity assessment process that allows products to move freely in the European market.

By adding the CE marking, the manufacturer states that the product meets all applicable accessibility requirements. They take full responsibility for this conformity.

Source References.

This page references these sections of Directive (EU) 2019/882:

  • Article 7, Paragraph 2. Manufacturer obligation to create DoC.
  • Article 7, Paragraph 3. Manufacturer retention period.
  • Article 9, Paragraph 7. Importer retention period.
  • Article 16. EU declaration of conformity - content, structure, exceptions, single DoC.
  • Article 18, Paragraph 1. Relation to CE marking.
  • Annex IV. Elements of technical documentation related to DoC.
  • Recital 78. Context for single DoC.