We have never written a declaration of conformity

The EU declaration of conformity is a short document with a heavy meaning. Under the Low Voltage Directive 2014/35/EU it states that the fulfilment of the safety objectives in Annex I has been demonstrated (Article 15(1)). It follows the model structure in Annex IV, contains the elements of Module A in Annex III, is continuously updated and is translated into the languages the Member State of sale requires (Article 15(2)). By drawing it up, the manufacturer assumes responsibility for the compliance of the equipment (Article 15(4)). The manufacturer writes it only after the conformity assessment has demonstrated compliance, affixes the CE marking at the same stage, and keeps the declaration with the technical documentation for 10 years (Article 6(2) and (3)).^[1]

The model is almost the same across the acts. Annex IV of the Low Voltage Directive asks for the product model, type, batch or serial number; the name and address of the manufacturer or its authorised representative; the statement that the declaration is issued under the sole responsibility of the manufacturer; the object of the declaration, which may include a colour image; the statement of conformity with the relevant Union harmonisation legislation; the references of the harmonised standards or other technical specifications; additional information; and the signature block with place, date, name and function. The EMC Directive 2014/30/EU adds the date of each standard and, where applicable, the notified body's intervention (Annex IV).^[1][3]

Radio equipment has two extra points. Annex VI of Directive 2014/53/EU asks for standards with their identification number and version and, where applicable, date of issue, and, where applicable, a description of the accessories and components, including software, covered by the declaration. Each item must be accompanied by a copy of the declaration or by the simplified declaration of Annex VII, which gives the exact internet address of the full text (Articles 10(9) and 18(2)).^[2]

Toys use the older name, the EC declaration of conformity. It states that Article 10 and Annex II are met, follows the model in Annex III to Directive 2009/48/EC, contains the elements of the relevant modules in Decision No 768/2008/EC and is continuously updated (Article 15). Those modules come from the common framework: Article R10 of Decision No 768/2008/EC sets the same pattern of model structure, updating and translation, and Annex III of the decision holds the original model. The Toy Safety Regulation (EU) 2025/2509, which applies from 1 August 2030, replaces the toy declaration with a digital product passport that the manufacturer creates before placing the toy on the market; by creating it, the manufacturer assumes responsibility for the toy's compliance (Article 19(1) and (4)).^[5][6][7]

A declaration that is missing, incomplete or out of date is a non-compliance that the authority can order corrected. Where the operator does not act, the authority ensures that the product is withdrawn, recalled or prohibited (Regulation (EU) 2019/1020 Article 16(3) and (5)).^[4]