{
  "type": "problem",
  "slug": "marketplace-doc-upload",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/marketplace-doc-upload/",
  "markdown": "https://www.conphora.com/solutions/problem/marketplace-doc-upload.md",
  "title": "A marketplace wants our declaration and test report uploaded",
  "description": "A marketplace asks for a declaration of conformity and a test report per listing. What the law requires, what is its own rule, and what to upload.",
  "answer": "The marketplace acts do not require sellers to upload documents. Marketplaces ask because the General Product Safety Regulation and the Digital Services Act make them collect seller information and check offers. Upload the EU declaration of conformity only where a CE act such as the Low Voltage Directive or the toy rules requires one, check that it names the listed model, and add a supporting test report.",
  "theme": {
    "id": "marketplace-retailer",
    "label": "Marketplace and retailer demands"
  },
  "roles": [
    {
      "id": "online-seller",
      "label": "Online seller"
    },
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    }
  ],
  "regulations": [
    "GPSR",
    "LVD",
    "TSD"
  ],
  "path": [
    "product-validation",
    "documentation-generator"
  ],
  "trigger": "A marketplace adds a mandatory document field to your listings or asks for documents during a product review",
  "keep": null,
  "why": [
    {
      "text": "Marketplaces have their own duties, and document requests follow from them. Under the Digital Services Act, Regulation (EU) 2022/2065, platforms that let consumers conclude distance contracts with traders must obtain each trader's contact details, identification, payment account details, trade register number and a self-certification committing to offer only products that comply with Union law (Article 30(1)). Platforms that are micro or small enterprises are exempt from these trader rules unless designated as very large online platforms (Article 29). They must make best efforts to assess whether that information is reliable and complete, including by asking the trader for supporting documents from reliable sources (Article 30(2)), and design their interface so that traders can give product identification and the labelling and marking required by product law (Article 31(1) and (2)). These rules have applied since 17 February 2024 (Article 93(2)); platforms that are micro or small enterprises are exempt unless designated as very large online platforms (Article 29).",
      "sources": [
        4
      ]
    },
    {
      "text": "The General Product Safety Regulation (EU) 2023/988 builds on this for product safety. Each listing must be able to show the manufacturer, the responsible person where the manufacturer is outside the Union, information identifying the product including a picture and type, and warnings and safety information (Article 22(9)). The marketplace's internal processes must let traders provide that information and their self-certification (Article 22(10)). Neither act names the declaration of conformity or a test report as something the trader must upload. A request for them is the marketplace's own way of meeting its duties, set out in its terms.",
      "sources": [
        1,
        4
      ]
    },
    {
      "text": "The declaration itself comes from the CE acts. Under the Low Voltage Directive 2014/35/EU, the manufacturer draws up an EU declaration of conformity once conformity has been demonstrated (Article 6(2)); it follows the model in Annex IV, identifies the equipment, references the standards applied, is continuously updated and is translated into the languages the Member State requires (Article 15(1) and (2)). Where several acts require a declaration, there is one declaration naming them all (Article 15(3)). The Toy Safety Directive 2009/48/EC calls it an EC declaration of conformity (Article 15), and a toy needs an EC-type examination by a notified body where harmonised standards covering all its safety requirements do not exist, were not applied or were applied only in part, were published with a restriction, or where the manufacturer considers third-party verification necessary (Article 19(3)).",
      "sources": [
        2,
        3
      ]
    },
    {
      "text": "Test reports are part of the evidence behind the declaration. The Low Voltage Directive lists them in the technical documentation (Annex III, point 2(f)), and the GPSR's technical documentation includes the outcome of tests where appropriate (Article 9(2)(a)). The Commission's Blue Guide describes the declaration as the document stating that the product meets all relevant requirements and says it must be made available to authorities on request (section 4.4). What a marketplace may see beyond that is a matter between it and the seller.",
      "sources": [
        1,
        2,
        5
      ]
    }
  ],
  "steps": [
    {
      "name": "Find out which document the product actually has",
      "text": "A declaration of conformity exists only for products under a CE act, such as electrical equipment or toys. A product covered only by the GPSR has technical documentation but no declaration. If the field insists on a declaration for such a product, tell the marketplace why there is none rather than inventing one.",
      "item": "product-validation"
    },
    {
      "name": "Check the declaration before you upload it",
      "text": "It must identify the listed model, name every act that requires a declaration for it in a single document, reference the standards applied with their versions, name the notified body where one took part, and carry the date and signature of the manufacturer or its authorised representative.",
      "item": "documentation-generator"
    },
    {
      "name": "Pick the test report that backs the declaration",
      "text": "Choose a report that names your model and the standards listed in the declaration. Whether you upload the full report or a summary is between you and the marketplace; set by agreement. The report stays part of the manufacturer's technical documentation either way."
    },
    {
      "name": "Match the documents to every listing",
      "text": "Upload against each listing and each variant the declaration covers, and make sure the model, type and identifiers in the listing match those in the documents. A declaration for a different model does not support the listing."
    },
    {
      "name": "Keep a record and update it",
      "text": "Note which document version sits on which listing. When the declaration changes, for example after a new standard version or a new manufacturer address, replace it everywhere it was uploaded."
    }
  ],
  "documents": [
    {
      "name": "EU declaration of conformity, for products under a CE act",
      "from": "The manufacturer or its authorised representative",
      "ground": "LVD Article 15 and Annex IV; Toy Safety Directive Article 15"
    },
    {
      "name": "Test report naming the model and the standards in the declaration",
      "from": "A laboratory, via the manufacturer",
      "ground": "LVD Annex III point 2(f); GPSR Article 9(2)(a)"
    },
    {
      "name": "Listing information required for every offer",
      "from": "You, the trader",
      "ground": "GPSR Article 22(9) and (10)"
    },
    {
      "name": "Your self-certification to the marketplace",
      "from": "You, the trader",
      "ground": "Digital Services Act Article 30(1)(e); GPSR Article 22(10)(b)"
    }
  ],
  "risks": [
    {
      "title": "Account suspended for inaccurate information",
      "text": "If the marketplace has reason to believe your trader information, including the self-certification, is inaccurate or incomplete and you do not correct it, a marketplace within the Digital Services Act's trader rules must suspend its service to you (Article 30(3); micro and small platforms are exempt unless designated as very large, Article 29).",
      "source": 4
    },
    {
      "title": "Suspension for repeated non-compliance",
      "text": "Marketplaces suspend, for a reasonable period and after a prior warning, traders that frequently offer products that do not comply with the GPSR (Article 22(11)).",
      "source": 1
    },
    {
      "title": "Listings removed on an authority order",
      "text": "A marketplace that receives an authority order about a dangerous product must act within two working days (GPSR Article 22(4)).",
      "source": 1
    }
  ],
  "faq": [
    {
      "q": "Does the law require us to upload a declaration to the marketplace?",
      "a": "No article read for this page does. The law requires the declaration to exist and to be available to authorities on request. The upload is the marketplace's own requirement, set by agreement in its terms, which it uses to assess the information you provide."
    },
    {
      "q": "Our product has no CE marking. What do we upload?",
      "a": "There is no declaration of conformity under the GPSR. The manufacturer draws up technical documentation instead (GPSR Article 9(2)). Upload what the marketplace accepts for such products, often a test report or a statement, and say plainly that no declaration exists."
    },
    {
      "q": "Do we have to share the full test report?",
      "a": "The law does not say. Test reports belong to the manufacturer's technical documentation, which is kept for authorities. How much a marketplace sees is set by agreement. A report that does not name your model does not help either way."
    },
    {
      "q": "Can one declaration cover a product under several acts?",
      "a": "It must. Where a product falls under more than one act requiring a declaration, the manufacturer draws up a single declaration naming all of them (LVD Article 15(3)). Upload that single document."
    },
    {
      "q": "The toy declaration is called an EC declaration. Is that wrong?",
      "a": "No. The Toy Safety Directive 2009/48/EC uses the term EC declaration of conformity (Article 15). The Directive is repealed by Regulation (EU) 2025/2509 with effect from 1 August 2030; until then its terms apply."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 2009/48/EC on the safety of toys, consolidated text of 29 August 2026",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009L0048-20260829",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2022/2065 on a Single Market for Digital Services (Digital Services Act)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R2065",
      "accessed": "2026-10-04"
    },
    {
      "title": "The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01)",
      "publisher": "European Commission, via EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "retailer-proof",
    "marketplace-listing-removed",
    "marketplace-account-suspended",
    "first-declaration-of-conformity",
    "several-acts-one-doc",
    "supplier-no-test-report"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-05",
  "notice": "General information, not legal advice."
}