A marketplace wants our declaration and test report uploaded

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).^[4]

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.^[1][4]

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)).^[2][3]

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.^[1][2][5]