One product, several acts: we need one declaration

Many products fall under more than one CE act at once: a mains-powered appliance under the Low Voltage and EMC Directives, electrical and electronic equipment under RoHS as well, and a connected device under the Radio Equipment Directive. The acts answer the paperwork question the same way. Where equipment is subject to more than one Union act requiring an EU declaration of conformity, a single declaration shall be drawn up in respect of all such acts, and it shall identify the acts concerned including their publication references (Directive 2014/35/EU Article 15(3)). The EMC Directive 2014/30/EU (Article 15(3)) and the Radio Equipment Directive 2014/53/EU (Article 18(3)) contain the same rule. It goes back to Article 5 of Decision No 768/2008/EC, which asks harmonisation legislation to provide for a single declaration containing all information needed to identify the acts it relates to.^[1][3][2][6]

Radio equipment changes which acts appear. Radio equipment within the scope of Directive 2014/53/EU is not subject to the Low Voltage Directive except as set out in its Article 3(1)(a) (Article 1(4)). Instead, its essential requirements include the protection of health and safety with the Low Voltage Directive's safety objectives but no voltage limit, and an adequate level of electromagnetic compatibility as set out in the EMC Directive (Article 3(1)). The Annex VI model reflects this: the conformity statement names Directive 2014/53/EU and other Union harmonisation legislation where applicable, and lists the standards with their identification number and version and, where applicable, date of issue.^[2]

RoHS needs a declaration but lets the evidence be shared. Directive 2011/65/EU requires an EU declaration of conformity with the model and elements of its Annex VI (Article 13(2)). Its manufacturer obligations refer to internal production control under Module A of Decision No 768/2008/EC, and where another act requires a conformity procedure at least as stringent, compliance with the substance restrictions in Article 4(1) may be demonstrated within that procedure, with a single technical documentation (Articles 7(b) and (c) and 13(2)). The RoHS article itself has no single-declaration clause; the rule in the Low Voltage, EMC and Radio Equipment Directives covers all acts requiring a declaration, RoHS included. For toys, from 1 August 2030 a digital product passport under Regulation (EU) 2025/2509 that contains all the information these acts require for the declaration counts as their declaration (Article 19(5)).^[4][7]

The combined declaration still has to carry everything each model asks for. The EMC model asks for the date of each standard and any notified body intervention (Annex IV); the radio model adds accessories and software covered by the declaration (Annex VI). Each act requires the declaration to be kept up to date and translated into the languages the Member State of sale requires (Directive 2014/35/EU Article 15(2); Directive 2014/53/EU Article 18(2)). Missing acts or out-of-date references are formal non-compliance that an authority can order corrected (Regulation (EU) 2019/1020 Article 16(3)(a)).^[1][2][5]