Hundreds of variants and only one set of documents
EU acts tie the declaration of conformity to a product model and require it to identify the products it covers. One file can serve a family only if it shows that every variant meets the requirements. Group variants by the differences that affect safety or compliance, assess or test those differences, list every covered model in the file and the declaration, and link each item number to its family.
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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice
Why this happens
EU product law thinks in product models, while sales systems think in item numbers. The gap between the two is where variant problems start. Under the Low Voltage Directive 2014/35/EU the manufacturer draws up a written EU declaration of conformity "for a product model", keeps it with the technical documentation for 10 years, and the declaration "shall identify the electrical equipment for which it has been drawn up" (Annex III point 4.2). The declaration model asks for the product, type, batch or serial number and for an object description that allows traceability (Annex IV items 1 and 4).[1]
The technical file must support every variant it is used for. Annex III point 2 of the low voltage directive requires documentation that makes it possible to assess the equipment's conformity, including an adequate analysis and assessment of the risks, covering design, manufacture and operation as far as relevant. Manufacturers must also keep series production in conformity and take changes in design or characteristics adequately into account (Article 6(4)). Each product must bear a type, batch or serial number or another element allowing identification (Article 6(5)).[1]
Radio equipment makes configurations explicit. The conformity assessment must take into account all intended operating conditions, and where the equipment can take different configurations it must confirm that the essential requirements are met in all possible configurations (Directive 2014/53/EU Article 17(1)). The declaration of Annex VI may describe the accessories and components, including software, it covers.[2]
Products outside the CE acts follow the General Product Safety Regulation (EU) 2023/988. The manufacturer's technical documentation contains a general description of the product and its essential characteristics relevant for assessing its safety (Article 9(2)), procedures keep products produced in series in conformity (Article 9(4)), and each product bears a type, batch or serial number or other identifying element, easily visible and legible for consumers (Article 9(5)). The common framework adds that conformity assessment conditions shall be alleviated for custom-made products and small series production (Decision No 768/2008/EC Article 4(4)).[3][4]
How to solve it
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List every variant you place on the market
Export all item numbers, model numbers and configurations from your product data. Include colours, sizes, power ratings, bundled accessories, software versions and regional plugs. Variants you no longer sell but sold in the last 10 years belong on the list too.
Product validationCompliance engine Open in the console -
Sort the differences that matter from those that do not
For each attribute, ask whether it can change a requirement of the act: materials, electrical ratings, radio modules, sizes that change a hazard, warnings and age grading. A colour change in the same material often does not. Write the reasoning down per attribute.
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Form families and assess the differences
Group variants that share every compliance-relevant attribute. Where variants differ in a relevant way, assess or test that difference and add the evidence to the family file. Radio equipment that can take different configurations must be shown to meet the requirements in all of them.
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Name every covered model in the file and the declaration
The declaration identifies the products it was drawn up for. List the model or type numbers it covers, or a clear rule that identifies them, and make sure the same identifiers appear on the products or their packaging.
Documentation generatorCompliance engine Open in the console -
Gate new variants through the family check
Before a new item number goes live, decide which family it joins and whether its differences are already covered. If not, assess it first. Series production must stay in conformity, so the check belongs in the product release process.
Work through the steps in the platform with your own product.
What you need to show
| Document | Where it comes from | Legal ground |
|---|---|---|
| A variant register linking each item number to its family and its declaration | The manufacturer | Directive 2014/35/EU Article 6(5) and Annex III point 4.2 |
| A family file with the base assessment and the evidence for each relevant difference | The manufacturer | Directive 2014/35/EU Annex III point 2; Directive 2014/53/EU Article 17(1) |
| A declaration of conformity whose object identifies every covered model | The manufacturer | Directive 2014/35/EU Annex IV items 1 and 4 |
If you do nothing
A variant not covered by the file is not covered
The declaration is drawn up for a product model and shall identify the electrical equipment for which it has been drawn up (Directive 2014/35/EU Annex III point 4.2).[1]
Configurations must all comply
Where radio equipment is capable of taking different configurations, the conformity assessment shall confirm whether it meets the essential requirements in all possible configurations (Directive 2014/53/EU Article 17(1)).[2]
Identification must match
Manufacturers ensure their products bear a type, batch or serial number or other element enabling identification, easily visible and legible for consumers, or on the packaging where size or nature does not allow it (GPSR Article 9(5); for electrical equipment, Directive 2014/35/EU Article 6(5)).[3]
Questions about this problem
Can one declaration of conformity cover several models?
The low voltage directive asks for a declaration for a product model that identifies the equipment it covers (Annex III point 4.2), and the model asks for the product, type, batch or serial number (Annex IV item 1). The texts read do not say expressly whether one declaration may cover several models. Read together, a declaration used for several models needs to identify each of them, and the technical file must support each one.
Do we need to test every colour?
Not as a rule. The file must make it possible to assess conformity (Directive 2014/35/EU Annex III point 2). Where a colour means a different material or coating that could affect a requirement, assess or test that difference.
What about software versions of a connected product?
Where radio equipment can take different configurations, the assessment must cover all of them (Directive 2014/53/EU Article 17(1)). The declaration may describe accessories and components, including software, it covers (Annex VI).
Do small series get easier rules?
The common framework says the technical and administrative conditions of conformity assessment shall be alleviated for custom-made products and small series production (Decision No 768/2008/EC Article 4(4)). How far depends on the act.
Sources
- Directive 2014/35/EU on electrical equipment designed for use within certain voltage limits (consolidated text of 30 May 2026) EUR-Lex · accessed 4 October 2026
- Directive 2014/53/EU on radio equipment (consolidated text of 30 May 2026) EUR-Lex · accessed 4 October 2026
- Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 4 October 2026
- Decision No 768/2008/EC on a common framework for the marketing of products EUR-Lex · accessed 4 October 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 4 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). Hundreds of variants and only one set of documents. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/variant-families/
Conphora (2026) Hundreds of variants and only one set of documents. Available at: https://www.conphora.com/solutions/problem/variant-families/ (Accessed 13 October 2026).
@misc{conphora2026hundredsofvariantsandonl,
author = {Conphora},
title = {Hundreds of variants and only one set of documents},
year = {2026},
url = {https://www.conphora.com/solutions/problem/variant-families/},
note = {Retrieved 13 October 2026}
} See it working before you add a product
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