What is the EU Declaration of Conformity under GPSR?
The EU Declaration of Conformity (often abbreviated as DoC or EU DoC) is the formal document through which a manufacturer — or their authorised representative — declares that a product complies with all applicable EU legislation. It is a self-declaration, meaning the manufacturer prepares and signs it under their own responsibility; no external certification body is required to validate it, unless the applicable sector-specific legislation specifically requires third-party involvement. The Declaration is a legal instrument, not merely a formality: authorities, customs services, and online marketplaces use it to verify that a product has been assessed and found to meet EU requirements.
Under the GPSR alone, a Declaration of Conformity is not universally mandatory for every product. The GPSR (Regulation (EU) 2023/988) requires manufacturers to compile a technical file including a risk assessment, but does not uniformly mandate a DoC for products covered only by this general regulation. However, a DoC is explicitly required when the product also falls under sector-specific EU legislation that mandates one — such as the Toy Safety Directive (2009/48/EC), the Low Voltage Directive (2014/35/EU), the EMC Directive (2014/30/EU), the Radio Equipment Directive (2014/53/EU), or several others. In those cases, the DoC is both a GPSR-adjacent and a sectoral legal requirement. Even where it is not strictly mandatory, issuing a Declaration of Conformity is strongly recommended practice for any product sold on the EU market, and Amazon systematically requests it when conducting compliance reviews.
A valid EU Declaration of Conformity must contain: the manufacturer's full name, registered trade name or trademark, and postal address; if the manufacturer is outside the EU, the EU Responsible Person's details; a clear identification of the product (type, model, batch, or serial number); a reference to all applicable EU legislation and regulations the product claims to comply with — including Regulation (EU) 2023/988 where relevant; the European harmonised standards or other technical specifications applied to demonstrate conformity; the place and date of issue; and the name, function, and signature of the person authorised to sign on behalf of the manufacturer. The DoC must be included in the technical file and provided to authorities on request.
What the law says
Article 9.2 of Regulation (EU) 2023/988 requires the technical file to include references to standards and conformity assessment procedures used. A Declaration of Conformity is mandatory under sector-specific legislation (Toy Safety Directive, Low Voltage Directive, etc.) and is standard practice for all GPSR compliance files. Amazon requests it as part of its compliance verification process.
Consequences of non-compliance
Missing a Declaration of Conformity when required leads to listing rejection on Amazon and can trigger EU customs holds. For products sold under sector-specific directives, the absence of a DoC means the product is non-compliant even if it is physically safe. Without a DoC, demonstrating due diligence in a product liability dispute is significantly harder.
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