Declaration of Conformity Template: Fields, Signing, and Retention

A declaration of conformity template needs to capture four things at minimum: what the product is, who is taking legal responsibility for it, which regulations and standards it complies with, and a dated signature from an authorized person. There is no single government-issued form to download. Instead, each regulatory system, whether the EU, Great Britain, the U.S. Consumer Product Safety Commission, or the FCC, prescribes a set of required data elements you must include. Miss one, and the declaration can be treated as invalid.

The right template depends on where you’re selling. Below are the required fields for each of the major regimes, along with the details that most often trip manufacturers up.

EU Declaration of Conformity Fields

The EU declaration follows the model in Annex III of Decision No 768/2008/EC. You don’t have to use a specific form, but every declaration has to contain the same eight elements in a format authorities recognize:

  • Unique product identification: a name, type number, batch number, or serial number that lets an inspector tie the declaration to a specific item or production run.
  • Manufacturer or authorized representative: full legal name and registered address. If the manufacturer sits outside the EU, the EU-based authorized representative goes here instead.
  • A statement that the declaration is issued under the sole responsibility of the manufacturer.
  • Product description with enough detail for traceability, including a color image where identification requires it.
  • A statement that the product complies with the relevant EU harmonization legislation.
  • Reference numbers and dates of the harmonized standards or specifications used to demonstrate conformity.
  • Notified body information, where a third-party assessment body was involved: its name, identification number, description of what it did, and the certificate number issued.
  • Signature block: place and date of issue, plus the name, job title, and signature of the person authorized to sign for the manufacturer.

By drawing up the declaration, the manufacturer assumes legal responsibility for compliance. Article R10 of Decision 768/2008/EC is explicit on that point. If a market surveillance authority later finds the product doesn’t meet the stated requirements, the person who signed carries personal and corporate exposure.

Listing the Right Directives and Standards

The compliance section is where most templates go wrong. You need to list every EU directive that applies to your product, not just the most obvious one. A single electronic device can fall under the Low Voltage Directive (2014/35/EU), the EMC Directive (2014/30/EU), and the RoHS Directive (2011/65/EU) at the same time. Missing one can invalidate the entire declaration.

Under each directive, list the harmonized EN standards you tested against. For example, EN 62368-1 covers safety for audio, video, and information technology equipment. Take the standard reference numbers and their publication dates from the Official Journal of the European Union, because standards get revised. Citing a superseded version can render your declaration invalid, so if you tested against EN 62368-1:2020 and the current version has been updated, you need to retest or confirm the older version still carries a presumption of conformity.

RoHS deserves a note. Directive 2011/65/EU requires a separate EU declaration of conformity for compliance with the substance restrictions in Article 4, but EU law allows you to combine it into a single technical documentation file alongside your other directives. You don’t need a physically separate document, provided every applicable directive appears on the declaration you draw up.

When the Notified Body Field Applies

Not every product needs third-party involvement. The conformity assessment procedure specified in each directive tells you whether you can self-assess or must engage a notified body. For many consumer electronics, general electrical equipment, and toys below certain risk thresholds, the manufacturer can test internally (or use a lab voluntarily) and self-declare. Higher-risk products, including medical devices, certain machinery, pressure equipment, and some construction products, require an independent notified body to review the design, witness testing, or audit the quality management system before you sign.

The template reflects the distinction. Field 7 of the Annex III model stays blank when self-assessment applies. When a notified body is involved, you must include its name, four-digit identification number, what it did, and the certificate it issued. Leaving that field empty when third-party assessment was legally required is one of the fastest ways to get a product pulled from the market.

UKCA Declaration for the Great Britain Market

Great Britain uses its own declaration of conformity for the UKCA mark, and the structure closely mirrors the EU model. Same core fields: manufacturer name and address, product identification, responsibility statement, applicable legislation, signature. One useful flexibility: the legislation references can cite either UK regulations or recognized EU product regulations. Under The Product Safety and Metrology (Amendment) Regulations 2024, the UK continues to recognize CE marking alongside UKCA marking for most product categories.

If you already hold a valid EU declaration, you may not need to redo your entire compliance file for the GB market, but you still need a UK-specific declaration document.

U.S. General Certificate of Conformity

The United States doesn’t use the phrase “declaration of conformity” for consumer products. The Consumer Product Safety Commission requires certificates under Section 14 of the Consumer Product Safety Act (15 U.S.C. § 2063). For general-use products subject to a CPSC safety rule, ban, standard, or regulation, the certificate is called a General Certificate of Conformity.

There is no mandatory form. Seven data elements must appear:

  • Product identification detailed enough to tie the certificate to specific products.
  • Each applicable CPSC safety rule the product is certified against, including any exemption citations.
  • Certifier identification: name, full mailing address, and phone number of the domestic manufacturer or importer.
  • Test records contact: name, address, email, and phone number of the person maintaining the test records.
  • Date and place of manufacture, at minimum the month and year, plus the city, state (if applicable), and country of final assembly.
  • Date and place of testing.
  • Testing laboratory: name, address, and phone number, if third-party test results are used.

The certificate and all supporting information must be in English.

U.S. Children’s Product Certificate

For products designed for children 12 and under, the CPSC requires a Children’s Product Certificate. The seven required data elements are identical to the GCC, but with two important differences. The testing laboratory field is mandatory rather than conditional, and the lab must be one the CPSC has accepted. You cannot self-certify a children’s product the way you can with a general-use item. Registered small batch manufacturers who qualify for certain testing exemptions include their CPSC registration number instead of lab information.

FCC Supplier’s Declaration of Conformity

Electronic devices that emit radio frequency energy, including computers, monitors, LED lighting, and many household electronics, need an FCC Supplier’s Declaration of Conformity under 47 CFR 2.1077. This is a separate document from any CPSC certificate and covers electromagnetic interference compliance under Part 15 of the FCC rules.

The SDoC template is shorter than either the EU or CPSC documents. It must include:

  • Product identification: name and model number.
  • A compliance statement declaring that the product complies with the applicable FCC rules. The specific wording is prescribed in 47 CFR 15.19.
  • Responsible party: name, address, and telephone number or internet contact information. The responsible party must be located within the United States.

The U.S. location requirement catches many foreign manufacturers off guard. If the manufacturer has no domestic presence, the importer typically becomes the responsible party. The compliance information has to be included in the user manual or provided as a separate sheet with the product.

Signing the Declaration

Every declaration requires a signature from someone with the legal authority to bind the company, usually a director, quality manager, or regulatory affairs lead. The signature has to be accompanied by the person’s printed name, job title, and the place and date the document was issued. The signer is personally vouching that all testing was completed and every requirement was met before the product reached the market.

Most companies print the declaration on official letterhead, but that isn’t legally required. What matters is the content. The new EU Machinery Regulation (2023/1230) explicitly permits digital-format declarations of conformity and instructions for use once it becomes mandatory on January 20, 2027. For other product categories, EU law does not prohibit electronic formats, and the eIDAS Regulation (910/2014) provides the legal framework for electronic signatures across the EU. Wet-ink signatures on printed documents are still common, but digital versions stored as part of an electronic technical file are increasingly accepted.

Translation of the Declaration

An EU declaration of conformity must be translated into the official language of every EU member state where the product is sold or made available. Selling across the entire single market can mean dozens of translations. The obligation covers the full declaration, not a summary. Most manufacturers prepare translations for their primary markets and add others as distribution expands.

UKCA declarations must be in English. U.S. CPSC certificates must also be in English. The FCC SDoC has no explicit language rule beyond the fact that it ships with a product sold in the U.S. market, so English is the practical standard.

How Long to Keep It on File and When to Update It

EU law requires manufacturers to retain the declaration and supporting technical documentation for 10 years after the last unit of the product has been placed on the market. Some sector-specific legislation extends this. The Medical Device Regulation, for example, requires at least 15 years for implantable devices. The clock starts from the last unit sold, not the first, so a product in production for five years generates a retention obligation stretching at least 15 years from the original design.

The declaration lives inside a technical file that also includes test reports, design drawings, risk assessments, and any notified body certificates. Market surveillance authorities can request the whole file at any time, and you must produce it without unreasonable delay. Electronic storage is permitted as long as the documentation stays accessible and well-organized.

Treat the declaration as a living document. If you change the product design, switch components, or the applicable standards get revised, update the declaration to reflect the current state of compliance. One that was accurate at signing can become invalid if the underlying standards change and you don’t reassess.

What a Defective Declaration Costs You

Enforcement follows a predictable pattern across jurisdictions: delays first, then fines, then market bans.

In the EU, market surveillance authorities in each member state set their own penalty schedules under Regulation (EU) 2019/1020. Consequences run from mandatory withdrawals and recalls to financial penalties that vary significantly by country. A missing or defective declaration is often the first thing inspectors check and the easiest basis for stopping a shipment, since no product testing is needed to act on it.

In the United States, CPSC violations can be expensive. Under 15 U.S.C. § 2069, a knowing violation of certification requirements can trigger civil penalties of up to $100,000 per violation, with a ceiling of $15,000,000 for any related series of violations. For FCC-regulated products, marketing a device without a valid SDoC, or with a responsible party not located in the United States, can result in equipment seizure at the border and monetary forfeitures. The FCC has separate enforcement authority from the CPSC, so a product needing both certificates faces two independent regulatory risks.