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An Attestation of Conformity is a third-party issue certificate “attesting” that a certain product complies with specified regulations, directives, and standards. A legit Attestation of Conformity can be valuable in the sense that it provides an opinion from a third-party declaring that a product is compliant.
However, many Attestation of Conformity certificates are issued on questionable grounds, which can result in serious consequences for importers and other buyers accepting such documents at face value.
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What is an Attestation of Conformity?
An Attestation of Conformity is generally a voluntary certificate issued by a third-party “attesting” that a certain product is compliant with specified regulations, directives, and product standards.
Attestation of Conformity certificates are more commonly issued to attest compliance with EU and UK compliance requirements, compared to those in the United States and other countries.
An Attestation of Conformity can be valuable if it is issued on the basis of a careful evaluation of product compliance documentation, test reports, labelling, and other relevant information. This is valuable for two reasons:
1. It provides manufacturers with an “opinion” that the product is compliant (it is not always easy to determine if a collection of documents, label files and test reports is sufficient).
2. It provides importers and other buyers with an “assurance” that a product is compliant.
In practice, however, Attestation of Conformity certificates are often issued without any such review taking place. This essentially means that many Attestations of Conformity certificates are worthless and even deceptive.
Unfortunately, these documents are so common today that the European Commission has issued a warning about so-called “voluntary certificates”.
Attestation of Conformity certificates tend to look official, and thus, many companies (especially importers) tend to accept these at face value.
This can, if the Attestation of Conformity certificates are rejected, result in recalls, fines and goods being seized and destroyed by the customs authorities.
Amazon and other marketplaces can also remove product listings without sufficient compliance documentation.
Is an Attestation of Conformity proof that my product is compliant?
No, an Attestation of Conformity alone is generally not sufficient to demonstrate compliance with regulatory requirements in the EU, UK or other markets.
Sending an Attestation of Conformity certificate (without other supporting documents) to the customs authorities, market surveillance investigators or Amazon will almost certainly result in rejection.
Only the compliance documentation required by relevant regulations and or directives can be used to demonstrate compliance. A third-party issued Attestation of Conformity certificate cannot override regulatory requirements and the documentation needed.
How do I know if an Attestation of Conformity is valid?
You can generally contact the issuing company to verify if the Attestation of Conformity is valid. Some companies, like TÜV SÜD, also provide online certificate verification.
You should also ensure that the document contains:
1. The correct manufacturer name
2. The correct product model/SKU
While doing so, you should also ask if they can facilitate any test reports that the Attestation of Conformity is based on.
If test reports cannot be provided, which is often the case, then it is likely that no product testing took place and that the Attestation of Conformity certificate is thus based on nothing but an exchange of money.
What is the difference between an Attestation of Conformity and a test report?
A test report details actual safety, performance or chemical tests and their outcomes. As such, a test report is a technical document that, if passed, serves as evidence that a product is safe and compliant.
An Attestation of Conformity, on the other hand, is usually a one-page document stating that a certain product complies with listed regulations and standards. There is no record specifying what tests took place, and the results.
Can I use an Attestation of Conformity instead of a test report?
No, an Attestation of Conformity certificate cannot replace a test report as it does not contain test data.
A legit Attestation of Conformity should contain a reference to one or more test reports. The supporting test reports should also be readily available.
Does an Attestation of Conformity replace a Declaration of Conformity?
No, an Attestation of Conformity is not the same as a Declaration of Conformity. The latter must contain the information specified in the relevant EU and UK legislation.
As such, an Attestation of Conformity is never a substitute or replacement for a Declaration of Conformity.
Can I use an Attestation of Conformity instead of an EC-type examination certificate?
No, an EC-type examination certificate is issued by a Notified Body (or a Type examination certificate from an Approved Body in the UK). An Attestation of Conformity cannot replace an EC-type examination certificate.
Which companies issue Attestation of Conformity certificates?
Attestation of Conformity certificates are often issued by third parties in Europe and Asia.
As mentioned, not all Attestation of Conformity certificates are issued on questionable grounds. I have seen such documents issued by TÜV SÜD and other trustworthy companies.
The problem is that some companies somehow obtain Attestation of Conformity certificates without testing ever taking place. The question is then how a third party can attest to something that has never been verified.
Why do suppliers provide Attestation of Conformity documents?
My best guess is that many manufacturers simply don’t know better. Some may have a vague idea that their products must be CE marked or comply with other regulations, and seek out services from third-party companies offering the cheapest possible solution.
As it will always be cheaper to issue a certificate out of thin air than to do actual testing, it likely comes down to a combination of not understanding what is actually required and cutting costs.
Ultimately, it is up to importers in the EU, the UK and elsewhere to understand and follow actual product regulations rather than relying on wishful thinking that fancy-looking PDF files solve the problem.
Attestation of Conformity Example
This is an example of an Attestation of Conformity certificate issued by TÜV SÜD in 2022. This is an example of a “legit” Attestation of Conformity document.
There are a few things that are noteworthy about this Attestation of Conformity:
Test report number
The Attestation of Conformity references a test report – this indicates that the certificate is based on actual lab testing taking place
Statements
This Attestation of Conformity is issued on a voluntary basis according to the Low Voltage Directive 2014/35/EU relating to electrical equipment designed for use within certain voltage limits. It confirms that the listed equipment complies with the principal protection requirements of the directive and is based on the technical specifications applicable at the time of issuance. It refers only to the particular sample submitted for testing and certification.
1. It is specified that the Attestation of Conformity is issued on a voluntary basis. It cannot be used to demonstrate compliance on its own.
Still, for a manufacturer or importer, it is highly valuable that a company like TÜV SÜD attests that the product is compliant, in this case with the Low Voltage Directive.
2. The certificate states that an actual sample was submitted (as said, that is not always the case).
After preparation of the necessary technical documentation as well as the EU declaration of conformity the required CE marking can be affixed on the product. The declaration of conformity is issued under the sole responsibility of the manufacturer. Other relevant EU-directives have to be observed.
TÜV SÜD does not claim that the Attestation of Conformity is a replacement for technical documentation or a Declaration of Conformity.
