How to Create an EU Declaration of Conformity for Electronics

This guide explains how to create an EU Declaration of Conformity for electronic products. The example in this guide is based on Annex IV of the Low Voltage Directive. That said, the same principles apply to the Declaration of Conformity model structures found in many other regulations and directives applicable to electronics.

1. Product model/product (product, type, batch or serial number):

The device covered by the Declaration of Conformity must be identified under the first point. This generally includes the following information:

• Product name
• Product model number or SKU
• Batch number or serial number format

You may also include information about other variations of the same product model.

It should also be noted that this should match the information specified on the product labels, test reports, and technical documentation.

2. Name and address of the manufacturer or his authorised representative:

The name and address of the manufacturer must be indicated:

• Manufacturer company name
• Manufacturer address

If you have an Authorised Representative, which is mandatory if you are a non-EU company selling directly to consumers in the EU, then their company name and address must be specified.

3. This declaration of conformity is issued under the sole responsibility of the manufacturer.

This is a statement.

4. Object of the declaration (identification of electrical equipment allowing traceability; it may include a colour image of sufficient clarity where necessary for the identification of the electrical equipment):

Under this section, you can include information or product images that make it possible to trace the Declaration of Conformity to a specific product or series of products. If your device comes with an AC adapter, USB cables, or other accessories covered by the Declaration of Conformity, then these should also be included under this point.

Example

5. The object of the declaration described above is in conformity with the relevant Union harmonisation legislation:

Under this section, you must list the EU regulations and directives that the electronic device complies with. What you must list here depends on which regulations and directives apply, which in turn depends on the parameters of your product.

Here are some of the key factors:

• Input and output voltage
• If your device contains a battery
• If your device can connect to the internet
• If your device is Bluetooth, WiFi, 5G or GPS enabled

Overview

Regulation/Directive	Scope
RoHS Directive	Electrical and electronic equipment
EMC Directive	Electrical and electronic equipment
Low Voltage Directive	Electrical equipment within the following voltage rating: 50-1,000 V AC 75-1,500 V DC
Radio Equipment Directive	Radio equipment (i.e., WiFi, Bluetooth, 5G and GPS-enabled devices)
Ecodesign Directive	Energy-related products
Ecodesign for Sustainable Products Regulation	Electrical and electronic equipment
Batteries Regulation	Batteries
Cyber Resilience Act	Products with digital elements that are designed to be connected to a device or network.

Product case studies

Here is a comparison between an electric heater and a Bluetooth speaker containing a lithium battery.

Regulation/Directive	Electric heater	Bluetooth speaker
RoHS Directive	Yes	Yes
EMC Directive	Yes	Yes
Low Voltage Directive	Yes	No
Radio Equipment Directive	No	Yes
Ecodesign Directive	Yes	No
Ecodesign for Sustainable Products Regulation	Yes	No
Batteries Regulation	No	Yes
Cyber Resilience Act	No	No

6. References to the relevant harmonised standards used or references to the other technical specifications in relation to which conformity is declared:

Under this section, you must list the harmonised standards applied to your product. Note that each of the regulations and directives listed above has its own set of harmonised standards. As such, you must list harmonised standards that belong to each of the applicable EU regulations and directives.

Note that you must be able to demonstrate how compliance with listed standards was verified prior to the creation of the Declaration of Conformity. In general, this requires third-party lab testing.

Below follow a few examples of such standards:

RoHS Directive

EN IEC 63000 – Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances

EMC Directive

EN 61000-3-2 – Electromagnetic compatibility (EMC) – Part 3-2: Limits – Limits for harmonic current emissions (equipment input current ≤ 16 A per phase)

EN 61000-6-1 – Electromagnetic compatibility (EMC) – Part 6-1: Generic standards – Immunity for residential, commercial and light-industrial environments

EN 60730-1 – Automatic electrical controls for household and similar use – Part 1: General requirements

Low Voltage Directive

EN 50106 – Safety of household and similar electrical appliances – Particular rules for routine tests referring to appliances under the scope of EN 60335-1

EN 50689 – Safety of laser products – Particular Requirements for Consumer Laser Products

EN 60309-1 – Plugs, socket-outlets and couplers for industrial purposes – Part 1: General requirements

Radio Equipment Directive

EN 18031-1 – Common security requirements for radio equipment – Part 1: Internet connected radio Equipment

EN 302 502 V2.1.1 – Wireless Access Systems (WAS); 5,8 GHz fixed broadband data transmitting systems; Harmonised Standard covering the essential requirements of Article 3(2) of Directive 2014/53/EU

EN 302 066 V2.2.1 – Short Range Devices (SRD); Ground- and Wall- Probing Radio determination (GPR/WPR) devices; Harmonised Standard for access to radio spectrum

7. Additional information:

Finally, you must also assign a person in your company who signs the Declaration of Conformity.

Signed for and on behalf of:

(place and date of issue):

(name, function) (signature):

Other DoC requirements for electronics

This Declaration of Conformity is based on Annex IV of the Low Voltage Directive. However, you can find Declaration of Conformity model structures in the following regulations and directives:

• RoHS Directive: Annex VI
• EMC Directive: Annex IV
• Low Voltage Directive: Annex IV
• Radio Equipment Directive: Annex VI
• Ecodesign Directive: Annex VI
• Ecodesign for Sustainable Products Regulation: Annex V
• Batteries Regulation: Annex IX
• Cyber Resilience Act: Annex V

FAQ

Do we need more than one Declaration of Conformity?

Most companies only issue a single Declaration of Conformity. That being said, the model structure does differ between regulations and directives applicable to electronics. If more than one regulation or directive applies, which is likely the case, then you may need to combine elements from more than one Declaration of Conformity model structure.

Is it mandatory to create a Declaration of Conformity for each electronic product?

Yes, you need to create a Declaration of Conformity for each electronic product you place on the EU market.

What is the required Declaration of Conformity format for electronics?

The model structure is decided by the regulations and directives that apply. You can find model structures in the annexes listed above.

Who is responsible for creating a Declaration of Conformity for electronics?

The manufacturer is responsible for creating the Declaration of Conformity.

Do electronics importers need to create a Declaration of Conformity?

No, importers do not create the Declaration of Conformity, but they must obtain one from the manufacturer.