EU Declaration of Conformity

The EU Declaration of Conformity (DoC) is a formal document that manufacturers must create to declare that their products meet all the applicable accessibility requirements of the European Accessibility Act. By drawing up this declaration, the manufacturer assumes full responsibility for the compliance of the product.

This document is a critical part of the conformity assessment process, serving as the manufacturer's official statement that their product complies with the legal requirements. It enables authorities, distributors, and end-users to verify that the product has undergone the necessary assessment procedures.

According to Article 16 of the EAA, the EU Declaration of Conformity:

• Must follow the model structure set out in Annex III to Decision No 768/2008/EC
• Must contain all the elements specified in Annex IV of the EAA
• Must be continuously updated if any changes are made to the product
• Must be translated into the language(s) required by the Member State where the product is placed or made available

The declaration must identify the product for which it has been drawn up, typically including information such as:

• Product name, type, batch or serial number
• Name and address of the manufacturer and, where applicable, their authorized representative
• References to the relevant harmonized standards or technical specifications applied
• Date of issue of the declaration
• Signature of the person responsible

When manufacturers use the exception for fundamental alteration or disproportionate burden under Article 14 of the EAA, the declaration must explicitly state which accessibility requirements are subject to that exception.

The EAA specifies that the requirements for technical documentation should avoid imposing any undue burden for microenterprises and SMEs, while still ensuring sufficient detail to demonstrate compliance.

For detailed information on disproportionate burden assessments, seeAnnex IV: Disproportionate Burden.

Where a product is subject to more than one Union act requiring an EU Declaration of Conformity, manufacturers may create a single declaration that covers all applicable Union acts. This approach:

• Reduces administrative burden on economic operators
• Ensures effective access to information for market surveillance purposes
• Must contain the identification of all the relevant acts, including their publication references

This provision allows manufacturers to include all relevant individual declarations of conformity in a single document, which is particularly useful for products that must comply with multiple directives or regulations.

Manufacturers and importers have specific obligations regarding the EU Declaration of Conformity:

• Manufacturers must keep the declaration for five years after the product has been placed on the market
• Importers must keep a copy of the declaration for five years at the disposal of market surveillance authorities
• A copy of the declaration must be made available to relevant authorities upon request
• Distributors must verify that the product is accompanied by the required documentation, including the declaration when applicable

For more information on market surveillance procedures, seeMarket Surveillance.

The EU Declaration of Conformity is closely linked to the CE marking:

• The CE marking is the visible indication that a product complies with EU legislation
• The EU Declaration of Conformity is the document that substantiates this compliance
• A manufacturer must draw up the EU Declaration of Conformity before affixing the CE marking to a product
• Together, they form a complete conformity assessment process that enables free movement of products in the European market

By affixing the CE marking, the manufacturer declares that the product is in conformity with all applicable accessibility requirements and that they take full responsibility for this conformity.

For detailed information on CE marking requirements, see theCE Marking page.