Who is legally allowed to sign a Declaration of Conformity for a product?

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Jason van de Zande

The legally allowed signatory for an EU Declaration of Conformity is the manufacturer or a duly empowered representative acting on the manufacturer’s behalf, depending on the specific EU harmonisation legislation that applies to the product. The signatory must have authority to bind the manufacturer and access to the evidence proving compliance.

In practice, the EU Declaration of Conformity is most common for CE-marked products, where the manufacturer takes legal responsibility for meeting all applicable requirements before placing the product on the EU market. The key is not job title, but legal role, written authority, and control of the compliance file.

The questions below break down who can sign, what they must know, and when other economic operators can or cannot sign instead.

Who is legally allowed to sign a Declaration of Conformity?

The EU Declaration of Conformity must be signed by the manufacturer, or by a natural person who is authorised to sign on the manufacturer’s behalf under the relevant EU product legislation. For a CE marking declaration of conformity, the signature represents the manufacturer’s formal statement that the product meets all applicable EU requirements.

For most CE-marked products, the manufacturer is the legal entity that designs or manufactures the product (or has it designed or manufactured) and markets it under its name or trademark. That manufacturer is the party that issues the EU Declaration of Conformity and keeps control of the supporting evidence.

Many companies delegate the act of signing internally to a senior employee, such as a compliance manager or director, but the delegation should be explicit and documented. The signature is not a formality. It is the point where the manufacturer accepts legal responsibility for conformity.

Also note the scope: an EU Declaration of Conformity is tied to specific EU harmonisation legislation (for example, CE marking frameworks). It is not a universal document for every consumer product category, and it is separate from General Product Safety Regulation (EU) 2023/988 (GPSR) obligations.

What authority and information must the DoC signatory have?

The Declaration of Conformity signatory must have written authority to bind the manufacturer and enough access to compliance evidence to make the declaration truthful and defensible. That means the signatory can confirm which EU laws apply, which standards were used, and where the technical documentation is stored so it can be produced to authorities on request.

To keep the EU Declaration of Conformity credible and audit-ready, the signatory should be able to verify at least the following before signing:

  • Correct legal entity details for the manufacturer and, where applicable, any authorised representative named on the document
  • Product identification that matches labelling and traceability information, such as model, type, batch, or serial references
  • Applicable EU legislation and any relevant conformity assessment route used
  • Standards and specifications actually applied, with versions that match the test reports
  • Supporting evidence such as test reports, risk assessment, design and manufacturing controls, and instructions and safety information
  • Technical documentation location and a process to provide it promptly if a market surveillance authority requests it

A practical rule: if the signatory cannot explain how conformity was demonstrated, or cannot ensure the file can be produced quickly, they should not sign. Signing without that control creates avoidable exposure if authorities challenge the CE marking declaration of conformity.

Can an importer, distributor, or responsible person sign the DoC instead of the manufacturer?

Usually, no. An importer or distributor generally cannot sign the EU Declaration of Conformity instead of the manufacturer because the DoC is the manufacturer’s legal declaration of compliance under EU harmonisation rules. A Responsible Person under GPSR also does not replace the manufacturer as the DoC signatory, because the RP role is different from issuing conformity declarations.

Importers and distributors have their own obligations, such as checking that required documents exist and cooperating with authorities, but those duties do not automatically give them authority to sign on behalf of the manufacturer. If an importer signs without being empowered by the manufacturer and permitted by the applicable legislation, the document may be treated as invalid and can trigger enforcement attention.

For GPSR, the Responsible Person is an economic operator established in the EU that supports product safety compliance and cooperation. Under Market Surveillance Regulation (EU) 2019/1020 (MSR), the Responsible Person must, among other tasks, inform the manufacturer if there are risks indicated by complaints or other information, but the RP is not the party responsible for notifying serious risks to authorities. That notification responsibility sits with the authorised representative when an authorised representative is appointed for the relevant framework.

There are narrow situations where someone other than the manufacturer signs, but the key condition is formal empowerment and legal fit. If a manufacturer’s authorised representative is appointed under the applicable legislation and is explicitly mandated to sign, then the representative can sign in the manufacturer’s name and on the manufacturer’s responsibility. That is not the same as an importer or distributor signing for convenience.

How EARP helps with Declaration of Conformity sign-off and EU market access?

To support correct Declaration of Conformity sign-off and smoother EU market access, we focus on making sure the right economic operator signs the right document for the right legal framework, and that the supporting file is complete and retrievable when authorities ask. We also help non-EU businesses meet GPSR Responsible Person requirements without creating conflicts of interest.

  • Role clarity so you do not confuse manufacturer, importer, distributor, authorised representative, and responsible person responsibilities
  • Documentation readiness checks to confirm required product safety documents are present, consistent, and traceable to the product
  • Technical documentation storage and retrieval processes so materials can be made available to authorities upon request
  • Regulatory liaison support to help you respond efficiently to market surveillance questions and reduce disruption to listings and shipments

If you want help validating who should sign your EU Declaration of Conformity and setting up a reliable compliance process, review our EU compliance services and then reach out through our contact page to discuss your product and sales channels.

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