“The EU type‑examination certificate is the only thing that matters. At least that one is issued by an independent laboratory. A declaration of conformity? Anyone can write whatever they want on a document.”
This is a common assumption — but it is not entirely correct.
Why not?
EU Regulation 2016/425 is built on the combination of the type‑examination certificate and the declaration of conformity. That is intentional.
The type‑examination certificate is the result of an assessment of a type, a prototype. It applies only to the samples that were tested and approved. It says nothing about the production that follows afterwards.
That is where the declaration of conformity comes in. In this document, the manufacturer declares that all products placed on the market under the same reference are identical to the samples submitted to the notified body for approval.
In essence, the declaration of conformity is therefore much more important than the type‑examination certificate. It is also the only document that must be supplied to the customer under EU 2016/425 — not the type‑examination certificate.
In theory, anyone could indeed “put anything on paper”, but falsifying a declaration is a criminal offence for a reason.
What are the essential elements of a declaration of conformity?
- Identification of the product concerned (name, number, batch or serial number)
- Name and address of the manufacturer or its authorised representative
- The applicable legislation (EU 2016/425)
- The harmonised standards applied during design (including the year of publication)
- The notified body that carried out the type‑examination
- For Category III products: the notified body responsible for ongoing quality assurance, including the chosen module (C2 or D)
- Place and date of signature
- Signature
- Name and function of the signatory