Simplified EU Declaration of Conformity for Space-Constrained Products

Annex IX allows use of a simplified EU Declaration of Conformity where including the full Annex V declaration would be disproportionate or impractical. The regulation does not define 'disproportionate' with precision, but typical scenarios include:

• Miniaturised hardware: Small IoT devices, embedded components, microcontrollers, or sensors where physical packaging is minimal and there is insufficient space for a printed full declaration
• Components for integration: Products sold primarily to other manufacturers for integration into end products, where the end product's packaging will carry the relevant declarations
• Software-only products: Applications or firmware distributed as downloads, where there is no physical packaging — the simplified declaration can appear in the installation interface with a link to the online full declaration
• High-volume consumer electronics: Where inserting a full multi-page declaration in every product box would be operationally burdensome and the same information is fully accessible online

The simplified declaration is not a reduced compliance standard — it is an alternative presentation format. The full declaration must exist and must be accessible at the referenced URL.

The simplified EU Declaration of Conformity under Annex IX contains a short statement that must include the following minimum information:

1. Product identification: The product name and model number (sufficient to match the product in question to the referenced full declaration)
2. Manufacturer identification: The manufacturer's name or registered trademark
3. Declaration statement: A statement that the full EU Declaration of Conformity is available at the following internet address:
4. URL: The full URL of the online page where the Annex V declaration can be accessed — this must be a direct link to the document, not a general homepage

The simplified declaration is typically formatted as a short printed insert in product packaging, a brief label on the product or its packaging, or a statement in the product's installation interface or 'about' section.

The URL referenced must resolve to the full Annex V declaration at all times. A link that returns a 404 error or redirects to a different page is a compliance failure.

The most operationally demanding aspect of using the simplified declaration is the obligation to maintain the online full declaration at a stable, accessible URL throughout the product's active market life and for 10 years afterwards.

Manufacturers should:

• Host the full declaration on infrastructure with high availability and long-term stability
• Avoid using URLs that depend on content management system structures that may change (for example, blog post URLs or dated page paths)
• Use stable URL patterns such as https://compliance.yourcompany.com/docs/cra/product-model-v1.pdf
• Implement URL redirects if the underlying document URL needs to change, ensuring old URLs continue to resolve
• Include the URL in multiple locations — the simplified declaration, the product's user documentation, and the manufacturer's compliance page — so users can find it through multiple paths

If the URL becomes inaccessible — for example, because the manufacturer changes its website — this creates a compliance gap. Domain changes, website migrations, and corporate events (mergers, acquisitions) that affect web infrastructure can all pose risks to URL stability.

For software products and digital goods distributed without physical packaging, the simplified declaration is the natural format. The declaration can be incorporated into the product's installation process, displayed in the product's user interface, or included in the digital documentation bundle downloaded with the product.

For mobile applications, the simplified declaration can appear on the app store product page, in the app's settings or 'about' section, and in the app's terms and conditions or legal documentation. All three locations are recommended to ensure discoverability.

For enterprise software distributed under licence agreements, the simplified declaration (or full declaration) can be incorporated into the software licence documentation provided to customers. Enterprise customers often require compliance documentation as part of procurement processes — providing it proactively reduces procurement friction.

The simplified EU Declaration of Conformity under Annex IX is the accompanying documentation for the CE marking — it does not replace the CE marking itself. The CE marking must still be affixed to the product, its packaging, or its documentation in accordance with Article 23, regardless of whether a simplified or full declaration format is used.

For miniaturised products where even the CE marking cannot be physically affixed in the required manner, the CE marking rules under Article 23 must also be consulted — in some cases the marking can appear on packaging or documentation rather than the product itself.

Manufacturers using the simplified declaration format should review both Annex IX and Article 23 to ensure that their CE marking placement and declaration format are both compliant.