Article 20 requires manufacturers to draw up an EU Declaration of Conformity (DoC) for each product before placing it on the EU market. The DoC formally declares that the product meets all applicable CRA requirements (Annex I) and relevant harmonised standards. It is the legal cornerstone of CE marking.
What Is the EU Declaration of Conformity?
The EU Declaration of Conformity (DoC) is a formal legal document in which the manufacturer declares, under their sole responsibility, that the product complies with all applicable requirements of the CRA.
- Drawn up for each product (or product family where risks are identical)
- Available to market surveillance authorities at all times
- Updated whenever the product is substantially modified
- Kept for 10 years after the product is placed on the market
The DoC is not the same as the technical file — it is a summary declaration that references the technical evidence held elsewhere.
Required Contents of the EU Declaration of Conformity
Per Annex IV of the CRA, the Declaration of Conformity must include:
- Product identification — Name, type, batch, serial number, or other identifier
- Manufacturer details — Name, registered address, and contact information
- Scope of declaration — Statement that the product meets CRA requirements
- Relevant legislation — Reference to the CRA and any other applicable directives
- Harmonised standards referenced — Any EU harmonised standards applied
- Notified body reference — If third-party assessment was used (required for Annex III products), include the notified body's name and certificate number
- Date and place of issue
- Authorised signatory — Name and signature of the person authorised to sign on behalf of the manufacturer
CE Marking and the DoC
The CE marking can only be affixed after the DoC has been drawn up. The CE mark is a visible declaration to market surveillance authorities and customers that the product meets EU requirements.
- CE marking must be affixed on the product or its packaging
- If the product is too small for physical marking, the CE mark may be on accompanying documentation
- The DoC reference number should be available via QR code or product documentation
Affixing a CE mark without a valid DoC backed by proper technical documentation is a serious regulatory offence.
CVD Portal helps you comply with Article 20 automatically.
Public submission portal, 48-hour acknowledgment tracking, Article 14 deadline alerts, and CSAF advisory generation. Free forever.
Start your free portalFrequently asked
Can one DoC cover multiple products?+
Yes — a single DoC can cover a product family if all products in the family have the same cybersecurity risk profile and the same technical documentation applies. However, if products within the family have significantly different security properties or configurations, separate DoCs are recommended.
Does the DoC need to be publicly available?+
The CRA does not require the DoC to be proactively published, but it must be available to market surveillance authorities on request. Many manufacturers choose to publish DoCs on their websites for customer transparency.
What language must the DoC be in?+
The DoC must be available in the official language(s) of each EU member state where the product is sold, or in a language accepted by the relevant national authority.
Related CRA Articles
Need a CVD policy that satisfies Article 20?
Download a free CRA-compliant template and deploy it in minutes.