GPSR Declaration of Conformity: Template and How-To Guide

A missing Declaration of Conformity can get your listing pulled instantly. That is the short version of why this one-page document matters more than its length suggests. If you sell into the EU under GPSR (Regulation (EU) 2023/988), the Declaration of Conformity is the signed promise that ties your brand, your product, and your test reports together. Get it wrong and Amazon's automated parser rejects it. Get it right and customs has nothing to seize.

This guide covers what the document is, when you actually need one, exactly what it must contain, and the rebranding rule that catches most private-label sellers off guard. There is a fillable template below.

What a Declaration of Conformity actually is

A Declaration of Conformity (DoC) is a document signed by a manufacturer or authorised representative confirming that the product placed on the market complies with applicable EU requirements. It is not a test certificate. It is not something a lab hands you. It is your statement, under your name, that the product meets the law.

The legal weight comes from the signature. By drawing up and signing a DoC, the manufacturer takes responsibility for product compliance with all applicable EU laws. You are not summarizing someone else's work. You are putting your company on the hook.

That distinction trips up a lot of FBA and dropshipping sellers. A CE certificate from a Chinese factory feels like the finished article, so people assume it counts as their DoC. It does not. A CE certificate issued by a third-party testing laboratory is an informative attestation of testing. Only the manufacturer or brand owner placing the product on the EU market can issue and sign the official Declaration of Conformity. The lab report is evidence. The DoC is the declaration built on top of it. For where the DoC fits among your other paperwork, see the GPSR technical documentation template.

The rebranding rule that catches private-label sellers

Here is the rule that changes everything if you sell private label. When you import products and place your own trademark or brand name on them, EU law defines you as the legal manufacturer. You cannot use the supplier's DoC. You must issue your own.

One seller put the misunderstanding plainly: "Ok so is the only thing I need to send them a one page DOC cert that I can make myself? I have the one from the manufacturer so I will just copy that but put my own company name." The instinct is half right and half dangerous. You do make your own one-page document. But copying the supplier's and swapping the company name is not enough, because the rest of the document has to point at your details and your responsibility.

The reason this matters at the border is blunt. As one operator described it, "when you rebrand, EU law legally defines you as the 'manufacturer', making the factory's CE insufficient on its own; you must issue your own declaration of conformity to void customs seizures." Amazon and EU customs reject the supplier's factory DoC for a simple mechanical reason: the brand name on the certificate does not match the brand on your listing and packaging.

So what do you do with the factory's lab work? You bridge it. Private-label sellers can use the original factory's laboratory test reports, EMC, RoHS, EN 71 and the rest, to support their own brand's DoC, provided the product has not been modified. The DoC acts as a formal self-declaration that links your brand, your product model, and your EU address directly to those original test reports. One seller called this "a self-declaration bridge that lets u use the factory's lab reports without their brand name appearing on ur final EU DoC." The lab data stays the same. The responsibility, and the name on the document, becomes yours.

The advice sellers keep repeating to each other is worth memorizing: "For the DoC specifically, make sure it shows your company name as the 'responsible economic operator' with your EU address, not your supplier's."

When you need a DoC, and when you need something close to it

The format follows the rules. The contents of the DoC must follow the model declarations set out in Annex III to Decision 768/2008/EC, or in the annexes to the applicable legislation. That Annex III structure is what marketplaces and surveillance authorities expect to see.

A formal DoC is strictly required for CE-marked products. For non-CE general consumer goods, you still need equivalent technical documentation proving compliance with general safety standards, and some EU retailers will ask for a general compliance statement. The platforms vary too. eBay does not always demand the physical upload of a DoC for non-CE categories, but it mandates that you keep a copy on file, ready for immediate inspection by regulators. Amazon, by contrast, parses your uploaded PDF automatically. If the manufacturer name or the model number in the document does not match your listing's backend metadata, it gets flagged and rejected.

If you are not sure which rules touch your product, the GPSR risk assessment step is where you map applicable directives and standards before you ever draft the declaration.

What the document must contain

A compliant EU Declaration of Conformity follows the standardized fields of Annex III. Leave one out and you have a draft, not a declaration. Here is the model template you can fill in.

EU DECLARATION OF CONFORMITY (No. ______)

1. Product Model / Type / Identification
   Product Name:      [Product Name]
   Model Number:      [Model Number]
   SKU / GTIN:        [______]
   Batch / Serial:    [______]

2. Name and Address of the Manufacturer (Rebrander / Brand Owner)
   Brand Name:        [______]
   Company Name:      [______]
   Postal Address:    [______]
   Email Address:     [______]

   This declaration of conformity is issued under the sole
   responsibility of the manufacturer.

3. Object of the Declaration (Traceability)
   Description:       [______]
   Product Image:     [reference]

4. The object above is in conformity with the relevant Union
   harmonization legislation, e.g.:
   - Directive 2011/65/EU (RoHS)
   - Regulation (EU) 2023/988 (GPSR)

5. References to the relevant harmonized standards used, e.g.:
   - EN IEC 63000:2018 (RoHS technical documentation)
   - EN 71-1:2014+A1:2018 (Toy safety: mechanical/physical)

6. Appointed EU Responsible Person (if manufacturer is outside the EU)
   Company Name:      [______]
   Postal Address:    [Full physical EU address]
   Email Address:     [Active EU email]

7. Signed for and on behalf of:
   Place of Issue:    [City, Country]
   Date of Issue:     [______]
   Name:              [______]
   Function/Position: [______]
   Signature:         [Handwritten or official digital signature]

A few fields do the heavy lifting. The harmonized standards have to be the exact ones your product was tested against, such as EN 71 for toys or EN 62368 for electronics. A DoC is only valid if it references the specific directives and standards verified in your accredited lab reports. Vague or wrong citations are the fastest way to fail an inspection.

The signature block is the other failure point. The DoC must be signed by a responsible employee of the brand owner, showing a printed name, title, and position. A digital or computer-generated signature with no formal attribution gets rejected. Secure e-signatures like DocuSign are fine, as long as they carry the name, date, and position.

If you sit outside the EU, section 6 is not optional. You can sign the DoC yourself, but you must name your appointed EU Responsible Person and their EU address on the document. EUProof generates the DoC and your other GPSR documents, but it does not act as your Responsible Person; you appoint that party separately.

Multi-directive products and bundles

Some products are not so tidy. A smart toy with both radio and electronic components needs a single DoC that references multiple directives at once, which is genuinely hard to draft by hand. Product bundles are similar. If a bundle pulls items from different suppliers, you compile the safety documents and test reports for each item, then draft one master DoC under your brand name that covers the whole set.

This is exactly the kind of stitching that eats an afternoon and still ends in a rejected upload. EUProof builds the DoC from your product details and the directives and standards that apply, so the citations line up and the responsible-operator fields read correctly the first time. You can generate GPSR documents in about five minutes instead of copy-pasting a factory file and hoping. If you want to see the document shells first, browse the templates.

Get it signed, get it filed

Once the document is complete and signed, export it as a PDF. The non-editable format is what marketplaces and regulators require; a fillable Word file is not acceptable for submission. Then keep it. You must retain the DoC and supporting reports for at least 10 years after the last unit of that model is placed on the market.

One last warning, because the downside is real. Signing a false DoC is a serious legal violation. The business can face administrative fines, product recalls, and potential criminal liability for endangering consumers. The signature is a promise. Only sign what your lab reports actually support.

For the full picture of how the DoC fits into your other obligations, start with the pillar guide on what GPSR is.

This article is general guidance, not legal advice. Confirm your obligations with a qualified advisor or your Responsible Person.