The EU declaration of conformity: what it claims, and who it binds

The declaration of conformity is the shortest document in the whole file and the one that carries the most weight. It is not a certificate issued to you by anyone. It is a statement you make.

It is a claim, and you are the one making it

Four lines that explain why this document is not paperwork. Signing it is how the manufacturer assumes responsibility for the machine complying. A notified body may have been involved in the assessment behind it; the declaration is still yours, and so is what it asserts.

A fixed shape, and a living document

Three separate duties in one sentence, and the middle one is the one that gets missed. The model structure is in Annex V Part A, so the form is not yours to design. "Continuously updated" means a declaration is not a thing you sign once and file: change the machine, change a harmonised standard it relies on, and the declaration has to follow. And it is translated into the language the market requires, which puts it on the same language footing as the instructions.

One machine, several Union acts

Machines rarely fall under the Machinery Regulation alone. EMC, low voltage, outdoor noise, pressure equipment and others commonly apply at once, and the text says you draw up a single declaration covering all of them rather than a stack of separate ones. It has to identify each act, including its publication reference.

Where it has to be, and for how long

The declaration may be digital on the same terms as the instructions: accompany the machine, or give an address or machine readable code where it can be found. Once digital it carries its own availability clock - the expected lifetime of the machine and in any event at least ten years from placing on the market or putting into service.

Note that this is a different duty from the one that keeps a copy at the disposal of market surveillance authorities. That one is Article 10(3) and can be a locked cabinet; this one is public and online. The guides on the ten year availability requirement and on the technical documentation separate the three clocks that get confused with each other.

What this guide does not cover

The model structure itself is in Annex V Part A and the module specific elements are in Annexes VI, VIII, IX and X. Which conformity assessment module applies to your machine is an Article 25 and Annex I question, and whether a notified body has to be involved is the first thing to establish about any machine. None of that is in scope here, and we are not the right source for it.