Compliance News

What is a Declaration of Conformity?

An EC declaration of conformity (DofC) is a document through which a product is declared compliant with an EC Directive. It can be used for declaring compliance with more than one EC Directive. There are 21 CE marking Directives in total and each has to be considered for the product in question but typically no more than a two or three EC Directives would apply to any one product.

The DofC is the sole responsibility of the manufacturer or his appointed authorised representative. And it has to be signed by someone who is personally and legally responsible for the product (usually a Technical Director). It forms an essential part of product compliance and it is the most important document you have in your compliance technical file.

The requirements for what go into a DofC vary slightly between the EC Directives.

It is important to realise that the DofC is not about compliance with tests or test standards. It is solely about compliance with the requirements of the EC Directives, sometimes called the "essential requirements". Test standards are typically a route to meeting the requirements of an EC Directive.

If the manufacturer, or his authorised representative, declares compliance with the applicable test standards as listed in the Official Journal then he has a "presumption of conformity" with the requirements of the EC Directive. A "preseumption of conformity" is the best legal position to be in. If the latest standards have not been used as the route to compliance, then the "presumption of conformity" is lost and further technical justification would be required in the technical documentation.

Remember that the Official Journal for each EC Directive changes typically once a year so it is important to keep up to date with those changes to maintain the "presumption of conformity".

What is a Declaration of Conformity?

An EC declaration of conformity (abbreviated to DofC, sometimes DoC) is a document through which a product is declared compliant with an EC Directive. It can be used for declaring compliance with more than one EC Directive. There are 21 CE marking Directives in total and each has to be considered for the product in question but typically no more than a two or three EC Directives would apply to any one product.

The DofC the sole responsibility of the manufacturer or his appointed authorised representative. It forms an essential part of product compliance and it is the most important document you have in your compliance technical file.

The requirements for what go into a DofC vary slightly between the EC Directives.

It is important to realise that the DofC is not about compliance with tests or test standards. It is solely about compliance with the requirements of the EC Directives, sometimes called the "essential requirements". Test standards are typically a route to meeting the requirements of an EC Directive.

If the manufacturer, or his authorised representative, declares compliance with the applicable test standards as listed in the Official Journal then he has a "presumption of conformity" with the requirements of the EC Directive. A "presumption of conformity" is the best legal position to be in. If the latest standards have not been used as the route to compliance, then the "presumption of conformity" is lost and further technical justification would be required in the technical documentation.

Remember that the Official Journal for each EC Directive changes typically once a year so it is important to keep up to date with those changes to maintain the "presumption of conformity".

EC Directives also change and in recent years, for example, 2004/108/EC became the new EMC Directive. Likewise, 2006/95/EC became the new Low Voltage Directive. The two previous Directives (89/336/EC and 73/23/EC) should not be used for products placed on the market today.

Your documentation is an important part of your compliance. It's not just about testing!

If you would like us to check that your DofC then simply email us at DofC@blackwood-labs.co.uk. There is no charge for this service.

Compliance News

19th March 2010 - New EMC and LVD Official Journal published
The latest EMC OJ and LVD OJ.

22nd August 2009 - Was there an error in the EMC & R&TTE OJs?
On 21st August the European Commission announced an additional two years for the date of withdrawal of EN 55022:1998 + A1:2000 + A2:2003. The date in the Official Journal (C 126 of 5 June 2009) is stated as 1st October 2009.

The EC announcement (C197/3 of 21st August 2009) has extended the date of cessation of presumption of conformity with this emissions standard to 1st October 2011. There is no explanation provided for this, however, this is not the correction of an earlier error in the original OJ. It is understood that the PLT manufacturers have lobbied successfully for this delay because they appear to comply with the 1998 version, but fail the 2006 version.

There is no technical difference between the 1998 and 2006 standard with respect to PLT conducted emissions. This has since been confirmed by CISPR/I.

This amendment to the OJ can be found here:

August 2009 amendment to the EMCOJ

20th July 2009 - Now there truly is only one EMC Directive!
The transition period whereby 89/336/EC could still be used for product compliance is now up. As from today 2004/108/EC is the only EMC Directive that exists for compliance of new and existing products that fall within its scope and placed on the market.

If you have any concerns about the 2004/108/EC then call John Davies on 01495 229219.

New EMC and LVD Official Journal published 5th June 2009
The latest EMC OJ and LVD OJ

Blackwood Labs host the ECANB and the R&TTE CA meetings

The European Commission Association of Notified Bodies (ECANB for the EMC Directive, 2004/108/EC) and the Radio & Telcommunications Terminal Equipment Compliance Association (R&TTE CA regarding Directive 1999/5/EC) meetings were held at the Millennium Stadium, Cardiff on 23rd and 24th April 2009.

August 2008 - BERR publish guide on EMC regulations

BERR (formerly the DTi) have published their guide to the UKs EMC regulations, SI 2006 No. 3418. BERR stated "We have published some interim guidance on specific issues of interpretation in the EMC Regulations 2006 to assist manufacturers and suppliers of electronic and electrical equipment to understand the effect of the Regulations."

BERR Guide to the EMC Regulations

Additions include the latest Ammendment 2 to EN 60335-1:2002 and gives a DOCOPOCOSS* of July 2009. Therefore products which conform only to the previous version of the standard (EN 60335:2002 +A1 +A11 +A12) should not be placed on the EU market after this date.

*Date Of Cessation Of Presumption Of Conformity Of the Superseded Standard