Navigating Amazon’s EC Declaration of Conformity Requirements_ A Seller’s Guide (2)
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Ajay C Thomas

Founder of Euverify | EU & UKCA Compliance Expert Ajay is an eCommerce expert with 17+ years of experience as an Amazon, eBay, and Etsy seller and a Shopify specialist. He excels in EU and UK compliance, including GPSR and UKCA, helping businesses expand into European and UK markets. Ajay is the founder of Sweans, a London-based eCommerce agency, and Euverify.com, a SaaS platform streamlining compliance for non-EU sellers.

Navigating Amazon’s EC Declaration of Conformity Requirements: A Seller’s Guide

Sooner or later, most Amazon sellers get the message. A notice appears in Account Health asking for a Declaration of Conformity, test reports and product photos, with a date by which the listing will be removed if nothing arrives.

If you sell CE marked products on Amazon in the EU or the UK, this guide explains what the document is, what a valid one has to contain, why Amazon asks for it, and how to be ready before the request comes.

Real-Life Scenario: When Amazon Comes Knocking

Picture this. Your listings are doing well, stock is moving, reviews are good. Then a notice lands in Account Health:

“We have identified that the following product may be subject to EU product safety requirements. Please provide a Declaration of Conformity, test reports and images of the product showing compliance markings within 7 days, or the listing will be removed.”

Real Life Scenario- When Amazon Comes Knocking

This happens more often than most sellers expect. Amazon runs compliance checks continuously, both on its own initiative and when a customer complaint or a market surveillance authority flags a product. The timeframe is short, usually a few days, and it catches sellers who have never seen a Declaration of Conformity before.

What follows if the documents do not arrive is predictable: the listing is deactivated, sales stop, the account health rating takes a hit, and in repeat cases the account itself is at risk.

EC, EU or UK Declaration of Conformity?

Understanding EC Declaration of Conformity (1)

So, what exactly is this document that Amazon is asking for? An EC Declaration of Conformity is a legal statement confirming that your product meets all the essential requiremenYou will see all three names, and they are not interchangeable.

EC Declaration of Conformity is the old name. It comes from the directives written before 2014. Many sellers and some Amazon notices still use it, which is why it is in the title of this article.

EU Declaration of Conformity (EU DoC) is the current name under EU law. Since the 2014 generation of directives (Low Voltage, EMC, Radio Equipment, Toys and the rest) this is the document that backs up a CE mark. If Amazon.de, Amazon.fr or any other EU marketplace asks for a Declaration of Conformity, this is what they mean.

UK Declaration of Conformity (UK DoC) is the equivalent for Great Britain under the UK’s own regulations, and backs up the UKCA mark. The UK left the EU single market in 2020 and is not part of the EEA, so an EU DoC is not, strictly, the UK document. In practice the UK now recognises CE marking indefinitely for most product categories, so Amazon.co.uk usually accepts an EU DoC for CE marked goods. If you have applied the UKCA mark, or you sell in a category where CE recognition does not apply, you need a UK DoC.

The content of both documents is almost identical. It is the legislation and standards cited that differ.

Why Amazon asks for it

Common Challenges for Amazon Sellers

Amazon has legal duties of its own. Under the EU General Product Safety Regulation (GPSR), in force since 13 December 2024, and the Digital Services Act, marketplaces must check that products have a responsible economic operator in the EU and remove unsafe or undocumented products quickly. Amazon passes those duties down to sellers.

So a compliance request today usually asks for several things together:

  1. The EU (or UK) Declaration of Conformity.
  2. Test reports from an accredited laboratory for the standards cited in the DoC.
  3. Photos of the product, packaging and labels showing the CE or UKCA mark, the manufacturer’s name and address, and the importer’s or responsible person’s details.
  4. The name and contact details of the EU Responsible Person, which Amazon also displays on the listing.

Requests come through the Account Health dashboard and the Manage Your Compliance page rather than by email alone. Deadlines vary. Some notices give a week, some remove the listing straight away and reinstate it once documents are approved. Either way there is rarely time to start from nothing.

If the documents are not provided or are rejected, the listing is deactivated. Repeated failures affect the account health rating and can lead to account suspension.

What a valid Declaration of Conformity contains

Step-by-Step Guide to Creating an EC Declaration of Conformity

The content is set by law, not by Amazon. Each directive has an annex (based on the EU’s Decision 768/2008) that lists what must appear. A DoC missing any of these is likely to be rejected by Amazon and, more importantly, is not legally valid.

  1. Product identification. Product name, type, model or batch number, and enough detail to trace it. Many manufacturers include a photo.
  2. Name and address of the manufacturer. And of the EU authorised representative, if one has been appointed.
  3. Sole responsibility statement. The words “This declaration of conformity is issued under the sole responsibility of the manufacturer” or equivalent.
  4. Object of the declaration. A description of the product clear enough to identify it.
  5. The legislation it conforms to. Every applicable directive or regulation, by number. For a wireless charger, for example: the Radio Equipment Directive 2014/53/EU, RoHS 2011/65/EU, and the Ecodesign rules that apply to it.
  6. The harmonised standards or technical specifications applied. With version and date, for example EN IEC 62368-1:2020+A11:2020. Out of date standards are a frequent reason for rejection.
  7. Notified body details, where relevant. Name, four digit number and certificate reference, if a notified body was involved.
  8. Signature block. Place and date of issue, and the name, function and signature of the person authorised to sign on behalf of the manufacturer.

A few practical points. The DoC must be kept for ten years after the last unit is placed on the market. It must be translated into the language required by each Member State where the product is sold, though Amazon accepts English for its review. Some newer laws, including the Machinery Regulation, the Batteries Regulation and the Packaging and Packaging Waste Regulation, allow the DoC to be provided digitally via a website link or QR code.

Who can sign it

Only the manufacturer, or an authorised representative with a written mandate from the manufacturer, can issue a DoC. An Amazon seller who imports someone else’s product cannot simply write and sign one. If you sell under your own brand and had the product made for you, you are the manufacturer in law and the responsibility is yours.

Manufacturers outside the EU need an EU based authorised representative for CE marked products, and an EU Responsible Person under GPSR for all consumer products. The same applies in the UK with a UK authorised representative. Without one, the paperwork is incomplete regardless of how good the DoC looks.

Common reasons Amazon rejects a Declaration of Conformity

The DoC is generic, covers a whole catalogue, or does not identify the specific model on the listing.

It cites withdrawn standards or the wrong directive for the product type.

The manufacturer’s address on the DoC does not match the one on the product or the test report.

The test reports are for a different model, or from a lab that is not accredited.

The document is unsigned, undated, or signed by the seller rather than the manufacturer.

There is no EU Responsible Person, or the details on the product do not match the ones submitted.

Step by step: putting together a Declaration of Conformity

Work out which rules apply. Check every EU directive or regulation that covers your product. A Bluetooth speaker, for instance, sits under the Radio Equipment Directive, RoHS, WEEE and the Batteries Regulation, with GPSR as the safety net.

Identify the harmonised standards. Use the current lists published in the Official Journal. Standards change; the version you cite has to be the one your product was tested to and still valid. Get the test reports. From an accredited lab, for the specific model, against the standards you cite.

Build the technical file. Design drawings, bill of materials, risk assessment, test reports, labels and instructions. The DoC is the summary; the technical file is the evidence behind it.

Draft the DoC. Use the annex of the main directive as your checklist so nothing is missed.

Sign, date and store it. Keep it with the technical file for ten years and update it whenever the product, the standards or the law change.

How Euverify Simplifies the Process

how euverify simplifies the process

Euverify’s EU Declaration Generator and UKCA Doc Generator take you through each required field, pull in the current directive and standard references, and produce a correctly formatted EU or UK DoC you can download and submit to Amazon. Documents are stored in your account so they can be updated when standards change.

For non-EU and non-UK sellers, Euverify also acts as EU Authorised Representative and GPSR Responsible Person, and as UK Authorised Representative, so the address on your product, your DoC and your Amazon listing all match.

Case Study: Success Story of an Amazon Seller Using Euverify

Here is a typical example, based on the kind of request we see every week. Details have been changed.

A seller of electronic accessories received an Amazon notice for her best selling wireless charger. She had five days to provide a Declaration of Conformity, test reports and product photos. She had none of them in a usable form. The factory had sent a one page “certificate” years earlier that cited a withdrawn standard and did not name her brand or model.

She used the EU Declaration Generator to build a proper EU DoC. The tool prompted her for the applicable legislation (Radio Equipment Directive, RoHS, Ecodesign for external power supplies), the current harmonised standards, and the manufacturer and Responsible Person details. She then requested the matching test reports from the factory’s lab, checked that the model number and address matched across all three documents, and submitted everything through Manage Your Compliance on day three.

The listing stayed live. She now prepares the DoC and technical file before each new product goes up, rather than waiting for a notice.

case-study

Keeping compliance documents in order

Prepare the DoC and technical file before you list a product, not after Amazon asks. Review declarations at least once a year and whenever a standard you cite is revised. Keep everything in one place with a clear naming convention, so that when a request arrives you can respond the same day.

Conclusion

A Declaration of Conformity is the manufacturer’s legal statement that a product meets EU or UK law, and Amazon treats it as the starting point for any compliance check. The document itself is short, but it only holds up if the standards are current, the test reports match and there is a responsible economic operator behind it.

If you are not sure your declarations would pass an Amazon review, Euverify can check them for you.