The declaration and responsibility
The EU declaration of conformity is issued under the manufacturer’s responsibility, including when a notified body participates. Use the applicable legal model, identify the product and manufacturer, cite applicable legislation and specifications, and include the authorised signatory and any required notified-body reference. An authorised representative acts within a written mandate. Language and provision to users are law- and market-specific.
Product-specific example and maintenance
For a Wi-Fi product, determine RED applicability and other relevant laws such as RoHS; do not automatically list RED, LVD and EMC together for the same radio equipment. Keep the declaration linked to the actual hardware, firmware and evidence versions. Update it when changes affect conformity or its contents. Withdrawal of a harmonised standard’s reference does not automatically invalidate every previously issued declaration: assess the applicable dates, transition provisions and continued evidence of conformity. Authority requests must be handled under the relevant law; there is no universal ten-working-day deadline or universal criminal penalty for every declaration error.
Radio equipment and other legislation
For radio equipment within RED, the safety objectives of LVD and the EMC requirements are incorporated through RED Article 3(1); the radio equipment does not automatically require separate LVD and EMC declarations. A separately supplied power supply may have its own assessment. Delegated Regulation 2022/30 activates different scopes for network protection, privacy and fraud protection; not every radio meets all three scope tests.
Scope of CE marking
CE marking is required only for products covered by EU legislation that specifically mandates it. It is the manufacturer’s declaration of conformity, not a general quality approval. A product outside those regimes must not carry CE merely because it is sold in Europe. The assessment route, declaration, marking placement and retention rules depend on the applicable product law.
Standards and their limits
Harmonised standards are generally voluntary. Applying an OJ-cited standard can provide a presumption of conformity only for the requirements it covers and subject to published restrictions. Under RED Article 17, missing or partly applied relevant standards for Article 3(2)/(3) require B+C or H for those requirements. Standards, accredited test laboratories and notified bodies have different roles.
Practical checklist
- Identify the product, intended use, market and applicable legal scope.
- Record the exact legal provisions, dates and applicable standard editions, including restrictions.
- Select the permitted assessment route and document the evidence needed.
- Link risk assessment, tests, product versions and declarations in the technical documentation.
- Assign responsibility for changes, support and responses to authorities.
This checklist supports planning; the applicable legal requirements determine the final assessment.