Who signs the Declaration (DoC)?

The individual who signs the Declaration of Conformity must be a legal representative or designated officer of the company placing the product on the EU market.

The signer takes direct personal and corporate responsibility for ensuring the product meets all relevant safety laws.

Who signs based on your business model:

• If you are a Private Label Seller: You sign. Because you put your brand name on the item, you are legally the manufacturer. The managing director or compliance officer of your company must sign, using your EU business address.
• If you are an Importer (Sourcing from outside the EU): You sign (or ensure an EU representative has signed). If you are selling the item under the factory’s original brand, the non-EU manufacturer signs their own Declaration. However, as the importer, you must often draw up an additional declaration or ensure your authorized representative signs to accept liability on EU soil.
• If you are an EU-Based Manufacturer: Your executive signs. The owner, CEO, or designated technical director of your manufacturing company signs the document before the product leaves the factory.

Critical mistakes to avoid:

• The “Foreign Supplier” Mistake: Do not allow a non-EU factory manager to sign a declaration that bears your private label brand name. If your company name is on the product box, an executive from your company must sign the paperwork.
• The “Unauthorized Employee” Mistake: Do not let a low-level warehouse manager or customer service agent sign. The person signing must have the legal authority to bind the corporation to regulatory liabilities. If the product causes damage or a fire, the signer can be subpoenaed by market surveillance authorities.