Declarations of conformity
What is a Declaration of Conformity?
A Declaration of Conformity (DoC) is a mandatory legal document under EU product legislation. In it, the manufacturer, importer, or authorised representative declares — under their sole responsibility — that a battery product meets all applicable EU legal requirements, including EU Battery Regulation 2023/1542.
The DoC is not optional. Any battery placed on the EU market must be accompanied by a Declaration of Conformity. It is one of the core conformity assessment outputs required before a product can bear CE marking, and it must be made available to market surveillance authorities on request.
The legal basis for the DoC requirement for batteries is Article 18 (and Annex IX) of EU Regulation 2023/1542.
Traceable does not yet provide an in-platform form for drafting, completing, and signing a Declaration of Conformity. In-platform DoC issuance — including digital signing via a Qualified Trust Service Provider (QTSP) under eIDAS 2.0 — is a planned feature and is not yet available in the current platform release.
Until it ships, prepare and sign your Declaration of Conformity outside the platform, then attach the signed PDF to the product as a compliance document (see below).
How to attach a Declaration of Conformity today
Because in-platform issuance is not yet available, operators record a DoC by uploading the externally prepared, signed document:
- Prepare your Declaration of Conformity outside the platform and have it signed by the authorised signatory.
- In the platform, navigate to the product the declaration covers.
- Upload the signed DoC PDF as a compliance document, selecting the Declaration of Conformity category (see Documents).
The uploaded DoC is stored as a document linked to the product and is available for download at any time. You can also review all DoCs across your products from Compliance → Documents using the Category filter set to Declaration of Conformity.
Required elements
EU Battery Regulation Annex IX specifies the mandatory content of a Declaration of Conformity. Whichever tool you use to prepare the document, it must include:
| Field | Description |
|---|---|
| Manufacturer name | Full legal name of the manufacturer |
| Manufacturer address | Registered address of the manufacturer |
| Importer name and address | Required if the manufacturer is outside the EU |
| Authorised representative | If signing authority is delegated |
| Product description | Battery name, model number, and category (EV, LMT, Industrial, SLI, Portable) |
| Battery chemistry | Cell chemistry (e.g. NMC, LFP, NCA, Lead-acid) |
| Applicable legislation | List of EU legislation this declaration covers — must include EU 2023/1542; include additional applicable directives (e.g. Low Voltage Directive 2014/35/EU, EMC Directive 2014/30/EU) as relevant |
| Standards applied | Harmonised standards used to demonstrate conformity (e.g. IEC 62619, IEC 62133) |
| Notified body | If conformity assessment involved a notified body, include name, address, and identification number |
| Statement of conformity | Declaration statement confirming the product meets the requirements of the cited legislation |
| Place of issue | City and country where the declaration is issued |
| Date of issue | Date the declaration is signed and issued |
| Signatory name | Full name of the authorised signatory |
| Signatory role | Job title or role of the signatory (e.g. Quality Director, CEO) |
| Signature | Signature of the authorised signatory |
When to issue a new declaration
A Declaration of Conformity is valid for a specific product configuration at a specific point in time. If any of the following change, a new declaration must be prepared and attached:
- Product model designation or description
- Battery chemistry or cell specification
- Applicable legislation (e.g. a new directive comes into force)
- Manufacturing site
- Conformity assessment outcome or notified body involvement
- Any change that affects the basis on which conformity was originally declared
Retain previous declarations as historical records rather than overwriting an issued one, so the applicable declaration for each product configuration remains traceable.
Retention
EU Battery Regulation Article 18(9) requires the Declaration of Conformity to be kept for 10 years from the date of placing the last batch of the product on the market.
To ensure DoCs are protected from automatic deletion:
- Navigate to Settings → Data Retention.
- Confirm that the retention policy for the Declaration of Conformity document category is set to at least 10 years.
- Alternatively, mark individual DoCs as Protected from the document detail view — protected documents are excluded from all automated retention and deletion processes regardless of policy settings.
Traceable will warn you before any deletion action that would affect a DoC document type.