Simplified EU Declaration of Conformity: Model Structure

The simplified EU Declaration of Conformity is deliberately short. Following the model structure in Annex VI, it consists of:

1. The manufacturer's identity: the name of the manufacturer drawing up the declaration.

1. Product identification: the product with digital elements, identified by type, model or another reference sufficient to identify it.

1. The conformity statement: a declaration that the identified product with digital elements is in conformity with Regulation (EU) 2024/2847.

1. The internet address of the full declaration: the address at which the complete EU Declaration of Conformity drawn up under Annex V can be obtained.

A typical rendering reads: *"Hereby, [manufacturer] declares that the product with digital elements [type / model] is in conformity with Regulation (EU) 2024/2847. The full text of the EU declaration of conformity is available at the following internet address: [URL]."*

Nothing else is required in the simplified form. The detail - standards applied, conformity assessment procedure, notified body where one was involved, signature and date - lives in the full Annex V declaration behind the link.

The simplified declaration exists because supplying the full declaration with every unit is impractical for many products. Common cases include small-format hardware with no room for a printed document, embedded modules sold in volume to integrators, and software distributed by download where a multi-page PDF alongside the installer serves nobody.

Using the simplified form is the manufacturer's choice rather than a concession that must be justified. What matters is that the user receives the short declaration with the product or its documentation, and that the address in it resolves to the full declaration.

The simplified form does not reduce the underlying obligations. The manufacturer must still complete the conformity assessment under Article 32, compile the technical documentation under Article 31 and Annex VII, draw up and sign the full declaration under Article 28 and Annex V, and affix the CE marking under Article 30.

The simplified declaration is only as good as the link it carries. The address must lead to the full declaration, and it has to keep working for as long as users and market surveillance authorities may need it - which, given the retention rule in Article 13(19), means at least ten years after the product was placed on the market, or the support period where that is longer.

Practical consequences worth designing for:

• Use a stable, product-specific URL. A link to a general marketing page forces the reader to hunt for the document, and a site restructure breaks it.
• Do not put the declaration behind a login. Gating it defeats the point, since the address exists so that anyone holding the product can reach the declaration.
• Keep superseded declarations available. A product on the market for a decade may have several declaration versions, and an authority examining a historic unit needs the version that covered it.
• Print the address so it survives the packaging. A URL that only appears on a discarded box is not available to the user who owns the device.

Annex V and Annex VI describe the same declaration in two forms. Annex V is the full model structure: product identification, the manufacturer or authorised representative, the statement of sole responsibility, the object of the declaration, the conformity statement, the standards and specifications applied, the notified body details where a third-party route was used, and the signature block. Annex VI is the short public-facing form that points to it.

One consequence is that the simplified declaration cannot be drafted first. The full declaration has to exist, because the simplified form asserts a conformity that only the full declaration and the technical file behind it can support.

Where a product falls under several Union acts requiring a declaration, a single declaration may be drawn up covering all of them, identifying each act concerned. The simplified form can then point at that combined document.

Four failure modes account for most problems seen in practice:

Treating it as the only declaration. The simplified form is a pointer. A manufacturer that has drafted only the short statement has no declaration of conformity at all, since there is nothing at the other end of the link.

A dead or redirected link. Site migrations quietly break declaration URLs. The link belongs in whatever change-control process protects other regulated artefacts.

Vague product identification. "Our smart sensor range" does not identify the product. The type or model reference must let a reader determine whether the unit in their hand is covered.

Omitting the regulation. The statement must reference Regulation (EU) 2024/2847. A generic assertion of CE conformity does not tell the reader which legislation is being declared against, particularly where the product also carries other CE obligations.