CE Declaration of Conformity for Gas Appliances: What It Must Contain

DoC vs Certificate vs Test Report

A common mistake is showing a customer only a test report or the type-examination certificate and calling it “the CE certificate”. The legal document that supports CE marking is the Declaration of Conformity; the certificate and reports are evidence kept in the technical file.

Mandatory Content of the DoC

1. A product identification number (model/type/batch/serial, as appropriate);
2. The name and address of the manufacturer (and, where used, the authorised representative);
3. A statement that the declaration is issued under the manufacturer’s sole responsibility;
4. A clear identification of the product that allows traceability (description, and where appropriate an image);
5. The EU legislation and the harmonised standards or other technical specifications applied, with their references and dates;
6. Where applicable, the name and identification number of the Notified Body, the conformity assessment carried out and the certificate reference;
7. The place and date of issue, the name and function of the signatory, and the signature;
8. Any additional information required by the specific legislation.

Sample DoC (Structural Template)

Language, Delivery and Retention

• The DoC must be translated into the language (or one of the languages) required by the EU country where the product is placed on the market; one signed original plus translations is standard.
• It must be provided with the appliance; a paper copy is not mandatory for every unit — the regulation may allow it to be made available electronically, but it must be accessible and downloadable.
• The manufacturer (and importer, where relevant) keeps the DoC and technical documentation for at least 10 years after the product is placed on the market.
• Importers must verify that the DoC exists and that the manufacturer’s name and address appear on the product.

When You Must Update the DoC

The dates of the standards matter: cite the exact edition applied, because an old or undated reference can be challenged in market surveillance even if the product itself is safe.

Where the DoC Sits in the Full Process

1. Build to the harmonised gas and electrical standards and run the tests on a calibrated bench;
2. Obtain the Notified Body’s EU type-examination certificate (Module B);
3. Set up the chosen production module (C2/D/E/F/H) and complete the follow-up checks;
4. Draw up and sign the DoC citing the legislation, standards, Notified Body and certificate;
5. Affix CE and supply the DoC with the product;
6. Keep the technical file, certificate and DoC for at least 10 years.

What Happens if the DoC Is Missing or Wrong

Market-surveillance authorities and customs check the DoC because it is the single document that proves the product was legally placed on the market. If it is missing, the importer cannot demonstrate conformity and the goods may be stopped at the border, held in customs, or refused entry. If it is present but incorrect — for example it omits the Notified Body number, cites a withdrawn standard, or lists legislation that does not apply — the authority can treat it as no declaration at all, require corrective action, and in serious cases order withdrawal or recall. The risk falls first on the importer and distributor in the EU, who must be able to hand the document to the authority on request, so a buyer that cannot obtain a correct DoC will simply move to a supplier who can provide one. For the manufacturer this is why the declaration is not a formality done at the end: it is the document the whole conformity process exists to support, and every claim on it must be traceable to the type-examination certificate and the test reports in the technical file. Keeping those three layers consistent — test reports, certificate and DoC — is the practical definition of “CE compliant” for a gas appliance.

Common Mistakes

• Calling a test report or type-examination certificate “the CE certificate” instead of providing the DoC;
• Issuing the DoC before Module B and the production module are complete;
• Omitting the Notified Body number and certificate reference (mandatory for GAR appliances);
• Citing standards without dates or using withdrawn editions;
• Signing a generic “this product is CE” letter with no legislation or standards listed;
• Reusing one DoC for different models or gas categories without updating it;
• Not keeping the DoC and technical file for the required 10 years.