Declaration review is a consistency check, not merely file collection. Product identity, manufacturer identity, referenced legislation, conformity procedure and supporting evidence should align with what is actually being imported.
Article 19 Requires the Declaration to Accompany the Product
Before market placement, the importer must ensure that the product is accompanied by the EU declaration of conformity referred to in Article 13(20). A missing declaration is therefore a market-access issue.
Match the Declaration to the Product
Check the model, type, version or other identifying information against the product being imported. A declaration for a different variant should not be accepted as evidence for the current product without a clear basis.
Check Manufacturer Identity
The manufacturer named in the declaration should align with the legal manufacturer identified on the product and supporting documentation. This is especially important in private-label and OEM arrangements.
Check CRA and Applicable Union Legislation
The declaration should identify the applicable Union harmonisation legislation and, where relevant, other legislation covered by a single declaration. Market-access teams should watch for outdated declarations that do not reflect the product's current regulatory position.
Check Referenced Standards or Specifications Where Used
Where the manufacturer relies on harmonised standards, common specifications or other referenced technical specifications, ensure the declaration is consistent with the stated conformity route.
Check Notified-Body Information Where Applicable
Where third-party conformity assessment is required and a notified body is involved, the declaration and supporting evidence should align with that involvement. Not every CRA product uses a notified body.
Keep Declaration Review Connected to CE Marking
CE marking and the declaration are related parts of the conformity framework. A market-access check should flag inconsistencies between the mark, product identity, manufacturer and declaration rather than reviewing each item in isolation.
Document the Review
Preserve the declaration version reviewed, product version, date and reviewer. This creates a clear record that the importer completed its pre-market verification.
Official sources
Read the full legal text and Commission material for precise wording, qualifications and updates.