DoC, DoI and Equivalent models
EU Declaration of Conformity (DoC)
If you intend to place products on the EU market, you must prepare and sign a Declaration of Conformity (DoC).
The DoC is specific to each product and confirms that the product complies with all applicable EU legislation. Thus, there is no specific separate declaration of conformity for ecodesign, but you have to add conformity information regarding ecodesign legislation to your general declaration covering all relevant EU legislation. As the energy labelling legislation does not cover minimum requirements, it is not part of the DoC.
Below you find a short summarising information, on what the DoC typically contains.
The DoC must contain:
- A header “Declaration of Conformity“.
- Name and postal address of the supplier (you can add a website address).
- The description of the product model that allows traceability (at least brand and model name, you can refer to a batch or serial number and may add photos).
- The declaration must include the following explicit statements:
- “This declaration of conformity is issued under the sole responsibility of [name and address of supplier]“ .
- “The object of the declaration described above conforms with the relevant Union harmonisation legislation:“ followed by a list of EU Legislation relevant to this specific product. This might e.g. include:
- Ecodesign Directive 2009/125/EC:
- Product-specific implementing regulation number .
- Ecodesign Directive 2009/125/EC:
- Enumerate other legislation, e.g.:
- 2014/35/EU: LVD (Low Voltage Directive).
- 2014/30/EU: EMC Directive (Electromagnetic Compatibility).
- 2011/65/EU: RoHS Directive.
- 2014/53/EU: Radio Equipment Directive.
- For each applicable regulation, the applied harmonised European standards have to be listed.
- Name and reference to relevant certificates of the notified body, if it was involved in the conformity assessment,
- City and date of signature of the DoC: The date of signature must not be before the completion of the compliance assessment by the manufacturer and not after the date of placing on the market.
- Name and signature of the person empowered to bind the supplier.
If the product is changed and still applies to the ecodesign requirements (or any of the other applicable regulations), a new DoC must be issued.
The DoC must be issued in all languages relevant to the EU countries, where the product is placed on the market. It can be multilingual within one document.
For imported products, the importer must ensure that the product is accompanied by the DoC.
The DoC must be made available to the MSA upon their request. If a product is under the scope of e.g. the directives relating to machinery, potentially explosive atmospheres, radio and terminal telecommunication equipment, each product must be accompanied by the DoC. The DoC can be uploaded to the EPREL compliance part voluntarily.
The supplier/importer must keep a copy for 10 years after the product has been placed on the market.
EU Declaration of Identity (DoI)
The Declaration of Identity (DoI) is used to prove that product models from the same or different manufacturers are equivalent and may share the same technical documentation.
This means that the product models have the same declared values for all parameters to be declared for ecodesign and energy labelling.
The use of DoI allows to reduce the amount of technical documentation (test reports, components list, etc.) that has to be prepared and provided to the MSA.
A DoI is typically used to link:
- Identical products with different model or brand names owned by the same company.
- Model variants or types, regardless of whether they belong to the same or different brand or manufacturer, where technical differences according to the technical documentation do not affect the compliance assessment.
- Various models, regardless of whether they belong to the same or different brand or manufacturer, which is covered by the same technical documentation supplemented with additional tests, calculations, or other technical evidence.
A DoI is mandatory in these cases:
- If a DoI creates a link between two models from two different manufacturers allowing them to declare that the two models are technically identical.
- When a DoI creates a link between two models from different manufacturers, where the technical information regarding one of the models is obtained by calculations based on the information from the other model.
Treatment of equivalent models
“Equivalent model” means a model which has the same technical characteristics relevant for the energy label and the same product information sheet as another model, but is placed on the market or put into service by the same supplier with a different model identifier.
- If products are equivalent, they should have the same model identifier, a single registration in EPREL, and the same energy label. Examples of equivalent models are models with different colour designs or similar design aspects, aesthetical aspects, different packaging configurations, and technically identical products sold by the same supplier under different brands.
- Equivalent models, if already placed on the EU market, including model identifiers, shall be indicated in the:
- Technical documentation.
- EPREL database (section for model compliance, see also in specific information on EPREL):
The EPREL database will generate the same energy label and PIS for all equivalent models.
- In case of market surveillance requires corrective actions for a product model, these shall also be applied to all equivalent models, except for models where the supplier can prove compliance.
- If in market surveillance product testing the first sample of a product model does not pass the test (there are exceptions to this rule for a few product groups) and subsequently additional (three) models have to be checked, they may be taken from equivalent models.