Amazon asked your EU Responsible Person for the DoC: why a lab “CE certificate” is not a DoC, and how to match ASIN, model and test report

2026-11-12 · IberTrust Global

GPSR · EU Responsible Person · marketplace document requests · from our own case files, anonymised

The request reached our Responsible Person mailbox on a Wednesday afternoon. A marketplace compliance team wanted, for each of five ASINs that named us as EU Responsible Person, the EU declaration of conformity and the technical documentation or test reports. Not a sample. All five.

Four were straightforward: signed declarations, matching reports, sent within days. The fifth turned into a small investigation. One seller had a properly signed DoC, but it named a single ASIN, and the seller had several others on sale. A second file looked complete at first glance: a lab-issued “CE certificate”, an EMC test report and a RoHS report. There was no declaration of conformity in it at all. A third had a genuine manufacturer’s DoC, but it named a different company as authorised representative, and the product was a toy. None of them could go back to the platform as they were.

Below is what we check before a DoC is returned to a platform, and where sellers most often get stuck. Names, products and numbers from the case have been removed.

Why the request lands on the Responsible Person

For products covered by EU harmonisation legislation, including the EMC Directive 2014/30/EU and the RoHS Directive 2011/65/EU, Article 4 of Regulation (EU) 2019/1020 requires an economic operator established in the EU to verify that the EU declaration of conformity and the technical documentation have been drawn up, to keep the declaration at the disposal of market surveillance authorities, and to provide documentation following a reasoned request. Article 16 of the General Product Safety Regulation (EU) 2023/988 applies the same tasks to the responsible person for consumer products under that Regulation. When a marketplace asks for the DoC, it is in practice checking that the operator named on the listing can do that job.

It also explains what the Responsible Person cannot do. Under the EMC Directive (Article 15(4)), by drawing up the declaration the manufacturer assumes responsibility for the product’s compliance. Our role is to verify that the declaration exists and matches the product. We do not write or sign a DoC in place of the manufacturer.

A lab “CE certificate” is not a DoC

Test laboratories often issue a one-page “Certificate of Compliance” or “CE certificate” that summarises a test report. It is not the EU declaration of conformity. The lab does not place the product on the market, and its certificate contains no statement that the declaration is issued under the sole responsibility of the manufacturer. The model declaration in Annex III of Decision No 768/2008/EC, and the EMC Directive’s own model in its Annex IV, contain:

a declaration number (optional under the EMC Directive) and the product, type, batch or serial number
the name and address of the manufacturer or its authorised representative
the statement that it is issued under the sole responsibility of the manufacturer
the object of the declaration, identified so that it can be traced
the Union legislation complied with
the harmonised standards or other specifications used, with their dates
the notified body, where one was involved
additional information, and “signed for and on behalf of”, with place and date, name, function and signature

What the platform asks for vs what sellers often send

Requested	Often sent instead	Why it does not work
EU DoC issued by the manufacturer (or the brand selling under its own name)	Lab “CE certificate” or “Certificate of Compliance”	Not issued by the party responsible for the product; no responsibility statement
A DoC that identifies this ASIN	The DoC of a sister product listing another ASIN	Does not identify the product the platform asked about
EU declaration referring to EU legislation	UKCA certificate or UK declaration	Belongs to the Great Britain regime
Test report covering the model sold	Report for a test model whose series naming does not clearly cover the model on the product	The link between product, DoC and evidence breaks
DoC consistent with the Responsible Person on the listing	DoC naming another company as authorised representative	Two different operators for the same product

Step by step: build the DoC around the listing

Start from the listing, not from the file. List every ASIN that names you, per EU marketplace. ASINs on a UK marketplace can differ from those on EU marketplaces; confirm which one is actually on sale in the EU.
Map each ASIN to the model printed on the product, label and manual. The Commission’s Blue Guide states that the identification element on the product shall be the same as on the EU declaration of conformity.
Check the model is inside the report. Reports often test one model and list series models by a naming pattern. Confirm the model you sell fits that pattern. If it does not, ask the lab or manufacturer before anyone signs.
Decide who issues it. Normally the manufacturer. A seller that places the product on the market under its own name or trade mark is treated as the manufacturer under the EMC Directive (Article 11); in that case the seller issues the DoC and we recommend naming the factory as “Produced by”. Where the report applicant, the factory and the seller are three different companies, say how they relate.
List all applicable legislation in one declaration. For example EMC 2014/30/EU and RoHS 2011/65/EU as amended by Delegated Directive (EU) 2015/863. Where several acts require a DoC, a single declaration covers them all. A radio module moves the product under the Radio Equipment Directive 2014/53/EU, which the EMC Directive excludes; a built-in battery means checking the Batteries Regulation (EU) 2023/1542 too.
Copy the standards and their dates from the report.
Name the supporting reports: laboratory, report number and date.
Put the ASIN in the body, next to the model. The legal model does not mention marketplace identifiers, but the platform matches documents to listings by ASIN.
Sign it properly: company, place, actual signing date, name, function, signature and company stamp, as a clear PDF.

Common mistakes

Reusing a signed DoC across ASINs when it names only one.
Sending the lab certificate as the DoC.
A model on the box that the report never mentions, such as a retail model number that is not obviously part of the tested series.
Sending the UKCA set because it sits in the same folder as the CE set.
A DoC naming another representative, often left over from an earlier provider or the UK side of the business.
Forgetting the battery or radio module when listing legislation.
Asking the Responsible Person to “just fill one in”.

Who this does not apply to

Toys. They follow the Toy Safety Directive 2009/48/EC, with its own requirements. Regulation (EU) 2025/2509 will replace it from 1 August 2030, when a digital product passport replaces the declaration. We review toys separately, case by case.
Products where a notified body is involved. The DoC must refer to the notified body and its certificate; that review goes beyond this checklist.
Consumer products not covered by any CE legislation. There is no EU DoC to ask for; under the GPSR the manufacturer draws up technical documentation instead.
The UK market. Separate regime and separate representative.

FAQ

Can one DoC cover several ASINs?

Yes, if they are the same product or models covered by the same evidence. List each ASIN with its model in the declaration. A DoC that names one ASIN does not cover the others.

Can the test laboratory sign the DoC?

No. The declaration is drawn up by the manufacturer, or its authorised representative where the mandate provides for it. The lab’s certificate is supporting evidence only.

The report applicant is a different company from the seller. Is that a problem?

Not necessarily, and it is common. The DoC should name the issuing manufacturer, identify the producing factory where it differs, and list the report, so the link from product to evidence is clear.

Can my EU Responsible Person write the DoC for me?

We do not. The DoC is the manufacturer’s declaration of responsibility. We check it against the listing, the label and the reports, and tell you what is missing.

Can I use our UKCA certificate for the EU?

No. UKCA belongs to the Great Britain regime. The EU needs an EU declaration referring to EU legislation and the CE marking.

Has a marketplace asked for your DoC?

IberTrust Global S.L. acts as EU Responsible Person under the GPSR for sellers established outside the EU. Send us the request and the documents you have, and we will tell you, ASIN by ASIN, what matches and what the manufacturer still has to provide.

Ask for a DoC check →
Or write to contact@ibertrust.info.

Sources: Regulation (EU) 2019/1020, Art. 4; Regulation (EU) 2023/988 (GPSR), Arts. 9 and 16; Decision No 768/2008/EC, Annex III; Directive 2014/30/EU (EMC), Arts. 2, 11, 15 and Annex IV; Directive 2011/65/EU (RoHS); Delegated Directive (EU) 2015/863; Directive 2014/53/EU (RED); European Commission, The ‘Blue Guide’ on the implementation of EU product rules 2022, sections 4.2.2.5 and 4.4; European Commission, Toy safety; UK Government, Placing UKCA or CE marked products on the market in Great Britain; IberTrust Global S.L. case files (November 2026), anonymised. General information, not legal advice.