Some clients have asked us “what is a certificate of conformity” over the years, and we wrote this article to answer that question. We’ll explain what a CoC is, what it’s used for, and what it includes. 

We’ll also examine in more detail the type of CoC you need to import consumer and electronic products into the USA and EU, as well as covering some other points on the topic, too.

Table of Contents

Hit the links to jump to each section:

1. What is a certificate of conformity (CoC)
2. When does a buyer ask the supplier for a CoC?
3. What should a certificate of conformity include?
4. CoC for importing consumer goods in the USA
5. Certification authorization vs. SDoC (Supplier’s Declaration of Conformity) for electronics being imported into the USA
6. CoC for importing products in the EU
7. Certificate of Compliance vs. Certificate of Conformity
8. CoC for importing motor vehicles

1. What Is a certificate of conformity?

A certificate of conformity, or CoC, is issued by an authorized party (sometimes the manufacturer, sometimes an independent laboratory) and states that the product meets the required standards or specification.

The CoC can either be requested by a buyer to ensure the product being manufactured has been tested and passes the set criteria within a specification and meets both technical and safety requirements, or it would be a mandatory requirement as stated by country regulations and law for certain products, such as Bluetooth devices being sold in the USA.

2. When does a buyer ask the supplier for a CoC?

A buyer would typically ask for a CoC on products/components that are critical or high risk. And, in some cases, specific documents are required for certification or to show the end user/customer, that the product is safe.

Let’s take an example. An airline buys fan blades for their planes’ engines. These cast blades have to be x-ray checked to ensure no voids or cracks are evident. A defect can lead to a failure that might result in loss of life. Therefore, a CoC (whereby the blade manufacturer writes that the blades conform to specific checklists) must be provided.

In some cases, it has to be provided for EVERY part with its own serial number. In other cases, batch CoC would be good enough.

What about the cases where a CoC is requested by a country’s Customs?

Certain countries request a CoC for certain categories of imported products.

The CoC is sometimes called Certificate of Conformance or Certificate of Compliance. It is generally inspected during customs clearance if the product being imported requires it. Without a CoC, products may be impounded, confiscated, and in some case destroyed.

The main reason a CoC is required at customs is to prove a product that the product being imported meets the required standard(s).

3. What should a certificate of conformity include?

Elements that should typically be included in a CoC are:

1. Product identification
   • Description of the product covered in the CoC
2. List of all safety regulations the product must pass
   • The CoC must clearly list each of the safety regulations the product must be tested for, refer to related tests reports or certificates
3. Importer or manufacturer’s identification
   • Provide the name, full mailing address, and telephone number of the importer or domestic manufacturer certifying the product
4. Contact information for the individual maintaining records of test results:
   • Provide the name, full mailing address, e-mail address, and telephone number of the person maintaining test records in support of the certification.
5. Date and place where the product was manufactured
   • At last the month and year should be shown and the city, state, and country needs to be shown.
6. Provide the date(s) and place when the product was tested for compliance with the consumer product safety rule(s) cited above:
   • Provide the location(s) of the testing and the date(s) of the test(s) or test report(s) on which certification is being based.
7. Identification of any third-party laboratory on who’s testing the certificate depends:
   • Provide the name, full mailing address, and telephone number of the third-party laboratory.

4. CoC for importing consumer goods into the USA 

On the US CPSC (Consumer Product Safety Commission) website, one can find several samples of CoCs. Here is one example.

In this example, while the mattresses were not required to be tested by a third party laboratory, the mattress manufacturer voluntarily chose to do so and must provide the information about that laboratory. If you do not use a third party laboratory, you may label this section “N/A.” If the mattresses being certified are for cribs or children’s size mattresses, please see the requirements for issuing a CPC.

1. Identification of the product covered by this certificate: Luxe Mattress Models #456, 789 (Queen, King)
2. Citation to each CPSC product safety regulation to which this product is being certified: 16 CFR Part 1632, Standard for the Flammability of Mattresses and Mattress Pads16 CFR Part 1633, Standard for the Flammability (Open Flame) of Mattress SetsIn this example, the two standards for mattress flammability are the only applicable requirements.
3. Identification of the importer or domestic manufacturer certifying compliance of the product: MattressSafety USA Importers
   123 Good Sleep Way
   Springfield, MA 12345
   (549) 456-7890
4. Contact information for the individual maintaining records of test results: Mary Smith, Compliance and Quality Control
   MattressSafety USA Importers
   123 Good Sleep Way
   Springfield, MA 12345
   (549) 456-7890 ext. 99, mary@mattressafety101.net
5. Date and place where this product was manufactured: May 2011, Guangzhou, China
6. Date and place where this product was tested for compliance with the regulation(s) cited above: June 2011
   Guangzhou, China. General use (non-children’s) products must be subjected to actual testing or a reasonable testing program and do not require testing by an accredited, third party laboratory accepted by the CPSC.
7. Identification of an accredited laboratory accepted by the CPSC on whose testing the certificate depends: Guangzhou Quality Labs
   No. 023 Shi Nan Road
   Dong Zhou, Pan Zi
   Guangzhou City
   Guangdong Province, China. 511453
   +(86) 20 09 7723 5467

5. FCC Certification vs. SDoC (Supplier’s Declaration of Conformity) for RF electronics being imported into the USA

Depending on the nature of the electronic device being imported, you will either need to go through a more comprehensive FCC certification or can submit your own ‘Supplier’s Declaration of Conformity.’ Let’s look at the difference between the two: 

FCC Certification

For ‘RF Devices with the greatest potential to cause harmful interference to radio services‘ like smartphones, Bluetooth speakers, earbuds, etc, that emit radiation a self-declaration is not acceptable to comply with FCC regulations and they must be certified by an FCC-recognized Telecommunication Certification Body (TCB) based on an evaluation of the supporting documentation and test data submitted by the responsible party (e.g., the manufacturer or importer) to the TCB. Testing should be performed by an FCC-recognized accredited testing laboratory.’

According to the FCC (47 CFR Section 2.906):

Equipment that consists of only a radio transmitter (not a transceiver) – such as remote control transmitters; land mobile radio transmitters and wireless medical telemetry transmitters – are required to be approved using the certification procedure.

Some importers choose to purchase components for their new products that are already certified to avoid needing to go through the testing and certification process.

SDoC (Supplier’s Declaration of Conformity)

FCC (47 CFR Section 2.906) again states that the SDoC is:

…a procedure that requires the party responsible for compliance ensure that the equipment complies with the appropriate technical standards. The responsible party, who must be located in the United States, is not required to file an equipment authorization application with the Commission or a TCB. Equipment authorized under the SDoC procedure is not listed in a Commission database. However, the responsible party or any other party marketing the equipment must provide a test report and other information demonstrating compliance with the rules upon request by the Commission. The responsible party has the option to use the certification procedure in place of the SDoC procedure.

Importers of some consumer electronic products that intentionally or non-intentionally emit radiation between 9kHz to 3,000 GHz radio frequency range including personal computers, fans, power stations for devices, LED lights, TV remotes, etc, into the USA must issue a Supplier’s Declaration of Conformity (SDoC) which is supported by lab tests that may or may not be performed by an FCC-recognized and accredited lab as long as the testing is correct according to the standards (or may also choose to get the product certified as described above in some cases). 

Equipment that only contains digital circuitry (does not contain a radio transmitter) – such as computer peripherals, microwave ovens consumer ISM equipment, switching power supplies, LED light bulbs, radio receivers and TV interface devices – are subject to approval using the SDoC procedure or may optionally use the certification procedure.

Your SDoC will include:

• Product ID: Unique product ID may include SKU, serial number, batch number, model number, and images.
• Responsible party info: who is responsible for the product being imported into the USA? This varies, but it can be a US-based manufacturer, assembler, importer, or local representative (foreign companies must use a local representative). Company and individual details, contact info, and signature will be provided.
• Compliance statement: this statement will make it clear that the device complies with relevant FCC rules.
• Supporting documents: these documents relate to the compliance statement and show product compliance, an example would be lab test reports.

6. EU declaration of conformity

An EU declaration of conformity (DoC) is a mandatory document that you as a manufacturer or your authorised representative need to sign to declare that your products comply with the EU requirements. By signing the DoC you take full responsibility for your product’s compliance with the applicable EU law.

EU DoC

According to the EU’s own guidance, your EU DoC should contain the following information:

• your name and full business address or that of your authorised representative
• the product’s serial number, model or type identification
• a statement, stating you take full responsibility
• means of identification of product allowing traceability – this can include an image
• the details of the notified body which carried out the conformity assessment procedure (if applicable)
• the relevant legislation with which the product complies, as well as any harmonised standards or other means used to prove compliance
• your name and signature
• the date the declaration was issued
• supplementary information (if applicable – this may include the technical documentation)

For imported products, the importer must ensure that the product is accompanied by the DoC and must keep a copy of it for 10 years after the product has been placed on the market.

You must translate the EU declaration of conformity into the language or languages required by the EU country in which your product is sold.

Technical documentation for EU products

Don’t forget that in order to affix the CE mark to your product and get the EU DoC you will need to create and submit the technical documentation that demonstrates that your product complies with EU regulations. It will include:

• your name and address, or those of any authorised representatives
• a brief description of the product
• identification of the product, for example, the product’s serial number
• the name(s) and address(es) of the facilities involved in the design and manufacture of the product
• the name and address of any notified body involved in assessing the conformity of the product
• a statement of the conformity assessment procedure that has been followed
• the EU declaration of conformity
• label and instructions of use
• a statement of relevant regulations to which the product complies
• identification of technical standards with which compliance is claimed
• list of parts
• test results
• risk assessment

Finding examples on the internet is easy. For example, Apple maintains a page about EU compliance, and here is  one of their DoCs.

Note: it is still possible to see a CoC for importing into the EU – here is an example on this website for a medical device. It is not sufficient to have this paper, of course.

7. Certificate of Compliance vs. Certificate of Conformity

8. Importing motor vehicles

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Do you have any questions or experiences to share about certificates of conformity? Please tell me by leaving a comment.

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Editor’s note: This post was originally published in July 2019 and has since been updated and republished with additional content.

Disclaimer

We are not lawyers. What we wrote above is based only on our understanding of the regulatory requirements. QualityInspection.org does not present this information as a basis for you to make decisions, and we do not accept any liability if you do so.

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