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Who Signs the EU DoC for Your Software Product?

The EU Declaration of Conformity (DoC) is a significant legal document under the Cyber Resilience Act (CRA). It's not just a form to fill out; it carries weight. So, who holds the pen and takes responsibility for your app's or game's DoC?

The Manufacturer's Responsibility​

The primary responsibility for drawing up and signing the EU DoC lies with the manufacturer of the product with digital elements. Article 28, Paragraph 4, clearly states that "By drawing up the EU declaration of conformity, the manufacturer shall assume responsibility for the compliance of the product with digital elements".

This means if you are the company or individual who develops or manufactures the software (or has it designed/developed/manufactured) and markets it under your name or trademark, you are the one who signs.

Role of the Authorised Representative​

A manufacturer can appoint an authorised representative established within the Union via a written mandate. This authorised representative can, if specified in the mandate, perform certain tasks on behalf of the manufacturer.

According to Annex V (point 2), the DoC should list the name and address of the manufacturer or its authorised representative. Point 8 of Annex V also refers to the signature being "for and on behalf of..." which implies the signatory is acting with authority from the manufacturer.

However, the ultimate legal responsibility for the product's conformity typically remains with the manufacturer. The authorised representative acts on the manufacturer's behalf for specified tasks.

The Signature Itself​

Annex V, point 8, specifies the DoC must include:

  • "Signed for and on behalf of:"
  • "Name, function"
  • "Signature"

This means a specific individual, with the authority to represent the manufacturing entity (e.g., CEO, Director, or another duly authorised person), must sign the document.

Key Takeway​

The manufacturer of the software product is responsible for signing the EU Declaration of Conformity, thereby taking legal responsibility for the product's compliance with the CRA. An authorised representative may sign if duly mandated.