When Annex VII Applies
ESPR Annex VII sets out the conformity assessment procedure that requires involvement of a notified body. It applies to product categories where the delegated act specifies that Annex VII assessment is required — typically higher-risk products or products where self-declaration under Annex VI is considered insufficient. The delegated act for each product category specifies whether Annex VI or Annex VII applies.
Annex VII is described as "internal production control plus supervised product testing." It combines the manufacturer's own internal production control (as in Annex VI) with independent testing of product samples by a notified body. The notified body does not audit the manufacturer's production process — it tests product samples to verify that they meet the applicable ecodesign requirements.
Annex VII Procedure Steps
| Step | Responsible Party | Output |
|---|---|---|
| 1. Technical documentation | Manufacturer | Technical file per Annex VI Section 1 |
| 2. Product sample submission | Manufacturer | Representative product samples to notified body |
| 3. Product testing | Notified body | Test report against applicable ecodesign requirements |
| 4. Assessment decision | Notified body | Certificate of conformity (if tests pass) |
| 5. EU Declaration of Conformity | Manufacturer | DoC citing notified body ID and certificate number |
| 6. CE marking | Manufacturer | CE marking + notified body ID affixed to product |
| 7. Ongoing production control | Manufacturer | Internal quality control to maintain conformity |
| 8. Surveillance testing | Notified body (periodic) | Periodic re-testing to verify ongoing conformity |
Selecting a Notified Body
Notified bodies are listed in the NANDO (New Approach Notified and Designated Organisations) database at ec.europa.eu/growth/tools-databases/nando/. When selecting a notified body, manufacturers should verify that the notified body is designated for the specific regulation (ESPR) and the specific product category. Not all notified bodies are designated for all regulations or all product categories.
Notified bodies charge fees for their services. Fees vary significantly between notified bodies and depend on the complexity of the product and the scope of testing required. Manufacturers should obtain quotes from multiple notified bodies before selecting one. The notified body's identification number (a four-digit number) must be included in the EU Declaration of Conformity and affixed next to the CE marking on the product.
Ongoing Surveillance
Annex VII requires periodic surveillance testing by the notified body to verify that the manufacturer's production continues to meet the applicable ecodesign requirements. The frequency of surveillance testing is specified in the applicable delegated act. If surveillance testing reveals that a product no longer meets the requirements, the notified body must notify the manufacturer and the relevant market surveillance authority.
Annex VII: EU Declaration of Conformity — Required Content
Annex VII of ESPR specifies the required content of the EU Declaration of Conformity (EU DoC). The EU DoC must contain: (1) the product name, model, type, batch, or serial number; (2) the name and address of the manufacturer and, where applicable, the EU Authorised Representative; (3) a statement that the EU DoC is issued under the sole responsibility of the manufacturer; (4) the object of the declaration — a description of the product sufficient to allow traceability; (5) a reference to the relevant delegated act and any harmonised standards or common specifications applied; (6) where applicable, the name and identification number of the notified body that performed the conformity assessment; (7) additional information where required by the delegated act; (8) the place and date of issue; and (9) the name, function, and signature of the person authorised to sign on behalf of the manufacturer.
EU Declaration of Conformity: Digital vs Paper Format
The ESPR regulation allows the EU Declaration of Conformity to be provided in digital format. Article 19 of ESPR specifies that the EU DoC may be provided as a website address where the declaration can be accessed, provided that the website address is included on the product, its packaging, or an accompanying document. For products with a DPP, the EU DoC URL should be included in the DPP data as a reference. The digital EU DoC must be available throughout the product's lifetime — manufacturers must ensure that the URL remains active and that the document is not modified after the CE marking is affixed. Any modification to the product that affects its conformity with the ESPR requirements requires a new EU DoC to be drawn up.
Authorised Representative and the EU Declaration of Conformity
Non-EU manufacturers that appoint an EU Authorised Representative must include the Authorised Representative's name and address in the EU Declaration of Conformity. The Authorised Representative signs the EU DoC on behalf of the manufacturer and takes legal responsibility for the product's compliance with ESPR requirements in the EU market. The Authorised Representative must hold a copy of the EU DoC and the technical documentation for at least 10 years after the last product is placed on the market. If the Authorised Representative relationship is terminated, the manufacturer must appoint a new Authorised Representative before the previous appointment expires — a gap in Authorised Representative coverage means the product cannot legally be placed on the EU market.
Annex VII Conformity Assessment: When It Applies
ESPR Annex VII describes the conformity assessment procedure for products where the delegated act requires a higher level of assurance than Module A (internal production control). Annex VII is based on Module D1 (Quality Assurance of the Production Process) and requires the manufacturer to operate an approved quality management system for production, final product inspection, and testing. The quality management system must be approved by a notified body, which conducts an initial assessment of the quality management system and periodic surveillance audits. Annex VII is expected to apply to product categories where the ecodesign requirements are complex and difficult to verify through product testing alone — for example, products with recycled content claims that require supply chain verification, or products with carbon footprint claims that require lifecycle assessment verification.
Preparing for Annex VII Assessment
Manufacturers that will be required to use Annex VII conformity assessment should begin preparing by implementing a quality management system that covers the ESPR-relevant aspects of their production process. ISO 9001 certification provides a strong foundation for Annex VII compliance, but manufacturers will need to extend their quality management system to cover ESPR-specific requirements such as supply chain data collection, DPP data accuracy verification, and ecodesign parameter monitoring. Manufacturers should engage with a notified body early to understand the specific requirements for Annex VII assessment in their product category and to plan the assessment timeline.
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Register Your Digital Product Passport →Annex VII Conformity Assessment: Third-Party Verification
ESPR Annex VII describes the third-party conformity assessment procedure, which requires manufacturers to have their products tested and certified by an independent notified body. Third-party conformity assessment provides a higher level of assurance than internal production control (Annex VI) because it involves independent verification of the manufacturer's claims. The relevant delegated act specifies whether Annex VI or Annex VII is required for each product category.
Notified bodies are independent organisations that have been accredited by a national accreditation body (such as UKAS in the UK, DAkkS in Germany, or COFRAC in France) to perform conformity assessment activities. Notified bodies are listed in the NANDO (New Approach Notified and Designated Organisations) database maintained by the European Commission. Manufacturers must use a notified body that is listed in NANDO and that is accredited to perform conformity assessment for the specific product category and ESPR requirements being assessed.
Under the Annex VII procedure, the manufacturer must submit the product and the technical documentation to the notified body. The notified body examines the technical documentation, tests the product against the applicable requirements, and issues a conformity assessment certificate if the product meets all requirements. The manufacturer then draws up the EU declaration of conformity on the basis of the conformity assessment certificate and affixes the CE marking to the product. The conformity assessment certificate must be renewed if the product design is changed in a way that could affect compliance with the requirements.
Frequently Asked Questions
Notified bodies for ESPR conformity assessment are listed in the NANDO database at ec.europa.eu/growth/tools-databases/nando. You can search the database by product category, country, and type of conformity assessment activity. The relevant delegated act will specify which conformity assessment activities are required, which will help you identify the appropriate notified body.
The duration of the Annex VII conformity assessment process varies depending on the complexity of the product and the workload of the notified body. For straightforward products, the process may take 4–8 weeks. For complex products with extensive testing requirements, the process may take 3–6 months. Manufacturers should factor the conformity assessment timeline into their product launch planning.
The cost of Annex VII conformity assessment varies depending on the notified body, the product category, and the scope of testing required. Typical costs range from €5,000 to €50,000 per product model, depending on the complexity of the testing. Manufacturers should obtain quotes from multiple notified bodies before committing to a specific provider.
Yes. If the product design changes in a way that could affect compliance with the ESPR requirements, the conformity assessment certificate must be renewed. Minor changes that do not affect compliance (such as cosmetic changes to the product appearance) may not require renewal, but the manufacturer must assess whether the change affects compliance and document this assessment.
No. For ESPR conformity assessment, manufacturers must use a notified body that is listed in the NANDO database and that is established in an EU member state. Conformity assessment certificates from non-EU bodies (such as UL in the US or SGS in Switzerland) are not accepted for ESPR compliance purposes, unless there is a mutual recognition agreement between the EU and the relevant country.