European industry associations urge alignment of CRA and Machinery Regulation on Declarations of Conformity

• Six European industry associations, including CECE, highlight legal uncertainty regarding the EU Declaration of Conformity (DoC) for products covered by both the Cyber Resilience Act and Machinery Regulation.

• The Cyber Resilience Act requires a physical DoC with the product, whereas the amended Machinery Regulation mandates a digital DoC under Omnibus IV.

• The Machinery Regulation demands a single EU DoC when multiple legal acts apply, creating a conflict with CRA requirements.

• The associations urge the European Commission to align CRA provisions with the Machinery Regulation, allowing manufacturers to provide a single digital DoC accessible via a mark on the machine or packaging without a separate physical DoC.

CECE and five other co-signing European industry associations have published a joint position on challenges for manufacturers of products falling within both the Cyber Resilience Act (CRA) and the Machinery Regulation (MR).

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The paper identifies legal uncertainty concerning the form of the single EU Declaration of Conformity (DoC) required for products subject to more than one Union legal act. The associations interpret the CRA as requiring some form of DoC to physically accompany the product, while the amended Machinery Regulation will require the DoC to be provided in digital format once the relevant Omnibus IV requirements apply. At the same time, the Machinery Regulation requires a single EU Declaration of Conformity where more than one Union legal act applies.

The joint position therefore calls on the European Commission to align the relevant CRA provisions with the Machinery Regulation as amended by Omnibus IV and provide clarification that, for products falling within the scope of both acts, manufacturers can provide a single digital DoC accessed by a mark on the machine, its packaging or an accompanying document, without also being required to provide a simplified DoC.