Over the course of five years, Standards and Quality has reviewed hundreds of declarations completed independently by manufacturers. Most of them contained at least one of the errors described below. Each such error poses the risk of receiving a prescription from the State Service for Food Safety and Consumer Protection, losing a batch of goods at customs, or facing claims from retail chains.
1. Incorrect UKTSED code
The Ukrainian Classification of Goods for Foreign Economic Activity code determines which technical regulations apply to a product and which conformity assessment procedure is used. Even a single digit error can result in the declaration referring to the wrong regulations or becoming invalid altogether.
How to avoid this: check the code against the current version of the UKTSED on the State Customs Service website. If the product is new or complex in composition, consult a customs broker for a classification decision before completing the declaration.
2. Reference to a canceled or obsolete standard
National standards are regularly updated. The DSTU that was in effect at the time of the first release of the product may have been replaced or canceled. If the declaration refers to an invalid standard, it loses its legal force, even if the product itself meets all safety requirements.
How to avoid it: Before preparing your declaration, check the status of each standard through the UkrNDNC fund. Pay attention to the date of entry into force of the replacement standard — sometimes the transition period allows you to use the previous version.
3. Discrepancy between the declaration and the technical specifications
The declaration must clearly correspond to the products described in the technical specifications. If the technical specifications specify one composition or characteristics, and the declaration specifies others, this is a direct basis for declaring the document invalid. The problem becomes more acute when a company changes its recipe or technology but forgets to update the technical specifications. As a result, the declaration refers to technical specifications that no longer describe the actual product.
How to avoid this: whenever there is a change in composition, design, or production technology, first update the technical specifications and then reissue the declaration. The development of technical specifications must precede the declaration procedure, not the other way around.
4. Errors in product identification
The product name in the declaration must exactly match the name on the label, in the technical specifications, and in the test reports. This would seem to be an obvious requirement, but in practice, discrepancies occur all the time: abbreviations instead of full names, trademarks instead of names, and missing models or sizes. During product certification, this correspondence is monitored by the assessment body, but during declaration, no one except the manufacturer itself monitors it.
How to avoid this: Use the same wording for product names in all documents. Create an internal register of names and ensure that each new document complies with this register.
5. Absence or incompleteness of data on the manufacturer
The declaration must contain the full name of the manufacturer, its legal and actual address, and its EDRPOU code. For imported products, the details of the authorized representative in Ukraine must also be indicated. An omitted field or incorrect address is a formal violation that the inspector will record in the inspection report.
How to avoid this: check the details against the current extract from the Unified State Register. After any change in the legal address or name of the company, reissue all current declarations.
6. Reference to incorrect technical regulations
There are several dozen technical regulations in force in Ukraine, and some product categories fall under two or three of them at once. For example, an electric heater may fall under regulations for low-voltage equipment and electromagnetic compatibility at the same time. If only one of them is specified in the declaration, the document is incomplete.
This error is particularly critical for manufacturers who plan to certify their products for entry into new markets or expansion of their product range: an incomplete declaration may block deliveries to retail chains.
How to avoid it: Identify all technical regulations that apply to your products. If you are unsure, contact conformity assessment experts for a preliminary analysis.
7. Absence of signature or seal of the responsible person
The declaration is signed by the head of the enterprise or an authorized person. Without a signature, the document has no legal force. Although a seal is not formally required for all types of entities, it significantly increases the credibility of the document among regulatory authorities and trading partners.
How to avoid it: Develop an internal procedure for signing declarations. Identify the persons authorized to sign such documents and ensure that there is a valid order to that effect. Implementing an ISO 9001 quality management system helps formalize such processes and minimize the human factor.
8. Ignoring industry reporting requirements
Different product categories have their own declaration requirements. For food products, it is important to take into account safety and labeling requirements, which differ significantly from those for industrial products. Food product certification involves additional requirements for traceability, allergens, shelf life, and storage conditions. If these parameters are not included in the declaration, it is considered incomplete.
The situation is similar in the construction industry. Certification of construction products is regulated by separate technical regulations for construction products, which require a declaration of performance specifying specific indicators of strength, fire resistance, and durability.
How to avoid this: study the industry technical regulations before you start the registration process. If the product is new to you, consult with specialists in the relevant field.
9. The declaration is not updated after changes in production.
Changing raw material suppliers, relocating production to another site, modernizing equipment—all of these factors can affect the characteristics of the finished product. If the declaration remains unchanged after such changes, it effectively describes a product that no longer exists.
How to avoid it: Introduce internal regulations for reviewing declarations. Every significant change in the production process should trigger a review of existing declarations of conformity and, if necessary, retesting. The development of documentation in accordance with ISO 9001 specifically provides for change management as a mandatory element of the quality system.
How to minimize risks when declaring
Most of the errors listed above have one common cause: the manufacturer treats the declaration as a formality that needs to be “taken care of” as quickly as possible. In reality, a declaration of conformity is a legal document with real consequences. An incorrectly completed declaration protects neither the manufacturer nor the consumer.
Standards and Quality recommends a systematic approach to declaration. Start by auditing your existing documentation: are the technical specifications up to date, are the test reports valid, and are the technical regulations correctly defined? If you have doubts about even one point, it is better to consult specialists before the declaration is submitted to the regulatory authorities.
Practice shows that companies that implement systematic documentation control and regularly check declarations against the actual state of production pass inspections without any issues. Those who put off audits “until later” face orders, fines, and delays at customs.
We assist manufacturers at all stages: from determining applicable regulations and product certification to preparing a complete set of documents and providing support during inspections. A systematic approach to documentation quality saves time, money, and the company’s reputation.
