Who Issues the DoP for Steel Panel Radiators — the Manufacturer, the Importer, or the Distributor?

Ask who has to issue the Declaration of Performance for a shipment of steel panel radiators and the short answer is: the manufacturer. Under the EU Construction Products Regulation (CPR 305/2011), the DoP is the manufacturer's own declaration of the product's performance against the harmonized standard EN 442, and drawing it up is the manufacturer's job — not the importer's, and not the distributor's. But there is one exception every radiator buyer should know before putting their own logo on a panel: place the product on the market under your own name or trademark, and the regulation treats you as the manufacturer, with the same responsibility for the declaration. This article walks through what each role in the chain must do, where the private-label trap lies, and how to settle DoP ownership in the contract before production starts.

A DoP assigns responsibility — that is the point A Declaration of Performance is often misread as a certificate that some authority 'awards' and that can therefore be transferred, renewed, or handed down the supply chain like a license. It is none of those things. The DoP is a self-declaration: the manufacturer states the product's declared performance — heat output at ΔT50, maximum operating pressure and temperature, reaction to fire — and by signing it takes legal responsibility for every figure. The values behind it must come from laboratory type testing to EN 442-2, but the declaration itself is drawn up and owned by the manufacturer. That is the single most useful thing to understand: 'who issues the DoP' is really 'who is legally standing behind the performance claim.' For what the document contains field by field, see [how to read a DoP](/en/blog/reading-declaration-of-performance-steel-panel-radiators).

Manufacturer, importer, distributor: what each must do The CPR splits the duties cleanly. The manufacturer draws up the DoP, keeps the technical documentation and the test basis on file, and ensures that production continues to match what was declared. The importer does not issue anything, but must verify that a DoP exists for the radiators it brings into the market, keep a copy available, and make sure the required documents and markings accompany the goods. The distributor's duty is due care: check that the DoP is available for what it sells and pass it down the chain, rather than letting product move without its paperwork. In the normal case each role stays in its lane — the manufacturer declares, the importer verifies and retains, the distributor passes it along. For an importer the practical consequence is simple: before the goods ship, you should have the DoP for each model in hand, checked against your order — not a promise that the paperwork will follow.

The private-label exception: when the buyer becomes the 'manufacturer' Here is the part that catches OEM and private-label buyers. Under the CPR, an importer or distributor that places a construction product on the market under its own name or trademark — or modifies it in a way that may affect the declared performance — is treated as the manufacturer for regulatory purposes. The responsibility to hold and stand behind the DoP shifts onto the brand owner, even though a factory elsewhere physically made the radiators. Buyers who assume 'the factory handles all the paperwork' are caught out exactly here: putting your logo on the panel is not a cosmetic decision in compliance terms, it is a decision about who owns the performance declaration. None of this is a reason to avoid private label — it is a reason to plan the documentation deliberately, and that comes down to the contract.

Put DoP ownership in the OEM contract — before production If you are ordering OEM or private-label radiators, treat the DoP as a contract item rather than an afterthought. The agreement should state which models the manufacturer provides a DoP for, whose name appears as manufacturer on the declaration and on the product labeling, and — critically — that the underlying EN 442-2 type-test report remains available to you, because if branding makes you the responsible party you need access to the performance basis you are now standing behind. Agree on how changes to a model will be re-documented, and confirm that the manufacturer named in the test report is the factory you actually contracted — the same checks that belong in [an OEM/ODM brief](/en/blog/oem-odm-custom-radiator-sourcing-china). One regional note: the DoP is an EU-market instrument. Buyers shipping to Russia and Central Asia will run the parallel conversation on [GOST compliance](/en/blog/gost-certification-steel-radiators-russia-central-asia), and a factory that serves both markets should carry both sets of paperwork without hesitation.

JD Radiator (Tianjin Jiuding Yangguang HVAC Co., Ltd.) is a family-run manufacturer since 2002, serving buyers in Europe, Russia, and Central Asia. As the manufacturer, we hold Declarations of Performance for our steel panel radiator models under EN 442, and in OEM cooperation we bring the DoP and its underlying performance basis into the contract so that responsibility for the declaration is clear on both sides from the start. GOST compliance is held for Russian and EAEU-bound orders. To discuss how the DoP should be handled for your order — house brand or your own label — contact lunan@jdradiator.com / kevin@jdradiator.com or call +86-22-69189950; the model range is at /en/products and certification details at /en/credentials.