Solemn declaration of research purpose: what it is, when it is asked for and what it does not cover
The solemn declaration under Article 8 of Law 1599/1986 records, under criminal liability, what the recipient of a research material knows and states. It is not a licence, it does not change the status of a substance, and it replaces no control.
A solemn declaration (υπεύθυνη δήλωση) is a written statement under Article 8 of Law 1599/1986 by which a person attests facts or particulars within their knowledge, with criminal liability if they knowingly state something false (Article 22(6) of the same law) [1]. In a purchase of research material, the supplier or the institution may ask the recipient to declare who they are, which laboratory they are receiving for, and that the material will be used exclusively for laboratory research. The declaration records who declared what, and when. It is not a licence, it does not change the legal status of a substance, and it does not make lawful a supply the law does not permit.
That distinction is the whole subject. A solemn declaration adds responsibility to the person who signs it and a document to the file of the person who receives it. It removes no obligation from anyone. Anyone who sees it as a way to be relieved of a check, whether as supplier or as buyer, has understood it backwards.

What a solemn declaration is in Greek law
The instrument is governed by Article 8 of Law 1599/1986 on relations between the state and the citizen [1]. It is used for facts that are not proven by any other document: what the declarant knows, has done, or will personally do. Its weight does not come from any approval attached to it, because none is attached. It comes from the criminal sanction in Article 22(6) for anyone who knowingly declares false facts or conceals true ones [1].
That also sets its limits. A declaration can attest only what is within the declarant's knowledge and control. A researcher can declare which project they are receiving a material for and how their own laboratory will handle it. They cannot meaningfully declare anything about people or acts they do not control.
Why it is asked for when buying research materials
Many reagents are supplied under the designation "research use only". That designation describes the purpose for which the supplier makes the material available; what the "research use only" designation means is explained elsewhere. The solemn declaration is how the supplier records that the customer knows that purpose and states that they will keep to it. It is part of the supplier's due diligence, not a substitute for it.
- On first dealing with a new laboratory or institution, together with the invoicing and delivery details.
- When the delivery address does not obviously match a laboratory facility and the supplier needs an explanation.
- When the supplier's internal policy requires it for certain categories of material.
- When the buyer's own institution asks for it for the procurement file.
What is declared
The declaration is short and specific. Every sentence should be a fact the declarant knows or a commitment to their own action. A reasonable content:
- The declarant's identity and capacity, such as principal investigator or laboratory head, with the institution or company.
- The order or quote number, so the declaration concerns a specific purchase and not every future one.
- That the material will be used exclusively for laboratory research in the named laboratory and not for administration to humans.
- That handling will be carried out by trained staff, in line with the safety documents accompanying the material [5].
- That the material will not be resold or passed to third parties outside the laboratory.
- Place, date and signature, on paper or digital.
Where the declarant signs on behalf of a legal entity, they must have authority to bind it. Otherwise the declaration binds only them personally, and that is something its recipient needs to know.
What it does not cover
| The declaration is | The declaration is not |
|---|---|
| A written record of the purpose the recipient states | A licence, approval or exemption from any rule |
| Acceptance of personal responsibility for what is declared | Proof that supplying or using a material is lawful |
| A document in both parties' procurement files | A way to change how a substance is classified, e.g. from medicine to reagent |
| A supplement to the supplier's due diligence | A substitute for the approvals the research project itself needs |
The supplier's obligations remain intact. For example, the REACH rules on passing safety information to the recipient apply regardless of anything the customer declares [5]. And a substance that legislation classifies as a medicine does not become something else because the buyer declares a research purpose.
The declarant's liability
The declarant is responsible for what they write. Anyone who knowingly declares false facts or conceals true ones in a solemn declaration is subject to the criminal sanctions of Article 22(6) of Law 1599/1986 [1]. In practice, three rules protect the researcher who signs:
- Declare only what you know and control; remove from the text any sentence about the acts of others.
- If circumstances change, for example the project ends or the material moves to another laboratory, tell the supplier in writing.
- Do not sign open-ended declarations "for all future orders" without a time limit; tie each declaration to a specific purchase.
How a supplier checks a declaration it receives
A declaration that is not checked is just one more piece of paper in the file. The supplier who asks for it also takes on the duty of reading it, and of reading it together with the rest of the order:
- The verification code of an electronic declaration is checked on gov.gr before dispatch, not after [3].
- The declarant's name and capacity match the details on the order and the invoice.
- The laboratory and address named in the declaration are the same as those for the shipment.
- The quantities and items ordered are reasonable for the laboratory described.
- Where something does not match, the discrepancy is recorded and clarified in writing before dispatch; if it is not clarified, the order is not fulfilled.
That check is the reason the declaration exists. Without it, the document records only that someone signed something, and says nothing about whether the supplier did what it was obliged to do.
Issuing it electronically on gov.gr
A solemn declaration can be issued electronically through the gov.gr Digital Documents service [3]. Sign-in is with TAXISnet or e-banking credentials, and issue is confirmed with a one-time code sent by SMS to the mobile number registered in the National Communication Registry or with a bank [2]. According to the National Register of Administrative Procedures, the electronic declaration has the same force, electronically or printed, as a document bearing a certified genuine signature, and gov.gr digital documents carry a unique verification number and an advanced electronic seal under Law 4727/2020 [2] [4].
For the recipient this means verification needs no phone call. The document's code is checked in gov.gr's validity-check service, and the result of the check is filed with the declaration [3]. The text of the declaration is free-form, so it is worth the supplier providing ready wording for the recipient to copy, rather than asking for "a solemn declaration" with no content.
Filing on both sides
- The supplier links the declaration to the order number, invoice and delivery note, and keeps the result of the validity check [3].
- The laboratory keeps a copy in the procurement file, together with the award decision where there is one and the batch documents.
- Both sides keep the declaration for as long as they keep the other documents of the same transaction, not less.
- Each new purchase has its own declaration; an old declaration does not cover a new order with different contents.
References
- Νόμος 1599/1986 «Σχέσεις κράτους – πολίτη, καθιέρωση νέου τύπου δελτίου ταυτότητας και άλλες διατάξεις» (ΦΕΚ Α΄ 75/11.6.1986)Ανεξάρτητη Αρχή Δημοσίων Εσόδων (ΑΑΔΕ) — Ηλεκτρονική Βιβλιοθήκη, 1986
- Υπεύθυνη δήλωση και ηλεκτρονική υπεύθυνη δήλωσηΕθνικό Μητρώο Διοικητικών Διαδικασιών (ΜΙΤΟΣ), Υπουργείο Ψηφιακής Διακυβέρνησης
- Ψηφιακά Έγγραφα gov.gr — υπεύθυνη δήλωση, εξουσιοδότηση και έλεγχος εγκυρότηταςΕλληνική Δημοκρατία — gov.gr
- Νόμος 4727/2020 «Ψηφιακή Διακυβέρνηση (Ενσωμάτωση στην Ελληνική Νομοθεσία της Οδηγίας (ΕΕ) 2016/2102 και της Οδηγίας (ΕΕ) 2019/1024) – Ηλεκτρονικές Επικοινωνίες και άλλες διατάξεις» (ΦΕΚ Α΄ 184/23.9.2020)Ελληνική Δημοκρατία, Εφημερίς της Κυβερνήσεως (κωδικοποιημένο κείμενο, Kodiko.gr), 2020
- Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)Official Journal of the European Union (EUR-Lex), 2006
