If the technical documentation is not correct, the product is formally non-compliant. The Ecodesign Directive does not specifically address charges to manufacturers for testing costs, but does require Member States to lay down penalties for infringement of national provisions adopted pursuant to the Directive.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.