Key takeaways
- 1No third party. The Low Voltage Directive 2014/35/EU uses internal production control and states that none of its procedures requires a notified body.
- 2Always a third party. Every procedure in Article 16(1) of the Lifts Directive 2014/33/EU involves a notified body.
- 3A choice. Where third-party involvement is mandatory, the EU framework asks legislators to consider the manufacturer's need to choose between quality assurance and product certification modules.
Two sources decide this. The product's EU legislation decides whether a notified body is needed. The buyer decides whether a management system certificate is needed. One answer does not settle the other.
1. Does EU harmonisation legislation cover the product?
The CE marking may be affixed only to products for which specific EU harmonisation legislation provides for it. Some acts use another mark, such as the wheel mark for marine equipment. If no harmonisation act applies, there is no notified body route, although other EU rules may still apply.
If one does, get its name and number. Your EU importer must check the conformity assessment procedure before placing the product on the market, so ask them.
2. Which conformity assessment procedure does that act set?
The act itself says, and acts differ:
- No third party. The Low Voltage Directive 2014/35/EU uses internal production control and states that none of its procedures requires a notified body.
- Always a third party. Every procedure in Article 16(1) of the Lifts Directive 2014/33/EU involves a notified body.
- A choice. Where third-party involvement is mandatory, the EU framework asks legislators to consider the manufacturer's need to choose between quality assurance and product certification modules.
3. Is the notified body notified for this act and this task?
The European Commission's NANDO database lists each notified body with its identification number and the tasks it was notified for. Check the body against the act and task, not only its name. Where it is involved in the production control phase, its number follows the CE marking.
4. Is the buyer asking for something in addition?
A buyer may also ask for ISO 9001, ISO 14001 or ISO 22000 certification from an accredited body. That purchasing requirement is met by a management system certificate, checked by its number, scope and register status. It sits beside the regulatory route, never in its place.
5. Is any document being asked to do both jobs?
- A management system certificate offered as evidence of CE conformity. Under ISO/IEC 17021-1 §8.3.4 f), the certification body must require its clients not to imply that it certifies a product.
- A management system certification mark on the product or its packaging. ISO/IEC 17021-1 §8.3.1 rules this out.
- A notified body's quality system approval described as an ISO 9001 certificate, or the reverse. Under Modules D, E and H, the approval comes from a notified body, against the legislation.
Putting the answers together
If question 1 is no, there is no notified body to find and question 4 is what remains. If it is yes, questions 2 and 3 tell you whether a notified body is involved and which one qualifies. Question 4 runs in parallel. Anything still unplaced goes back to whoever set it, with a request to name the act or standard.
CAS — An EGAC accredited MS certification body No. 012418. Accredited scope: ISO 9001, ISO 14001, ISO 45001, ISO 22000, ISO 50001 and ISO 22301. Certificates accredited for ISO 9001, 14001, 45001, 22000 and 50001 fall within EGAC's IAF MLA scope; ISO 22301 is accredited by EGAC and sits outside that scope.
Verify any certificate: cas.com.eg/certsearch
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