At a glance
- The module decides how you prove conformity: on the product (sampling or piece by piece) or on your quality system.
- Only module A (category I) runs without a notified body; within your category the choice of route is yours (Art. 14(3)).
- Rule of thumb: one-off → product module (G, B+F); series or an existing ISO 9001/3834 system → system module (D, E, H). And watch hold versus witness points in your planning.
What a module is
A conformity assessment module describes how you demonstrate that your equipment meets the essential safety requirements. Not what to build, but how the evidence is produced and who checks it. Article 14 sets which modules are permitted per category; Annex III describes them one by one.
Article 14(3) gives you the choice within your category, and additionally allows a procedure of a higher category. That freedom is the only real steering instrument you have once the category is fixed.
Who is who: notified body, recognised organisation and user inspectorate
First a misunderstanding out of the way: "NoBo" and "notified body" are the same thing. The real distinction is between three different roles:
| Notified body (NoBo) | Recognised third-party organisation | User inspectorate | |
|---|---|---|---|
| Assesses | the equipment or your quality system, through the modules of Annex III; issues the certificates and stands with its number next to the CE marking | people and working methods: approval of operating procedures and personnel for permanent joints (point 3.1.2 — there the manufacturer chooses between this organisation and the notified body) and of NDT personnel (point 3.1.3 — from category III exclusively this organisation) | the equipment, with modules A2, C2, F and G — but exclusively for the group of companies the inspectorate itself belongs to |
| Never | approve NDT personnel for categories III and IV — only the recognised third-party organisation can (point 3.1.3); for welding procedures and welders (3.1.2) the notified body is a permitted route | the equipment itself: no modules, no equipment certificate, nothing with the CE marking | equipment for third parties; the equipment gets no CE marking and stays within the group |
| Where | Art. 14 and Annex III; notification via Art. 20 | Art. 20; from category III the only route for NDT approval | Art. 16 |
In practice large inspection organisations often hold several roles at once: the same organisation can certify your vessel as a notified body and approve your welders as a recognised organisation. Legally they remain separate recognitions. So check per task whether the organisation is notified for it — in the European Commission's NANDO database, which is moving into the Single Market Compliance Space.
All modules at a glance
| Module | What it comes down to | What the notified body does |
|---|---|---|
| A | internal production control | nothing — no body involved |
| A2 | internal production control with supervised checks at random intervals | visits unannounced, checks the final assessment and takes samples |
| B (design type) | EU-type examination based on the design | examines the technical design documentation, without testing a specimen |
| B (production type) | EU-type examination based on a specimen | examines the design and tests a representative specimen |
| C2 | conformity to type, with supervised checks | checks the final product at random before placing on the market |
| D | conformity to type based on quality assurance of production | approves the quality system and keeps periodic surveillance |
| D1 | quality assurance of production, without prior type examination | assesses the quality system and repeats that periodically |
| E | conformity to type based on quality assurance of final inspection | approves the final inspection and testing system and keeps surveillance |
| E1 | quality assurance of final inspection, without prior type examination | assesses the final inspection and testing system and keeps surveillance |
| F | conformity to type based on product verification | examines and tests every individual item |
| G | unit verification | examines the file and tests the unit itself, piece by piece |
| H | full quality assurance | approves a system covering design through final testing, with periodic reassessment |
| H1 | full quality assurance plus design examination | additionally examines the design itself |
Which module with which category
Note the pattern from category III onwards: there is always a B in front, except with H, G and H1. Module B delivers the EU-type examination certificate the second module then builds on. Without that certificate you cannot run the second module.
How you choose
One-off or series
Building one piece? A module that acts on the item is usually cheaper than one that assesses your whole organisation: G in category IV, B + F in category III. Building the same thing repeatedly? A system module (D, E, H) pays itself back, because the body no longer has to see every piece.
Do you already run a quality system?
If ISO 9001 is in place and, for welding, ISO 3834, the step to module D or H is smaller than it looks: much of the assessment covers things you have already documented. Without such a system, a product module is more realistic.
What it does to your lead time
This is the consideration most often skipped. Under F and G the body itself attends the final assessment and the proof test; those moments are fixed and your fabrication waits for them. Under the quality system modules D, E and H that supervision sits with your own system and the body visits periodically. For a workshop on a tight schedule that difference is bigger than the price difference.
Fill-in templates for the matching technical file — ITP, deliverables list, register sheets, in your own house style — are available from € 395 excl. VAT; see the technical file page.
Frequently asked questions
Is a NoBo the same as a notified body?
Yes. NoBo is simply the abbreviation of Notified Body. Do not confuse the NoBo with the recognised third-party organisation (for NDT personnel from category III the only route; for welding procedures and welders a route alongside the NoBo — Art. 20 and Annex I points 3.1.2 and 3.1.3) or the user inspectorate (Art. 16) — separate roles with separate recognitions, even if one organisation sometimes holds several.
With which module is no notified body needed?
Only with module A, internal production control, reserved for category I. All other modules involve a notified body — on the product, on your quality system, or on every single item.
What is the difference between module B design type and production type?
With the design type the notified body examines the technical design documentation without testing a specimen. With the production type it examines the design and also tests a representative specimen of production. Article 14 prescribes per category which of the two is permitted.
May I use a module of a higher category?
Yes. Article 14(3) allows that explicitly. It is done, for example, when one quality system has to cover an entire scope of supply and you do not want to maintain a different route of proof per category.
Can I switch modules during a project?
Technically yes, in practice rarely without cost. A module that builds on an EU-type examination first needs that certificate; switching to a quality system module requires an assessment that can take months. So choose the module before fabrication starts, not after.
Which modules may you choose?
The free tool gives the category and the modules permitted with it. The full report works out per module what you have to deliver.
Run the free check or see the full report