CEPROCON.COM  •  BLOG ARTICLE  •  WEEK 8

Roles, responsibilities, and how to choose the right one

For manufacturers whose products fall under AVCP systems 1+, 1, 2+, or certain aspects of system 3, the CE marking process cannot be completed alone. At some point, an independent third party — a Notified Body — must become involved.

For many manufacturers, this is the first time they encounter the concept, and it raises a string of practical questions. What exactly is a Notified Body? What do they do? How do you find one? How much does it cost, and how long does it take? Can you choose any Notified Body, or does it need to be in your own country?

This article answers all of these questions, giving you a clear picture of what to expect if your CE marking project requires Notified Body involvement.

What is a Notified Body?

A Notified Body is an organisation that has been designated by an EU member state to carry out specific conformity assessment tasks under the Construction Products Regulation (CPR). “Notified” refers to the fact that the member state has formally notified the European Commission and other member states of this designation.

Notified Bodies are typically testing laboratories, inspection bodies, or certification bodies — often large organisations with accreditation across multiple product areas and multiple EU regulations, not just the CPR. Well-known examples include organisations such as TÜV, Bureau Veritas, SGS, and numerous national testing institutes, though there are many more, including smaller specialist bodies focused on specific product categories.

To become notified, a body must demonstrate to its national authority that it has the technical competence, independence, impartiality, and quality management systems required to carry out conformity assessment reliably. This is not a one-time check — Notified Bodies are subject to ongoing oversight by their national authorities.

NANDO: the official database of Notified Bodies

Every Notified Body is listed in NANDO — the New Approach Notified and Designated Organisations database, maintained by the European Commission. NANDO is the authoritative source for confirming whether a body is genuinely notified, and for what.

For each Notified Body, NANDO shows:

• Its unique four-digit identification number (this is the number that must appear on the CE marking label and DoP alongside the Notified Body’s involvement)
• The member state that designated it
• The specific regulation (in this case, the CPR / Regulation 305/2011) under which it is notified
• The exact scope of its notification — which product areas and which harmonised standards it is authorised to assess

This last point is critical. A Notified Body’s notification is scoped to specific standards and product areas — it is not a general licence to assess any construction product. Before engaging a Notified Body, always verify in NANDO that their scope explicitly covers the harmonised standard relevant to your product.

When is a Notified Body required? (Harmonised standard route)

Whether you need a Notified Body — and what type — depends entirely on the AVCP system that Annex ZA of your applicable harmonised standard assigns to your product’s essential characteristics.

AVCP system	Type of body required	What they do
1+	Notified Product Certification Body	Conducts type testing, certifies the FPC, and carries out ongoing audits plus continuous sampling and testing of the product.
1	Notified Product Certification Body	Conducts type testing and certifies the FPC, with ongoing FPC audits (no continuous product sampling).
2+	Notified Inspection Body	Certifies the FPC system through initial inspection and ongoing surveillance audits. Does not conduct product testing.
3	Notified Testing Laboratory	Conducts type testing only, typically for a specific characteristic such as reaction to fire. No FPC certification role.
4	None required	Manufacturer self-declares all aspects; no Notified Body involvement.

Remember that a single product can have different AVCP systems for different essential characteristics. It is entirely possible to need a Notified Testing Laboratory for one characteristic (system 3) while self-declaring all others (system 4). Check Annex ZA.1 of your harmonised standard carefully — the answer is rarely a single, uniform system across the whole product.

Can you choose any Notified Body in the EU?

Yes — and this is one of the most useful and least understood facts about the system. Under the CPR, manufacturers are free to engage any Notified Body established in any EU member state, provided that body’s notification scope covers the relevant harmonised standard. A certificate issued by a Notified Body in one member state is valid for placing the product on the market across the entire EU.

This means a manufacturer based in, for example, Poland is not restricted to Polish Notified Bodies. They can engage a Notified Body in Germany, Italy, the Netherlands, or any other member state — and many manufacturers do, often based on specialisation, cost, language, lead times, or existing relationships.

Factors that often influence the choice of Notified Body include:

• Specialisation: some Notified Bodies have deep expertise and testing capacity in specific product categories (e.g. fire doors, structural timber, insulation), which can mean faster and more reliable assessments.
• Capacity and lead times: well-known Notified Bodies in popular product categories can have significant backlogs. A less prominent but equally valid Notified Body may offer faster turnaround.
• Cost: fees for testing, certification, and ongoing surveillance vary significantly between Notified Bodies, even for equivalent services.
• Language and communication: working with a Notified Body that communicates fluently in your working language can significantly smooth the process, particularly for complex technical discussions.

Notified Bodies under the EAD / ETA route

Everything covered so far relates to products assessed under a harmonised standard (hEN). But Notified Body involvement is not limited to the hEN route. Products certified via a European Assessment Document (EAD) and European Technical Assessment (ETA) — typically innovative products without an applicable harmonised standard — can also require Notified Body involvement.

In the ETA route, the European Assessment Document itself specifies the applicable AVCP system, in the same way that Annex ZA does for a harmonised standard. Depending on the system assigned, a Notified Body (Product Certification Body, Inspection Body, or Testing Laboratory) may be required to carry out type testing, certify the FPC, or both — following the same logic as the systems described above.

There is one important distinction: in the ETA route, the Technical Assessment Body (TAB) that develops the EAD and issues the ETA is a separate role from the Notified Body that may subsequently be involved in AVCP. The TAB is responsible for the technical assessment underlying the ETA itself; the Notified Body is responsible for assessing and verifying constancy of performance once the ETA exists, exactly as it would under a harmonised standard.

In practice, this means manufacturers pursuing the ETA route should expect to engage with two different types of body — a TAB for the assessment underlying the ETA, and potentially a Notified Body for ongoing AVCP — and should clarify both roles, and their respective scopes, early in the project.

What does the process with a Notified Body actually look like?

While the details vary by AVCP system and Notified Body, the general process typically follows these stages:

1. Initial enquiry and scoping. You contact the Notified Body with details of your product, the relevant harmonised standard, and the essential characteristics requiring assessment. The Notified Body confirms their scope covers your needs and provides a quotation and indicative timeline.
2. Type testing (where applicable). For systems 1+, 1, and 3, the Notified Body conducts or oversees testing of product samples against the relevant essential characteristics using the test methods specified in the harmonised standard.
3. FPC assessment (for systems 1+, 1, and 2+). The Notified Body conducts an initial audit of your Factory Production Control system, typically including a site visit to your manufacturing facility, to confirm it meets the requirements of the harmonised standard.
4. Certificate or test report issuance. Once testing and/or FPC assessment is satisfactorily completed, the Notified Body issues the relevant document — a certificate of constancy of performance (systems 1+/1), a certificate of conformity of the FPC (system 2+), or a test report (system 3).
5. Ongoing surveillance (for systems 1+, 1, and 2+). The Notified Body conducts periodic audits — typically annually — to confirm the FPC continues to operate correctly. For system 1+, this also includes periodic product sampling and testing.

Realistic timelines and costs

Manufacturers are often surprised by how long Notified Body engagement takes — particularly for systems 1+, 1, and 2+. While exact figures vary enormously depending on the product, the Notified Body, and their current workload, some general patterns are worth knowing:

• Type testing can take anywhere from a few weeks to several months, depending on the complexity of the test, sample preparation requirements, and laboratory scheduling.
• FPC assessment, including the initial audit and certificate issuance, often takes one to three months from the point your FPC system is ready for assessment.
• Total project timelines for systems 1+ and 1, from initial enquiry to certificate in hand, commonly range from four to twelve months — longer if testing reveals issues that require product modifications and retesting.
• Ongoing costs are not one-off. Annual surveillance audits, and for system 1+ ongoing product sampling, represent a recurring cost that should be factored into the manufacturer’s budget for as long as the CE mark is used.

The practical implication is straightforward: if your product requires Notified Body involvement, build the timeline into your product launch planning early. Underestimating this stage is one of the most common reasons CE marking projects run over schedule.

Choosing the right Notified Body: a practical checklist

Before engaging a Notified Body, work through the following checks:

• Verify the NANDO listing. Confirm the body is currently notified under the CPR and that its scope explicitly includes the harmonised standard relevant to your product.
• Ask about relevant experience. Has the body worked with similar products before? Ask for examples or references where appropriate.
• Get a clear quotation covering all stages. Ensure the quotation distinguishes between initial testing, initial FPC assessment, certificate issuance, and ongoing annual surveillance — all of which may be quoted separately.
• Ask for a realistic timeline, including current backlog. Notified Bodies vary significantly in their current workload — ask directly about expected lead times for your specific tests.
• Clarify communication and reporting. Understand how you will be kept informed during testing and assessment, and in what language reports and certificates will be issued.

Summary

Notified Bodies provide the independent third-party assessment required under AVCP systems 1+, 1, 2+, and parts of system 3. Whether you need one — and what type — is determined by Annex ZA of your applicable harmonised standard, not by choice.

What is within your control is which Notified Body you engage. You can choose any body notified anywhere in the EU whose scope covers your standard — and that choice can have a meaningful impact on cost, timeline, and the overall experience of your CE marking project. Verify scope through NANDO, plan for realistic timelines, and budget for ongoing surveillance costs from the outset.

Need help selecting and working with a Notified Body?

CEProCon helps manufacturers identify the correct AVCP system, verify Notified Body scope via NANDO, obtain and compare quotations, and manage the testing and certification process from initial enquiry through to certificate issuance and beyond. We also cover Notified Body engagement in detail in our professional training programme.

If your product requires Notified Body involvement, our Notified Body Liaison & AVCP System Selection service covers the full process — from verifying scope in NANDO and comparing quotations, to managing the relationship through to certificate issuance. And if you are still working out which harmonised standard applies to your product, our guide to harmonised standards under the CPR explains what they are and how to find the right one.

contact@ceprocon.com  •  ceprocon.com