Notified Body for Gas Appliance CE: What It Does and When You Need One

Why Gas Appliances Are Different

Gas appliances carry a combustion and poisoning risk, so the EU does not allow the manufacturer to assess the design entirely on its own. The European Commission states that the GAR always requires third-party involvement in conformity assessment. This is a key difference from, for example, many Low Voltage or EMC products, where the manufacturer can self-declare without a Notified Body. Using harmonised standards (EN 30, EN 26, EN 15502 and EN 437) gives a presumption of conformity and makes the assessment smoother, but it does not remove the Notified Body requirement.

The Two Phases for Series Production

Choosing the Production Module

Manufacturers with a stable, well-documented quality system often choose D or H; smaller or first-time exporters frequently choose C2, which keeps the Notified Body involvement focused on random product checks. The choice affects both cost and how often the Notified Body visits or samples.

What the EU Type-Examination Application Includes

• The manufacturer’s name and address;
• A written declaration that the same application has not been lodged with any other Notified Body;
• The technical documentation: description, design and manufacturing drawings, lists of harmonised standards and other specifications applied, risk assessment, and the results of design calculations and tests;
• A representative sample or access to the type, as the Notified Body requires;
• Test reports for the gas tests (tightness, heat input, combustion/CO, flame-failure, efficiency) and electrical tests (IEC 60335 series).

If the type meets the GAR, the Notified Body issues an EU type-examination certificate; it may also ask for corrective work before issuing, which is why pre-testing on a compliant bench before submission reduces delays.

The Practical Step-by-Step

1. Identify the applicable gas and electrical standards for each destination gas category (EN 30 / EN 26 / EN 15502, EN 437, IEC 60335).
2. Build the technical file and run the gas and electrical tests on a calibrated bench, keeping the reports.
3. Search NANDO for a GAR-designated Notified Body and lodge a single Module B application.
4. Respond to questions, supply the sample and obtain the EU type-examination certificate.
5. Choose and set up the production module (C2/D/E/F/H), then sign the EU DoC and affix CE.
6. Keep the technical file, certificate and DoC for the period required by the regulation (at least 10 years) and complete production follow-up checks.

Cost and Timing Factors

• Module B fees depend on product complexity and the number of gas categories covered; every additional gas category or model family can add testing.
• C2/D/H differ in recurring cost: quality-system audits versus random product checks.
• Timing is dominated by re-testing — products that arrive fully compliant to the harmonised standards are certified far faster than those corrected during assessment.
• UKCA for Great Britain uses approved bodies (not the same EU Notified Body), so plan it separately if selling into the UK.

What the Notified Body Actually Examines

During Module B the body traces the design against the GAR’s essential requirements rather than simply reading a supplier’s test report. It checks that the design correctly manages the gas supply and gas tightness, that the heat input is correct for the declared gas categories and pressures, that combustion is stable and flue-gas CO is within limits, that ignition and flame-supervision devices work and close safely, that the appliance manages the air supply and flue discharge for its type, and that the electrical parts meet the IEC 60335 requirements. It also reviews the instructions, rating plate and warnings, and whether the manufacturer’s risk assessment actually covers the hazards. Where harmonised standards were used in full, the body can rely on the resulting presumption of conformity; where a clause was not covered, the manufacturer must justify the alternative solution with evidence. Products that fail at this stage usually do so because the technical file is incomplete or the test reports do not map to the gas categories the appliance is sold for — not because the body repeats every test from scratch. A complete, well-organised file with test reports for every declared gas category is therefore the fastest and least costly route through Module B.

Self-Certification vs Gas Appliance CE

Common Mistakes

• Assuming gas appliances can be self-certified with no Notified Body (they cannot under the GAR);
• Thinking that using harmonised standards removes the third-party requirement;
• Applying to more than one Notified Body for the same type-examination;
• Choosing a module without considering the recurring audit or sampling cost;
• Using an EU Notified Body for UKCA (a UK approved body is required);
• Starting production and CE labelling before the type-examination certificate is in place.