Module A, internal production control, is a conformity assessment procedure. Under this route the manufacturer prepares technical documentation, controls production and declares conformity on its own responsibility. It can be used only where the product’s applicable legislation permits it. An EU declaration of conformity is also issued under other procedures, including procedures involving a notified body.
The module framework
Decision 768/2008/EC provides a framework, not permission to choose any module under every directive. Module B is type examination; C addresses conformity to the examined type; H covers full quality assurance. A1 adds supervised product testing, using an accredited in-house body or tests under a notified body’s responsibility as specified by the applicable law. It does not simply mean any external accredited laboratory.
Routes for electrical and radio products
LVD provides internal production control. EMC offers internal production control or B+C. RED Article 17 distinguishes the requirements in Article 3(1) from those in Article 3(2)/(3). Where the relevant harmonised standards for the latter are missing, only partly applied or not applied, those requirements need B+C under Annex III or full quality assurance under Annex IV. Standards and any OJ restrictions must cover the assessed requirements.
GPSR is not a Module A route to CE. Medical devices have their own MDR procedures. Machinery classification and its applicable directive or regulation must be checked separately.
CRA assessment
The main CRA conformity requirements apply from 11 December 2027. Article 32 permits A for the default category; important Class I self-assessment is conditional. Class II uses B+C, H or a qualifying available certification scheme; B+D is not a CRA route. Critical products follow Articles 8 and 32, including the fallback where mandatory certification has not been specified. Classification depends on core functionality and the current category descriptions.
Practical checklist
- Identify the legislation and category.
- Verify that internal control is permitted.
- Check standards, scope and OJ restrictions.
- Assemble evidence and control production.
- Issue the required declaration and marking; retain records for the correct period.