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Approved BodyPost-Brexit

# UK Approved Body vs EU Notified Body: What Changed After Brexit

Brexit created two parallel third-party assessment systems for product compliance: EU Notified Bodies for CE marking and UK Approved Bodies for UKCA marking. Their certificates are not interchangeable. If your product requires third-party assessment and you want to sell in both markets, you need engagement with both systems. Understanding the differences, how to find a UK Approved Body, and how to avoid duplicating work is essential for manufacturers and importers managing dual-market compliance.

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## Key differences: UK Approved Body vs EU Notified Body

### Name and designation

EU Notified Body

Notified Body — designated by an EU member state and notified to the European Commission. Listed on NANDO database.

UK Approved Body

Approved Body — designated by UKAS (UK Accreditation Service) and listed by the relevant UK government department. Listed on gov.uk.

### Geographic scope of certificates

EU Notified Body

EU Notified Body certificates support CE marking for EU market access only.

UK Approved Body

UK Approved Body certificates support UKCA marking for Great Britain only.

### Can one body serve both markets?

EU Notified Body

Post-Brexit: EU Notified Bodies cannot issue certificates for UKCA marking. Some EU NBs have established UK subsidiaries.

UK Approved Body

UK Approved Bodies cannot issue certificates for CE marking. Some UK ABs have EU NB subsidiaries or partnerships.

### Database

EU Notified Body

NANDO (nando.nce.ec.europa.eu) — European Commission's official register

UK Approved Body

gov.uk/guidance/approved-bodies — UK government's official list maintained by product-specific departments (OPSS, MHRA, HSE)

### Which products mandatorily require third-party assessment

EU Notified Body

Lifts, pressure equipment in higher categories, ATEX, certain medical devices, certain radio equipment where no harmonised standard exists

UK Approved Body

Same categories under UK regulations — the mandatory categories largely mirror the EU list, but UK-specific guidance should be checked

## How to find and engage a UK Approved Body

01

### Identify which UK regulation requires Approved Body involvement

Not all UKCA-marked products need an Approved Body. Review the conformity assessment procedures in the applicable regulation. Approved Body involvement is only mandatory for higher-risk product categories specified in the regulation.

02

### Search the gov.uk Approved Bodies database

The official list of UK Approved Bodies is maintained on gov.uk by the relevant government department (OPSS for most products, MHRA for medical devices, HSE for pressure equipment, etc.). Search by product category.

03

### Verify the Approved Body's scope of designation

UK Approved Bodies are designated for specific product categories and conformity assessment modules. An Approved Body designated for radio equipment under the Radio Equipment Regulations is not automatically suitable for pressure equipment. Always verify scope before engagement.

04

### Obtain quotes and engage early in the development cycle

UK Approved Body capacity is limited. Popular bodies have waiting lists. Engage an Approved Body during product development rather than at the final testing stage to avoid launch delays.

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## Frequently asked questions

### Can my EU Notified Body certificate be used for UKCA marking?

No. EU Notified Body certificates cannot be used to support UKCA marking. UKCA marking for products requiring third-party assessment must be based on assessment by a UK Approved Body. However, a UK Approved Body may accept test evidence and technical documentation prepared by an EU Notified Body as input to their own UK assessment, potentially reducing the time and cost of the UK assessment. This depends on the individual UK Approved Body's policy and the scope of the assessment required.

### Is there a UK equivalent of the NANDO database for finding Approved Bodies?

Yes — the UK government maintains a list of UK Approved Bodies on gov.uk. Unlike NANDO, which is a single centralised EU database, UK Approved Body lists are maintained separately by each relevant government department: OPSS maintains the list for most general products, MHRA maintains the list for medical devices, HSE maintains the list for pressure equipment, and so on. There is no single consolidated UK AB database equivalent to NANDO.

### I already have CE marking via a Notified Body for the EU. How much additional work is needed for UKCA?

For most product categories, you can reuse the technical documentation, test reports, and risk assessment. What changes is: the body doing the assessment must be a UK Approved Body; the resulting certificate references UK regulations; and the Declaration of Conformity must reference UK law. The EU NB type-examination certificate or quality assurance certificate must be replicated by a UK AB. Many UK ABs have established expedited review procedures where your existing EU NB documentation forms the primary input, significantly reducing testing and documentation preparation costs compared to starting from scratch.

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Related guides

*   [UKCA Marking: Complete GuideComplete guide to UKCA marking for the Great Britain market: requirements, timeline, costs, GB vs NI differences, and how to tr…](/guides/ukca-marking)
*   [UK Conformity Assessment RoutesComplete guide to UK conformity assessment routes for UKCA marking: when self-declaration (internal production control) is perm…](/guides/uk-conformity-assessment-routes)
*   [CE to UKCA Transition GuideStep-by-step guide to transitioning from CE marking to UKCA marking for the Great Britain market: what changes, what stays the …](/guides/ce-to-ukca-transition)
*   [UK Designated StandardsComplete guide to UK designated standards for UKCA marking: how designated standards differ from harmonised standards, where to…](/guides/uk-designated-standards)
*   [Selling to the UK from the EU After BrexitComplete guide for EU-based companies selling to the UK after Brexit: customs duty and import VAT, UK product safety compliance…](/guides/uk-selling-from-eu)

Educational resource only. Always verify current UK Approved Body lists on gov.uk for the relevant product category before engaging any body for conformity assessment.