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

Before Brexit, EU Notified Bodies could certify products for both the EU and UK markets simultaneously. That ended on January 1st 2021. UK Approved Bodies and EU Notified Bodies are now separate accreditation systems with no mutual recognition. If your UKCA route requires third-party assessment, only a UKAS-accredited UK Approved Body counts — and that changes your test lab strategy.


## Transcript

### EU Notified Bodies cannot issue UKCA certificates

Before Brexit, a single Notified Body could certify a product for both the EU and Great Britain. Not anymore. EU Notified Bodies and UK Approved Bodies are separate systems with no mutual recognition. Only a UKAS-accredited Approved Body can fill a UKCA third-party role.

### How the two systems differ

EU Notified Bodies are accredited within EU states, listed in the NANDO database, and issue EU Type-Examination Certificates for CE marking. UK Approved Bodies are UKAS-accredited and issue UK Type-Examination Certificates for UKCA. Neither is mutually recognized. Labs like SGS, Intertek, Bureau Veritas, and TÜV SÜD UK operate as both, under separate designations.

### When you need a UK Approved Body

Most consumer electronics — radio products, IT equipment, household appliances — can self-declare UKCA under Module A, no Approved Body needed. You need one when third-party assessment is required: some radio products, higher-risk machinery, certain medical devices. Check your product's UK statutory instrument.

Tags: UKCA, UK Approved Body, Notified Body, Brexit, UK compliance