What Do Notified Bodies Do for Batteries?

Notified bodies for batteries are conformity assessment bodies that have been assessed, notified by a Member State and listed in the NANDO database, with a defined scope covering the battery Regulation procedures. Notified bodies carry out the tasks in Module D1 and Module G, assess quality systems, examine units, issue certificates and carry out surveillance, where the conformity assessment procedure requires notified body involvement. A notified body is not a general testing laboratory or a consultant: notification, scope and independence define the role, and a body without notification for the relevant procedure cannot perform the notified body tasks.

The notified body system is a trust system. Member States notify bodies that meet the requirements for competence, impartiality and independence, the Commission lists them, and operators and authorities rely on the listing. An operator who uses a body without checking the listing and scope relies on a claim rather than on the trust system, and an authority who finds a certificate from an unnotified body will treat the certificate as not meeting the procedure. The check is therefore a listing check, carried out before engagement and repeated during the relationship.

How is a body notified?

A conformity assessment body is notified when a Member State assesses the body against the requirements in the Regulation, including competence, impartiality, independence, confidentiality and liability, and notifies the Commission and other Member States through the NANDO system. Notification specifies the procedures, battery types and requirements covered, and the body may carry out notified body tasks only within that scope. Notification can be restricted, suspended or withdrawn where the body no longer meets the requirements, and the listing should be checked for current status, not only for initial notification.

A notification file for an operator should contain the NANDO entry, the scope, the notification date and the current status, with a review date. A file that contains only a certificate or a brochure, without the NANDO entry, does not show notification. A file with a NANDO entry from an earlier date, without a current status check, does not show that notification remains in force. The file should be updated when the scope or status changes, and the update should be dated.

What tasks do notified bodies carry out for batteries?

Notified body tasks for batteries include assessing the manufacturer quality system under Module D1, carrying out surveillance audits, examining technical documentation and test evidence, examining individual batteries or batches under Module G, issuing certificates or notifications, and, for carbon footprint and recycled content, carrying out third party verification where the Regulation requires it. Each task is defined in Annex VIII for the module in question, and the body must carry out the task as defined, with the conclusions and reasoned assessment decision recorded. A body that carries out a general review, without following the module tasks, has not performed the notified body role for that procedure.

Worked check: a manufacturer operates a quality system under Module D1. The notified body assesses the system in two stages, documentation review and on site audit, and issues a notification authorising the manufacturer to affix the notified body number after the CE marking. Annual surveillance visits check continued conformity, and recertification is required on the cycle set in the body procedures. A manufacturer who treats the initial notification as permanent, without surveillance, misses the continuing control that Module D1 requires.

How are notified bodies chosen?

Notified bodies are chosen on scope, competence for the battery type and procedure, independence from the manufacturer, and capacity to carry out surveillance and verification within the operator timetable. Price and location are secondary considerations, because a body without scope or without independence cannot provide a valid certificate at any price. The operator should obtain the NANDO scope, the body procedures, the surveillance plan and the fee structure before engagement, and should record the selection reasons in the conformity file. A selection based on price alone, without a scope check, is a weak selection that an authority can query.

Selection should be documented as a comparison of scope, competence and surveillance arrangements, not as a single body name. A comparison that lists two or three bodies, with scope and surveillance detail for each, shows that the operator considered the trust system. A selection record with a single name and no comparison shows only that a body was engaged, not why. The record should be retained with the conformity file, so that a later change of body can be judged against the original reasons.

What independence and impartiality rules apply?

Notified bodies must be independent of the manufacturer, importer and other economic operators whose batteries they assess, must not be involved in the design, manufacture, supply or maintenance of the batteries assessed, and must carry out assessment impartially, without conflicts of interest. Personnel involved in assessment must not have a financial or other interest in the outcome, and the body must have procedures to identify and manage conflicts. An operator who engages a body with a conflict, or who pressures a body on the outcome, undermines the assessment, and the certificate that results will not be reliable evidence.

Independence should be checked through the body declaration, the contract and the absence of design or supply involvement, with the check recorded. A check that relies only on the body statement, without reviewing the contract for design or consultancy services, misses a common conflict route. A check that reviews both the statement and the contract, and that records any consultancy or design services separately from assessment services, provides stronger evidence. The check should be repeated when the body or the operator relationship changes.

What surveillance do notified bodies carry out?

Surveillance under Module D1 includes periodic audits of the quality system, checks that the system continues to meet the module requirements, and, where the body procedures provide for it, unannounced visits and product checks. Surveillance findings must be recorded, with corrective actions required where nonconformities are found, and with follow up to confirm that corrective actions have been implemented. A quality system that passes initial assessment but fails surveillance has not maintained conformity, and the notified body must take the action provided for in the module, including restriction or withdrawal of the notification where the requirements are no longer met.

Surveillance evidence should be filed as a cycle: audit plan, audit report, findings, corrective actions and follow up, with dates for each step. A file with only the initial notification, without surveillance reports, is incomplete for a Module D1 battery. A file with surveillance reports but no corrective action follow up is incomplete where findings were raised. The cycle should be complete for each surveillance period, and the file should show the current cycle status at any point.

What happens when notification changes?

When a notified body notification is restricted, suspended or withdrawn, certificates and notifications issued by the body must be reviewed, and the operator must engage a new notified body where the procedure requires notified body involvement. Batteries placed on the market under a certificate from a body whose notification has changed need a review of the certificate status and, where required, a new assessment. As checked on 28 October 2026, notification status should be checked in NANDO before each placing cycle, not only at initial engagement. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. Notification and scope should be checked in NANDO before engagement and repeated during the relationship.