Is There a Module A for Lifts?

Short answer: No. Module A is defined as “internal production control” in the general EU conformity assessment system; however, it is not among the conformity routes that the Lifts Directive 2014/33/EU allows for completed lifts.

It is therefore not correct to issue a “Module A certificate” for the CE conformity of a new lift, or to present Module A as an alternative to H1, G or the routes used with B.

What Is Module A?

In the EU’s general conformity assessment framework, Module A is the internal production control approach: the manufacturer prepares the technical documentation, ensures the product’s conformity under its own responsibility, and no third-party conformity assessment body is involved.

Not every product law uses every module. Each piece of legislation defines which routes may be used according to the level of risk. Because lifts require a high level of safety, Directive 2014/33/EU has selected routes for completed lifts that involve a notified body.

The Valid Routes for Lifts under 2014/33/EU

Under Article 16 of the directive, the following routes are available for a completed lift:

• Module H1 — Annex XI full quality assurance + design examination,
• Module G — Annex VIII unit verification,
• Module B+E — Annex IV-B type-examination + Annex X product quality assurance,
• Module B+D — Annex IV-B type-examination + Annex XII production quality assurance,
• Module B+F — Annex IV-B type-examination + Annex V final inspection.

The directive also allows lifts designed and manufactured under an Annex XI quality system to be completed through one of the Annex V, X or XII routes. The choice should be confirmed with the notified body for each application.

Is Module A the Same as a Type A Inspection Body?

No; apart from the similar name, they are different concepts.

Concept	What it means	Role for lifts
Module A	General conformity assessment module based on internal production control	Not a route selected by 2014/33/EU for completed lifts
Type A inspection body	A type of independent inspection body under EN ISO/IEC 17020	Carries out periodic inspections of lifts in service
Notified body	A body authorised to carry out conformity assessment under specific legislation and scope	Takes part in CE processes such as H1, G, B, E, D or Annex V

A Type A inspection body may also hold notified body status for a specific scope; nevertheless, the periodic inspection it carries out and CE conformity assessment remain different activities.

Why Is Periodic Inspection Not Module A?

Periodic inspection:

• assesses the safe operation of a lift in service,
• is carried out by an authorised Type A inspection body,
• is repeated at set intervals,
• results in a report and an information label as required by the legislation.

Conformity assessment, on the other hand:

• is completed before a new lift is placed on the market,
• is the installer’s responsibility,
• follows one of the modules/annexes defined in 2014/33/EU,
• is the basis of the EU declaration of conformity and the CE marking.

The two processes cannot replace each other.

What to Ask If You Are Offered a “Module A Certificate”

To find out whether the term is being used incorrectly, ask these questions:

1. Which legislation and annex number is the certificate based on?
2. Is the certificate issued for a completed lift or for another product?
3. What are the notified body identification number and scope of the body carrying out the assessment?
4. Which of the H1, G, B+E, B+D or Annex V final inspection routes does the process correspond to?
5. What is the full name of the certificate to be issued?

It is not enough for a quotation or contract to say only “CE certificate” or “Module A”; the annex of the directive, the scope, the product/lift description and the authority of the body must be clearly stated.

Is Module A Used for Safety Components?

There is no stand-alone Module A route for lift safety components under 2014/33/EU either. For safety components, the directive provides for:

• B+C2,
• B+E,
• H.

This scope is separate from that of completed lifts.

How to Choose the Right Route

The choice depends on whether the product is a completed lift or a safety component, the number of installations, the model/type approach, the scope of the quality system, design responsibility and any special technical conditions.

For a comparative decision guide, see Lift Certification Modules.

Legal Basis

• Lifts Regulation (2014/33/EU) — Turkish Ministry of Industry and Technology (in Turkish)
• Article 16 and annexes of Directive 2014/33/EU — EUR-Lex
• Decision No 768/2008/EC, general conformity assessment modules — EUR-Lex

Because legislation and the scopes of bodies can change, check the current text and scope of authority on the application date.