ATEX Module A Explained: Internal Production Control Under Directive 2014/34/EU

Not every piece of explosion-protected equipment requires assessment by an ATEX Notified Body before it can be placed on the European market.

For certain lower-risk products covered by Directive 2014/34/EU (ATEX), manufacturers are permitted to demonstrate conformity using ATEX Module A, officially known as Internal Production Control. Under this conformity assessment procedure, the manufacturer evaluates product compliance internally without obtaining an EU-Type Examination Certificate from a Notified Body.

Although Module A is the simplest conformity assessment procedure under the ATEX Directive, it does not reduce the manufacturer's legal responsibilities. The manufacturer remains fully responsible for ensuring that the equipment complies with the applicable Essential Health and Safety Requirements (EHSRs), preparing technical documentation, issuing the EU Declaration of Conformity, and correctly applying the CE and ATEX markings before placing the equipment on the market.

This article explains what ATEX Module A is, when it can be used, which equipment categories qualify, and what manufacturers must do to comply with Directive 2014/34/EU.

Quick Answer

What Is ATEX Module A?

ATEX Module A is one of the conformity assessment procedures established under Directive 2014/34/EU. Officially referred to as Internal Production Control, it is described in Annex VIII of the Directive.

Unlike conformity assessment procedures such as Module B, Module D, or Module E, Module A does not require the participation of an independent ATEX Notified Body. Instead, the manufacturer evaluates whether the equipment complies with the applicable requirements of the Directive through its own design controls, manufacturing processes, and technical documentation.

This procedure is intended for equipment presenting a relatively lower level of explosion risk, where European legislation allows manufacturers to declare conformity without mandatory third-party product examination.

However, Module A should not be interpreted as "self-certification" in the informal sense. Manufacturers remain legally accountable for every aspect of product compliance and must be able to demonstrate conformity to the competent authorities whenever requested.

Why Does ATEX Module A Exist?

The ATEX Directive recognizes that explosion-protected equipment is used in environments with different levels of explosion risk. Consequently, not every product requires the same level of conformity assessment.

Equipment intended for Zone 2 gas atmospheres or Zone 22 combustible dust atmospheres presents a lower level of risk than equipment designed for continuous or frequent exposure to explosive atmospheres.

To avoid imposing unnecessary administrative burdens on manufacturers while maintaining an appropriate level of safety, Directive 2014/34/EU permits Internal Production Control for certain Category 3 equipment.

Although manufacturers are allowed to perform the conformity assessment internally, they continue to bear full legal responsibility for ensuring that the equipment satisfies all applicable Essential Health and Safety Requirements before it is placed on the European market.

Which Equipment Can Use ATEX Module A?

ATEX Module A generally applies to Category 3 equipment covered by Directive 2014/34/EU.

Category 3 equipment is intended for installation in hazardous areas where explosive atmospheres are not expected to occur during normal operation or, if they do occur, are likely to exist only infrequently and for short periods.

Typical applications include:

• Category 3G equipment intended for Zone 2 gas hazardous areas.
• Category 3D equipment intended for Zone 22 combustible dust hazardous areas.
• Certain Ex ec electrical equipment.
• Certain equipment employing other protection concepts permitted for Category 3 applications.

Manufacturers should always verify that the selected conformity assessment procedure is permitted for the specific equipment category and protection concept before applying Module A.

When Is Module A Not Permitted?

Module A cannot be used for higher-risk explosion-protected equipment that requires mandatory involvement of an ATEX Notified Body.

For example, equipment intended for Category 1 or many Category 2 applications generally requires conformity assessment procedures involving independent third-party evaluation, such as Module B combined with Module D, Module E, or Module F.

Manufacturers should therefore determine the equipment category before selecting the applicable conformity assessment procedure.

Manufacturer Responsibilities Under Module A

Although ATEX Module A does not require the participation of an ATEX Notified Body, the manufacturer assumes full legal responsibility for demonstrating that the equipment complies with Directive 2014/34/EU.

Internal Production Control means that the manufacturer is responsible for evaluating conformity, maintaining supporting evidence, and ensuring that every product placed on the European market satisfies the applicable Essential Health and Safety Requirements (EHSRs).

Before placing equipment on the market, manufacturers are expected to:

• Design equipment that complies with the applicable Essential Health and Safety Requirements (EHSRs).
• Apply the appropriate harmonized EN IEC 60079 standards where relevant.
• Prepare and maintain complete technical documentation.
• Implement production controls to ensure consistent manufacturing.
• Issue the EU Declaration of Conformity.
• Apply the CE and ATEX markings where required.
• Maintain documentation for inspection by the competent authorities.

The absence of third-party involvement does not reduce these obligations. Instead, it places greater responsibility on the manufacturer to demonstrate that the conformity assessment has been carried out correctly.

How Internal Production Control Works

Internal Production Control follows a structured process designed to ensure that products consistently comply with the applicable provisions of Directive 2014/34/EU.

Although the Directive does not prescribe a detailed quality management system for Module A, manufacturers are expected to establish adequate procedures to verify product conformity before equipment is placed on the market.

A typical Internal Production Control process consists of the following stages:

1. Determine the applicable equipment category and intended hazardous area.
2. Identify the relevant Essential Health and Safety Requirements.
3. Select the applicable harmonized standards.
4. Design and evaluate the equipment.
5. Prepare technical documentation.
6. Verify that production conforms to the approved design.
7. Issue the EU Declaration of Conformity.
8. Apply the required CE and ATEX markings.

Each stage should be documented to demonstrate that the manufacturer has exercised appropriate control over the design and manufacturing process.

Technical Documentation Requirements

One of the most important obligations under Module A is the preparation of technical documentation.

The technical documentation provides objective evidence that the equipment complies with the requirements of Directive 2014/34/EU and enables competent authorities to assess conformity if requested.

Although the exact contents vary depending on the product, technical documentation typically includes:

• General description of the equipment.
• Design and manufacturing drawings.
• Electrical schematics.
• Bill of materials.
• Engineering calculations.
• Risk assessment.
• List of applicable harmonized standards.
• Equipment marking details.
• Operating instructions.
• Supporting test reports.
• Manufacturing procedures where applicable.

The documentation should clearly demonstrate how compliance with the Essential Health and Safety Requirements has been achieved.

Manufacturers are also responsible for retaining this documentation for the period specified by Directive 2014/34/EU and making it available to market surveillance authorities upon request.

Demonstrating Compliance with the Essential Health and Safety Requirements

ATEX Module A does not eliminate the requirement to comply with the Essential Health and Safety Requirements (EHSRs) contained in Annex II of Directive 2014/34/EU.

Instead, the manufacturer must independently evaluate whether the equipment satisfies every applicable safety requirement before declaring conformity.

Compliance is typically demonstrated through a combination of:

• Engineering design calculations.
• Application of harmonized EN IEC 60079 standards.
• Type testing where appropriate.
• Performance verification.
• Material selection.
• Risk assessment.
• Manufacturing controls.

Using harmonized standards provides a presumption of conformity with the corresponding Essential Health and Safety Requirements, although manufacturers remain responsible for ensuring that every applicable requirement has been addressed.

Production Control Requirements

Module A requires manufacturers to ensure that products manufactured in series remain consistent with the approved technical documentation.

This means production processes should be sufficiently controlled to ensure that each unit placed on the market continues to comply with the design that formed the basis of the conformity assessment.

Typical production control activities include:

• Incoming material inspection.
• Manufacturing process verification.
• Assembly inspections.
• Routine electrical testing where applicable.
• Final product inspection.
• Verification of equipment marking.
• Documentation review before shipment.

Although Module A does not require a certified quality management system such as those used under Module D or Module E, manufacturers should maintain sufficient controls to ensure consistent product conformity throughout production.

Issuing the EU Declaration of Conformity

After completing the Internal Production Control procedure and confirming that the equipment complies with the applicable requirements of Directive 2014/34/EU, the manufacturer must prepare and sign the EU Declaration of Conformity (DoC).

The Declaration of Conformity is the manufacturer's formal legal statement that the equipment satisfies all applicable European Union legislation. By signing this document, the manufacturer accepts full responsibility for the conformity of the product.

A typical EU Declaration of Conformity includes:

• Manufacturer's name and address.
• Product identification.
• Description of the equipment.
• Applicable European legislation.
• Applicable harmonized standards.
• Reference to the conformity assessment procedure.
• Name and signature of the authorized person.
• Date of issue.

Under Module A, the Declaration of Conformity is issued solely by the manufacturer because no ATEX Notified Body participates in the conformity assessment process.

Applying CE and ATEX Markings

Once conformity has been demonstrated and the EU Declaration of Conformity has been issued, the manufacturer must correctly mark the equipment before placing it on the European market.

Depending on the product, the marking typically includes:

• CE marking.
• Specific ATEX marking.
• Equipment Group.
• Equipment Category.
• Explosion protection marking.
• Temperature class or maximum surface temperature.
• Manufacturer identification.
• Year of manufacture where applicable.

Unlike conformity assessment procedures involving an ATEX Notified Body, Module A does not require a Notified Body identification number to accompany the CE marking because no independent body participates in the conformity assessment.

Manufacturers should ensure that all markings are accurate, durable, and consistent with the technical documentation and the EU Declaration of Conformity.

Advantages of ATEX Module A

Module A offers several practical advantages for manufacturers producing eligible Category 3 equipment.

• No mandatory involvement of an ATEX Notified Body.
• Lower certification costs.
• Shorter time to market.
• Simplified conformity assessment process.
• Greater flexibility during product development.
• Reduced administrative burden.

These advantages make Module A particularly suitable for manufacturers producing equipment intended for lower-risk hazardous areas while maintaining compliance with Directive 2014/34/EU.

Limitations of ATEX Module A

Although Module A simplifies the conformity assessment process, it also has important limitations.

The procedure is only available where permitted by Directive 2014/34/EU and cannot be applied to equipment requiring mandatory third-party assessment.

Manufacturers should also recognize that Internal Production Control does not reduce their legal obligations. Because no independent organization reviews the product before it is placed on the market, manufacturers bear complete responsibility for demonstrating conformity.

If market surveillance authorities determine that the equipment does not comply with the Directive, the manufacturer remains fully accountable regardless of whether Module A was used.

ATEX Module A vs Module B

One of the most common sources of confusion is the difference between Module A and Module B.

Feature	Module A	Module B
Official Name	Internal Production Control	EU-Type Examination
ATEX Notified Body Required	No	Yes
Typical Equipment	Category 3	Category 1 and many Category 2 products
Technical Design Review	Performed by manufacturer	Performed by Notified Body
EU-Type Examination Certificate	Not required	Required
Primary Responsibility	Manufacturer	Manufacturer (supported by Notified Body assessment)

Module B focuses on independent examination of the product design, whereas Module A relies entirely on the manufacturer's own conformity assessment process.

Common Misunderstandings About ATEX Module A

Module A Means the Equipment Is Not Certified

No. Equipment assessed under Module A must still comply with Directive 2014/34/EU. The difference is that conformity is demonstrated through Internal Production Control rather than independent examination by an ATEX Notified Body.

Module A Is Simply Self-Certification

Not exactly. Although the manufacturer performs the conformity assessment internally, the process must follow the legal requirements of Directive 2014/34/EU. Comprehensive technical documentation and objective evidence of compliance are still required.

Manufacturers Do Not Need Technical Documentation

Incorrect. Technical documentation is one of the core requirements of Module A and must demonstrate that the equipment satisfies the applicable Essential Health and Safety Requirements.

Module A Can Be Used for Any ATEX Equipment

No. Module A is only available for equipment categories permitted under Directive 2014/34/EU. Manufacturers must first determine the applicable equipment category before selecting the conformity assessment procedure.

Frequently Asked Questions (FAQ)

What is ATEX Module A?

ATEX Module A is the Internal Production Control conformity assessment procedure defined in Annex VIII of Directive 2014/34/EU. It allows manufacturers of eligible Category 3 explosion-protected equipment to demonstrate compliance without the mandatory involvement of an ATEX Notified Body.

Does ATEX Module A require an ATEX Notified Body?

No. Under Module A, the conformity assessment is performed entirely by the manufacturer. An ATEX Notified Body does not examine the product or issue an EU-Type Examination Certificate as part of this procedure.

Which equipment categories can use Module A?

Module A is generally applicable to Category 3 equipment intended for lower-risk hazardous areas, such as Zone 2 gas atmospheres (Category 3G) and Zone 22 combustible dust atmospheres (Category 3D). Manufacturers should always verify the applicable conformity assessment procedure specified by Directive 2014/34/EU.

Is technical documentation required under Module A?

Yes. Technical documentation is a mandatory requirement. Manufacturers must prepare and maintain documentation demonstrating compliance with the Essential Health and Safety Requirements (EHSRs) and make it available to the competent authorities upon request.

Does Module A eliminate the need for CE and ATEX marking?

No. Equipment assessed under Module A must still bear the appropriate CE and ATEX markings where applicable. The manufacturer must also issue the EU Declaration of Conformity before the equipment is placed on the European market.

What is the main difference between Module A and Module B?

Module A relies entirely on Internal Production Control by the manufacturer, while Module B requires an ATEX Notified Body to carry out an independent EU-Type Examination of the product design before the conformity assessment can continue.

Conclusion

ATEX Module A provides manufacturers with a simplified conformity assessment procedure for eligible Category 3 explosion-protected equipment under Directive 2014/34/EU. By allowing Internal Production Control without mandatory involvement of an ATEX Notified Body, the Directive reduces administrative burden for lower-risk equipment while maintaining a high level of product safety.

However, Module A should not be mistaken for an exemption from the requirements of the ATEX Directive. Manufacturers remain fully responsible for ensuring compliance with the applicable Essential Health and Safety Requirements, preparing complete technical documentation, maintaining effective production controls, issuing the EU Declaration of Conformity, and correctly applying the CE and ATEX markings.

Understanding when Module A may be used—and the obligations that accompany it—helps manufacturers select the correct conformity assessment procedure while ensuring that explosion-protected equipment can be legally placed on the European market.

Technical Review

References

• Directive 2014/34/EU of the European Parliament and of the Council relating to equipment and protective systems intended for use in potentially explosive atmospheres.
• European Commission – ATEX Guidelines for Directive 2014/34/EU.
• European Commission – Blue Guide on the Implementation of EU Product Rules.
• EN IEC 60079 Series – Explosive Atmospheres.
• ISO/IEC 80079 Series.