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2026-04-20·13 min read·

CRA Art.29: The Notification Procedure — How Member States Formally Designate Notified Bodies, the NANDO Database, and the Commission Objection Mechanism (Developer Guide 2026)

Getting a conformity assessment body (CAB) approved at the national level under CRA Art.28 is only step one. Before that body can legally perform third-party conformity assessments for Class II products under the CRA, the member state must complete the notification procedure defined in Article 29 — formally informing the European Commission and all other member states of the designation.

This step is not a formality. It includes a one-month objection window during which the Commission or any member state can challenge the designation. Until that window closes (or until any objection is resolved), the newly approved body cannot act as a notified body under the CRA. For manufacturers of Class II products racing to certify before December 2027, this Art.29 pipeline is a critical dependency.

What CRA Article 29 Actually Covers

Article 29 defines the formal communication channel between national notifying authorities and the EU-level system. It addresses four core questions:

  1. What must the notification contain — the minimum information package the member state transmits to the Commission
  2. How notification happens — through the NANDO electronic information system, not bilateral correspondence
  3. What is the objection window — one calendar month after notification, open to the Commission and all member states
  4. What happens after objection — escalation paths including Commission investigation and binding decisions

Understanding Art.29 is essential for:

The Required Notification Content

When a national notifying authority has completed its Art.28 review and approved a CAB, it must transmit a notification to the Commission. The notification must include at minimum:

1. Identity of the Conformity Assessment Body

2. Scope of the Notification

The notification must specify precisely which CRA-related activities the body is designated to perform:

This scope specificity matters enormously for manufacturers. A notified body designated only for module B cannot issue the full certification you need if your product requires module H. Manufacturers must verify not just that a notified body exists, but that it is designated for the right module and product category.

3. Accreditation Evidence

The notification must reference the accreditation certificate issued by the national accreditation body, including:

If accreditation was granted under a national framework other than EA MLA, the notification must include additional justification — and the Commission has specific powers to investigate whether that framework provides equivalent assurance (see below under the objection mechanism).

4. Technical Competence Evidence Summary

A summary of the technical competency evidence reviewed during the Art.28 process, demonstrating that the body has the expertise to assess products in the claimed scope. This is the technical backbone that supports the notification — the Commission and other member states use it to evaluate whether an objection is warranted.

The NANDO Electronic System

All CRA notifications are submitted and published through NANDO — the New Approach Notified and Designated Organisations database. This is the single authoritative EU-level registry of all notified bodies across all New Approach directives and regulations, including the CRA.

NANDO serves several functions in the Art.29 procedure:

For notifying authorities: The member state submits the notification through the NANDO portal. This triggers the official start of the one-month objection period and creates a publicly visible entry.

For the Commission: NANDO is the monitoring tool. The Commission can see all pending notifications, track their status, and initiate objection proceedings directly through the system.

For manufacturers: NANDO is where you verify that a notified body has complete legal standing under the CRA. A body may have national approval (Art.28 complete) but if it does not appear in NANDO with an active CRA-scope entry, you cannot legally rely on its assessments for CRA compliance.

For other member states: NANDO provides the visibility needed to exercise the Art.29 objection right. Any member state can see a new notification the moment it is submitted.

How to Read a NANDO Entry

When NANDO publishes a CRA notified body entry, it will show:

The key field to check is Status = Active before relying on any notified body for your Class II product assessment. A body in "Pending" status cannot yet perform legally valid assessments under the CRA.

The One-Month Objection Period

After a notification is submitted to NANDO, a one-calendar-month objection window opens. During this period:

Who Can Object

  1. The European Commission — can raise objections on any ground, including insufficient accreditation evidence, scope claims that exceed demonstrated competence, or doubts about the national authority's evaluation procedure
  2. Any EU member state — can raise objections based on concerns about the body's independence, technical competence, or whether the notification scope is appropriate

Form of an Objection

Objections must be submitted in writing to the Commission with specific grounds. Vague concerns are not sufficient — the objecting party must identify specifically what element of the notification they believe is deficient and why.

What Happens After an Objection

When an objection is raised:

  1. Notification is put on hold. The body cannot act as a notified body during the investigation period, regardless of national approval.
  2. The Commission investigates. The Commission may request additional information from both the notifying authority and the applicant body. It may also consult technical experts or other accreditation bodies.
  3. Commission issues a decision. The Commission can:
    • Confirm the notification (objection rejected) — the body becomes active
    • Require modification of the scope — notification proceeds with a narrower designation
    • Block the notification — the body cannot proceed until the underlying deficiency is remedied
  4. Member state must comply. The notifying member state is legally bound by the Commission's decision.

This objection mechanism exists because the mutual recognition principle means that a notified body designated by Germany, for example, can perform assessments for manufacturers anywhere in the EU. All member states have a legitimate interest in the quality of designations made by their peers.

Special Rules for Non-EA MLA Accreditation

Most CRA notified body applications will rely on accreditation granted under the EA Multilateral Agreement (EA MLA) — the framework that harmonises accreditation standards across European national accreditation bodies. EA MLA accreditation is treated as strong presumptive evidence of competence under the CRA.

However, the CRA allows member states to use alternative accreditation frameworks in limited circumstances. When a notification relies on non-EA MLA accreditation:

  1. The member state must provide additional documentation explaining why the alternative framework provides equivalent guarantees
  2. The Commission has enhanced review rights — it can request a technical expert evaluation of the alternative accreditation framework itself, not just the body's specific competence
  3. The objection period may effectively be extended if the Commission opens a formal investigation
  4. Other member states have stronger grounds to raise objections — the absence of EA MLA accreditation is itself a legitimate concern

For manufacturers, this means: a notified body relying on non-EA MLA accreditation carries more uncertainty. Its notification is more likely to face objections and delays. If you are sourcing a notified body for Class II assessments, EA MLA-accredited bodies are the lower-risk choice.

Art.29 and the Class II Certification Bottleneck

The Art.29 notification procedure is one reason why the December 2027 deadline for Class II products creates real supply-side risk. The full pipeline looks like this:

CAB prepares for CRA accreditation
        ↓ (months of preparation)
CAB applies to national notifying authority (Art.28)
        ↓ (70-day review)
National authority approves application (Art.28 complete)
        ↓ (notification submitted to NANDO)
One-month objection period (Art.29)
        ↓ (+ time to resolve any objections)
Notified Body is ACTIVE in NANDO
        ↓
Manufacturer can book and complete Class II assessment
        ↓ (additional months for assessment itself)
Declaration of Conformity + CE marking
        ↓
Product on EU market

Working backwards from December 2027: if the Art.28 + Art.29 pipeline takes 4-6 months per body (not including the CAB's preparation period), and if manufacturers then need 3-6 months for the actual conformity assessment, the last realistic moment to start an Art.28 application that feeds into a December 2027 assessment is late 2026.

There is also capacity risk: if only a handful of notified bodies get designated by mid-2027, demand from all Class II manufacturers will concentrate on those bodies simultaneously. Assessment slots will be scarce and expensive.

After the Objection Period: What "Active" Really Means

When the one-month objection period passes without an objection (or after any objection is resolved in favour of the notification), the Commission issues the notification number and the body is published in NANDO as Active. From that moment:

  1. The notified body may begin performing conformity assessments under the CRA
  2. Assessments it issues carry EU-wide legal force under mutual recognition
  3. The body's notification number must appear in conformity assessment documents it issues and in manufacturers' technical documentation
  4. The body is subject to ongoing monitoring by the national notifying authority and can have its notification suspended or withdrawn under Art.31 if it ceases to meet the requirements

For manufacturers, the notification number is how you verify a certificate's legitimacy. If a CAB hands you a conformity assessment certificate without a notification number, it either lacks notification or the assessment predates notification — in either case, the certificate has no legal standing under the CRA.

Practical Checklist: Art.29 Compliance Dependencies

class CRANotificationPipelineChecker:
    """
    Art.29 status checker for Class II product manufacturers.
    Verifies notified body notification status before engaging for assessment.
    """

    def check_notified_body_status(self, body_name: str) -> dict:
        return {
            "nando_entry_exists": self._check_nando(body_name),
            "status_is_active": self._check_status(body_name),  # not Pending/Suspended
            "scope_covers_your_module": self._check_module_scope(body_name),
            "scope_covers_your_product_class": self._check_product_scope(body_name),
            "ea_mla_accredited": self._check_accreditation_basis(body_name),
            "notification_number_issued": self._check_notification_number(body_name),
            "no_pending_objection": self._check_objection_status(body_name),
        }

    def get_pipeline_risk_assessment(self, target_date: str) -> dict:
        """
        For Class II manufacturers: estimate pipeline risk given target_date.
        """
        return {
            "nb_application_deadline": "Submit Art.28 application to national authority by Q3 2026",
            "notification_bottleneck_risk": "HIGH if fewer than 10 NANDO-active CRA notified bodies by mid-2027",
            "capacity_risk": "Assessment slots will be scarce if NB supply is limited",
            "backup_strategy": "Identify 2-3 candidate bodies across different member states",
            "objection_risk": "Lower for EA MLA-accredited bodies",
        }

Key Questions Before Engaging a Notified Body

Before contracting with any conformity assessment body for CRA Class II assessments:

  1. Is the body listed in NANDO as Active? (not just nationally approved)
  2. Does the NANDO entry cover the specific Annex VIII module you need?
  3. Does the scope include your product's risk class?
  4. Was the accreditation granted under EA MLA or an alternative framework?
  5. What is the body's current assessment capacity and lead time for new clients?
  6. Does the body have prior experience with similar product categories?

Art.29 in Context: The Chapter V Notification Framework

Article 29 does not stand alone — it is the operational centre of Chapter V's multi-step notification framework:

ArticleFunction
Art.26Requirements a body must meet to qualify
Art.27Rules for subsidiaries and subcontracting
Art.28How a body applies to the national authority
Art.29How the national authority notifies the Commission
Art.30How notifying authorities are established and operate
Art.31Changes, suspension, and withdrawal of notifications

The full pipeline is Art.28 → Art.29 → NANDO Active status → legally valid assessments. Manufacturers of Class II products must track all three stages for any body they intend to rely on.

20-Item Art.29 Readiness Checklist for Class II Manufacturers

Understanding the Landscape

Monitoring the Pipeline

Due Diligence on Specific Bodies

Timeline Planning

Key Dates for Art.29 Context

Conclusion

Article 29 is the step that transforms a nationally approved conformity assessment body into a legally operative notified body with EU-wide standing. The NANDO database is the authoritative source of truth for which bodies are active and what they are authorised to do. The one-month objection period is a genuine quality control mechanism, not a formality — objections have been raised under other EU New Approach frameworks, and there is no reason to expect the CRA to be different.

For Class II manufacturers, the practical implication is clear: start engaging with the notified body pipeline early. The Art.28 + Art.29 sequence takes at minimum several months. If your product cannot begin its conformity assessment until a body clears the full notification pipeline, and if that pipeline is delayed by objections or capacity constraints, you may find yourself unable to place the product on the EU market by December 2027.

Track NANDO. Verify Active status. Confirm module scope. And build the notification pipeline into your CRA compliance roadmap — not as a footnote, but as a critical path dependency.

See Also