What is Module A?
Last reviewed 5 October 2026. Source: Regulation (EU) 2019/1009, consolidated text of 1 July 2026.
In simple words
Module A is also called internal production control. The manufacturer does the check alone. No notified body takes part. The manufacturer writes the technical documentation, makes sure production follows it, puts the CE marking on the product and writes the declaration of conformity. The manufacturer is fully responsible.
Words in this article
- Module
- One of the fixed routes for conformity assessment. The regulation has Module A, Module B followed by Module C, Module D1 and Module A1.
- Manufacturer
- The company that makes the product, or has it made, and sells it under its own name or brand.
- Technical documentation
- The set of documents that show the product follows the rules. It includes the product description, the materials, the production process, test reports and the label.
- EU declaration of conformity (DoC)
- A signed document in which the manufacturer states that the product follows the rules.
- CE marking
- A mark on the packaging. It shows that the manufacturer states that the product follows the EU rules.
- Notified body
- An independent organisation that an EU country has approved to check products or quality systems. Some modules need one.
What does the manufacturer do?
- Write the technical documentation. It must include an analysis of the risks.
- Take all steps so that production follows the technical documentation.
- Put the CE marking on each package.
- Write the declaration of conformity.
What must the manufacturer keep?
Keep the declaration and the technical documentation for 5 years after the product is first sold in the EU. Authorities can ask to see them. Give them a copy of the declaration on request.
When can you not use Module A?
You cannot use it for inhibitors, plant biostimulants and high-nitrogen ammonium nitrate fertilisers. Read which module applies.
How does RecyFert help?
RecyFert builds the Module A dossier in the Gilbert FPR software and keeps it ready for audits. You check and approve it. You stay responsible.