As a UKAS-accredited Conformity Assessment Body, we always recommend that businesses become approved manufacturers in their own right rather than relying on the NAWI Module D certification that their suppliers hold. This article outlines the importance of your own NAWI Module D certification and how it will benefit your business.
Why is it better to have your own NAWI Module D certification rather than piggy-backing with your supplier?
NAWI Module D certification provides complete legal control, independence, and market flexibility, whereas relying on a supplier ties your business operations directly to their compliance status and their products. It gives you:
Control and Independence
Sole responsibility: You manage your own Declaration of Conformity without relying on another company’s paperwork.
Supplier freedom: You can change or add component suppliers freely without needing to rewrite or transfer joint certification agreements.
No dependency risk: If your supplier loses their certification or goes out of business, your ability to place products on the market is not blocked.
Business and Market Flexibility
Direct manufacturer status: Your company name is officially listed on regulatory databases as an approved manufacturer.
Easier audits: You deal with the Approved/Notified Body directly for your own quality management system rather than exposing proprietary supply chain links.
Commercial leverage: Customers trust direct holders more when verifying legal metrology and trade-approved compliance. Having your own NAWI Module D certification shows professionalism and integrity. It also gives your business the edge over competitors that piggy-back on supplier certification.
Why is piggy-backing on your suppliers’ NAWI Module D a bad practice?
Piggybacking on your suppliers’ Module D (production quality assurance) for Non-Automatic Weighing Instruments (NAWI) is a bad practice because it undermines legal accountability, invalidates compliance, and misrepresents quality control. Under the NAWI regulations, the entity placing the device on the market holds sole legal responsibility for conformity.
Legal and Compliance Risks
Broken Legal Responsibility: Module D requires the specific manufacturer or approved importer to operate and maintain their own audited quality system. Relying on a supplier’s audit means you cannot legally declare conformity on your own behalf.
Traceability Failure: Regulatory and market surveillance authorities require product markings and documentation to match the exact economic operator responsible for production control.
Invalid Certification: A third-party or supplier quality approval does not automatically transfer down the supply chain to cover a distributor’s or re-brander’s legal obligations.
Quality and Operational Risks
Uncontrolled Processes: NAWI Module D evaluates specific manufacturing and testing locations. If your process changes or is unverified by an approved body at your site, the production control system fails.
Market Withdrawal Exposure: If authorities inspect the instruments and find that the local assembler or seller lacks independent Module D approval or valid matching documentation, the devices can be restricted, withdrawn, or recalled from the market.
Our Recommendations
UKMB would always recommend businesses become approved manufacturers in their own right. If you are ready to achieve NAWI Module D certification for your weighing and measuring instruments, then do get in touch to see how we can help.
We are now taking bookings for NAWI Module D certifications. Subject to the scope of the project, we can have you fully certified in as little as 4-6 weeks.
You can submit your application for certification by clicking here; alternatively, you can send us an email at info@ukmb.org.