but the RCD would almost certainly make it "similar switchgear"
I'd still argue not - without any overcurrent protective devices there's no incoming or outgoing circuits - it's all (by the definition of a circuit) all one circuit. It can't therefore be a distribution board, and thus not any particular type of distribution board that is a consumer unit, so any similarity doesn't seem at all obvious. Let alone meeting the switchgear definition's requirement for containing both main and auxiliary switching equipment.
but the RCD would almost certainly make it "similar switchgear"
I'd still argue not - without any overcurrent protective devices there's no incoming or outgoing circuits - it's all (by the definition of a circuit) all one circuit. It can't therefore be a distribution board, and thus not any particular type of distribution board that is a consumer unit, so any similarity doesn't seem at all obvious. Let alone meeting the switchgear definition's requirement for containing both main and auxiliary switching equipment.
