European PPE Regulation update

Reporting on the latest guidance applicable to PPE Regulation (EU) 2016/425.

The European Commission has recently issued additional guidelines on the interpretation of Article 47, relating to the transition arrangements to the new personal protective equipment (PPE) Regulation (EU) 2016/425.

The latest indication is that if at the relevant future date:
1 the ‘state of the art’ has not changed (that is, the applicable standard has not been revised with significant changes on such aspects as safety clauses and withdrawal of current versions), and
2 the design and manufacturing arrangements remain the same as when the product was last subject to EC type-examination, and
3 the product category under the regulation has not changed.

The product can then be placed on the market using a current EC type-examination certificate until 21st April 2023 (or until the expiry date of the certificate if it is earlier).

However, the product itself must be in compliance with the regulation from 21st April 2019. Therefore, the product markings and user instructions must be updated as required by the regulation and a new EU Declaration of Conformity must be produced. This means that the new EU Declaration of Conformity can be based on a valid EC type-examination certificate produced under PPE Directive 89/686 until 21st April 2023 (or the expiry date of the certificate if earlier).

The new guidance does provide many current EC type-examination certificate holders with a longer timescale to transfer. However, for a number of types of products, recent standards changes will still mean EU type-examination certificates in accordance with the new regulation will be required by 21st April 2019. SATRA would advise its members that having an EU type-examination certificate (and corresponding module C2 or D evidence for category III products) to Regulation 2016/425 is considered the preferable approach to being able to demonstrate compliance to the latest EU legislation to the various EU authorities and customs officials.

Suppliers of safety footwear should also note that the CEN and ISO technical committees are currently revising standards, and it is anticipated that new versions of the ISO 20344 series of standards will be published within the next couple of years.

Publishing Data

This article was originally published on page 38 of the January 2018 issue of SATRA Bulletin.

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