Personal Protective Equipment

PHASE 1: Does the Personal Protective Equipment Apply to Your Product?

As a manufacturer, you need to secure copies of the Directives and judge whether they apply to your product. The European Commission does not publish a list of products to which their laws apply; they require the manufacturer to determine the applicability of directives to any given product.

"For the purposes of this [Personal Protective Equipment (PPE)] Directive (89/686/EEC), PPE shall mean any device or appliance designed to be worn or held by an individual for protection against one or more health and safety hazards."

According to Article 1 of the Directive, the PPE also applies to the following:

"(a) a unit constituted by several devices or appliances which have been integrally combined by the manufacturer for the protection of an individual against one or more potentially simultaneous risks;

(b) a protective device or appliance combined, separably or inseparably, with personal non-protective equipment worn or held by an individual for the execution of a specific activity;

(c) interchangeable PPE components which are essential to its satisfactory functioning and used exclusively for such equipment."

Article 1 of the PPE Directive states that it does not apply to the following:

  • "PPE covered by another directive designed to achieve the same objectives as this Directive with regard to placing on the market, free movement of goods and safety,
  • the PPE classes specified in the list of excluded products in Annex I [of the PPE Directive], independently of the reason for exclusion mentioned in the first indent."

Annex 1 of the PPE Directive is below:

"ANNEX I

EXHAUSTIVE LIST OF PPE CLASSES NOT COVERED BY THIS DIRECTIVE

1. PPE designed and manufactured specifically for use by the armed forces or in the maintenance of law and order (helmets, shields, etc.).

2. PPE for self-defense (aerosol canisters, personal deterrent weapons, etc.).

3. PPE designed and manufactured for private use against:

a. adverse atmospheric conditions (headgear, seasonal clothing, footwear, umbrellas, etc.),

b. damp and water (dish-washing gloves, etc.),

c. heat (gloves etc.).

4. PPE intended for the protection or rescue of persons on vessels or aircraft, not worn all the time."

Components of the Personal Protective Equipment that are not CE marked and are intended to be incorporated in PPE yet are not essential to the basic functioning of the PPE product, will not be kept off the EU market (Article 4 of the PPE Directive).

A manufacturer can exhibit at trade shows its PPE product even it is not CE marked as long as the fact that the product is not CE marked is clearly displayed and in no way can the product be used or acquired for any purpose until the product becomes CE certified (Article 2 of the PPE Directive).

To view the Personal Protective Equipment (PPE) Directive and see the latest list of standards for that directive, please go to the website http://www.newapproach.org and click on "Directives and Standards."

This guide to the Personal Protective Equipment Directive is still being developed. For additional information on this directive, please contact either of the U.S. Department of Commerce's EU Specialists: Bob Straetz at 202-482-4496 or Sylvia Mohr at 011 32 2 508 2675.

PHASE 2: CE Marking Requirements for the Personal Protective Equipment Directive

Please see Annex II of the PPE Directive for the basic health and safety requirements for PPE products. To view the Personal Protective Equipment Directive and see the latest list of standards and requirements for that directive, please go to the website http://www.newapproach.org and click on the "Directives and Standards" link under PPE and then see Annex II.

This guide to the Personal Protective Equipment Directive is still being developed. For additional information on this directive, please contact either of the U.S. Department of Commerce's EU Specialists: Bob Straetz at 202-482-4496 or Sylvia Mohr at 011 32 2 508 2675.