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EURegulation guide

# PPE Regulation (EU) 2016/425: CE Marking for Protective Equipment

PPE CE marking is category-driven. The product's risk protection level — not the product type — determines whether you can self-certify or must involve a Notified Body. Misclassifying a Category III product as Category II is one of the most common and serious compliance failures in this space.

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At a glance

PPE categories

3

Key standards

7

Technical file items

8

## PPE categories and conformity routes

Category I

### Minimal risk

**Examples:** Gardening gloves, sunglasses for non-industrial use, simple protective clothing for minor cuts and abrasions.

**Conformity route:** Module A — manufacturer self-certifies. No Notified Body required. Manufacturer draws up Declaration of Conformity and affixes CE mark.

Category II

### Intermediate risk — hazards not covered by Category I or III

NB required

**Examples:** Safety helmets for construction, high-visibility clothing, safety shoes (EN ISO 20345), protective gloves for chemical handling at intermediate risk.

**Conformity route:** Module B (EU type-examination by NB) + Module C (conformity to type). Notified Body issues EU type-examination certificate.

Category III

### Severe risk — irreversible or mortal injury

NB required

**Examples:** Respiratory protection (face masks, respirators), fall-protection harnesses, protective equipment against electric arcs, high-voltage gloves, chemical protection suits.

**Conformity route:** Module B + Module C2, D, or F. NB type examination plus production QA or product verification. Most rigorous route.

## Key harmonised standards

EN ISO 20345

Personal protective equipment — safety footwear

EN 397

Industrial safety helmets — shock absorption and penetration resistance

EN ISO 374-1

Protective gloves against dangerous chemicals and micro-organisms

EN 166

Personal eye protection — specifications

EN 149

Respiratory protective devices — filtering half masks (FFP classifications)

EN 361

Personal protective equipment against falls from a height — full body harnesses

EN ISO 11612

Protective clothing against heat and flame

## Technical file checklist

01

Product description and intended use, including risk category classification rationale

02

Design drawings, manufacturing specifications, and bill of materials

03

EU type-examination certificate number and issuing Notified Body (Category II and III)

04

List of harmonised standards applied with OJ citation verification

05

Test reports from accredited laboratories

06

Risk assessment covering all identified hazards

07

User information and instructions in all required languages

08

Quality management documentation (Category III)

## Frequently asked questions

### What changed when the PPE Directive became the PPE Regulation?

The PPE Regulation (EU) 2016/425 replaced the old PPE Directive 89/686/EEC from April 2019. The core category system remained similar, but the Regulation introduced more detailed obligations for economic operators (manufacturers, importers, distributors), stronger requirements for instructions and information, and clearer rules on the EU Authorised Representative role. Products certified under the old directive needed reassessment.

### Is a face mask (surgical mask) covered by the PPE Regulation?

Surgical masks primarily intended to protect the patient from the wearer are Medical Devices (MDR), not PPE. Masks intended to protect the wearer from the environment — filtering face pieces (FFP1, FFP2, FFP3) — are Category III PPE under EN 149. Some products are dual-use and must comply with both frameworks. The intended use stated on the packaging is the key determining factor.

### Can the same PPE be certified under multiple categories?

No — a PPE product has a single category classification based on its worst-case risk protection function. If a product provides protection against both intermediate and severe risks, it is classified as Category III overall, and the most stringent conformity route (Module B+C2/D/F) applies to the whole product.

### How long does a PPE EU type-examination certificate last?

EU type-examination certificates for PPE are typically issued with a validity period set by the Notified Body — often five years. They can be withdrawn or suspended if the Notified Body identifies that the product no longer meets the certified standards. Manufacturers must notify their NB of any design changes, and significant changes require a new examination.

**Disclaimer:** Educational resource only. PPE category classification can have life-safety consequences — verify your classification with a qualified engineer or your Notified Body before placing any PPE on the EU market.

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