SME Safety position on the validity of test reports under the PPE Regulation

March 01, 2018

The European Coordination of Notified Bodies in the field of Personal Protective Equipment has proposed 57 new 'Recommendations for Use' (RfU) sheets in support of the PPE Regulation (EU) 2016/425. RfU are technical sheets for coordination of a common position of the Notified Bodies on PPE regulatory issues. Upon approval by the PPE Working Group, RfUs are published on the European Commission website

SME Safety would like to express comments on the draft RfU PPE-R/00.057. Such RfU is about the validity duration of test reports. The document aims at clarifying the maximum time from the date of issuing of a replica watches test report for its use in a new EU type-examination certificate, proposing a limit of 5 years for the validity of test reports.

SME Safety is seriously concerned that limiting the duration of tests validity will cause unnecessary costs for small manufacturers, while not having an actual positive impact on the safety of products. It should be noted that the PPE Regulation introduced a limit of 5 years to the validity of EU type-examination certificates. However, this does not in any way affect the limit of validity of test reports, whose maximum time of validity is not defined by the PPE Regulation. It is clear that if the product has not been changed by the manufacturer and if the relevant requirements in the applicable standards have not changed, test reports shall remain valid. 

Read here our full position.

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