The Personal Protective Equipment Regulation covers the design, manufacture, and marketing of personal protective equipment (PPE) sold in the European Union. PPE protects people against risks related to their safety and health, including risks at work, home, or during leisure activities. Typically, climbing equipment falls under this Regulation.
Risk categories of climbing equipment
The PPE Regulation classifies the risks associated with personal protective equipment into three categories, from the lowest (category 1) to the highest (category 3). Most climbing equipment protects from major or deadly hazards. Therefore, the risks climbing equipment protects from usually fall under the third category, as this category includes risks relating to falling from a height.
Climbing equipment such as harnesses, ropes, belay devices, carabiners, ice axes, ascenders, pulleys, and similar require the involvement of a third-party conformity assessment body, namely notified body. Based on the product type, there are different conformity assessment procedures to follow.
Conformity assessment of harnesses, ropes, and belay devices
Harnesses, ropes, and belay devices – such as a grigri – used to climb are subject to two conformity assessment routes:
- EU type examination performed by a notified body, which verifies the product’s technical design and assesses that it meets the safety requirements.
- a) Internal production control plus supervised product checks at random intervals, self-declaring the conformity of the PPE.
b) Quality assurance of the production process.
Among the technical documentation accompanying a PPE product, manufacturer must provide a Declaration of Conformity (DoC) stating the conformity assessment routes the product was subject to.
Standards for climbing equipment
Manufacturers of climbing equipment can use harmonised standards as a presumption of conformity with the Regulation. In addition to the required certification, different standards can apply to such products. The standardisation organisations covering PPE are the European Committee for Standardization (CEN) and the European Committee for Electrotechnical Standardization (CENELEC).
For instance, manufacturers of anchor devices can use EN 795:2012, while EN 12277:2015 can be used for harnesses. For ropes, EN 17109:2020 can be applied for individual safety systems for rope courses, whereas manufacturers of accessory cords can use EN 564:2023.
Compliance with the PPE Regulation
In light of the regulatory complexity, manufacturers of PPE are highly advised to appoint an authorised representative (EAR). Among others, an EAR cooperates with competent authorities, keeps the documentation available for inspections, and collaborates in eliminating or mitigating any risks related to the product. An EAR also helps manufacturers compile compliant documentation and checks the conformity of their file.
Lastly, the Market Surveillance Regulation imposes that PPE manufacturers must have at least one economic operator based in the EU. If the importer does not overtake the responsibilities of the EAR, the manufacturer must appoint an authorised representative.
European Commission. (2016). Regulation (EU) 2016/425 of the European Parliament and of the Council of 9 March 2016 on personal protective equipment and repealing Council Directive 89/686/EEC. Retrieved on 30/03/2023.