After PPE Regulation (EU) 2016/425, as a successor of the familiar PPE Directive 89/686/EC, came into force, there seems to be a run on renewed type examination certificates. Even in the cases where the manufacturer has brought a recently certified product onto the market, many customers require that these products are delivered with a 'new' certificate.
Notified bodies, which already have the greatest difficulty to implement the recent legal changes in their procedures, will encounter even more backlog. It is therefore not surprising that there are major delays in the certification process.
The question that arises is whether this run on new certificates, as a result of the pressure imposed on manufacturers by manufacturers, is justified.
European guidelines have already been issued from European organizations for the current transposition period. And only for personal protective equipment of which there are relevant changes to the essential safety and health requirements or for which one of the applicable harmonized standards has been changed, must be re-certified before April 21, 2019.
In all other cases, and for protective clothing this is usually the case, there is no need for a quick re-certification unless the current certificate has an expiry date until 21 April 2019 at the latest.
Because the main manufacturers of protective clothing keep up-to-date certificates for their products, in most cases the products prove to be certified well after April 2019.
In this situation, manufacturers are allowed to deliver on the basis of these 'old' certificates and it is not mandatory to re-certify now. However, they must bring the product marking, user information and declaration of conformity of the relevant products in line with the requirements of the PPE Regulation before 21 April 2019.
The run on new certificates for protective clothing is strictly speaking not necessary in most cases and manufacturers can, after adjustment of the product marking, user information and declaration of conformity, continue to deliver their products in accordance with the law up to the expiry date of the certificate.
That period also appears to be really necessary in order to give the Notified bodies the opportunity to eliminate the backlog and to implement the new procedures optimally.