Community news|03/04/19

PPE Regulations: transitional period and products in stock at the manufacturer

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The European Commission has published a guide on the transitional period between Directive 89/686/EEC and Regulation 2016/425 to recall the principles associated with the “placing on the market” and “making available on the market” of personal protective equipment (PPE).

This refers to the principles set out in the Blue Guide to help manufacturers understand how to manage their products in stock at the end of the transitional period between the two PPE regulations on 21 April 2019. The following elements are recalled: 

  • the “placing on the market” applies only to the manufacturer or importer;
  • the “placing on the market” and “making available on the market” are concepts that apply to each product individually;
  • the “placing on the market” is only possible if the product has actually been manufactured;
  • the “placing on the market” does not require a physical transfer of the product; it can therefore be carried out while the product is still in the manufacturer’s stocks;
  • the manufacturer or importer must have proof of the date of the “placing on the market” (e.g. date of dispatch of the product);
  • the manufacturer, by selling his products in stock to a legal entity responsible for distribution and belonging to the same group, places them on the market;
  • products that comply with the PPE Directive and are “placed on the market” before 21/04/2019 may be “made available on the market”.

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