THE EUROPEAN PPE REGULATION AND WHAT THIS MEANS FOR RIDERS
With the introduction of the European standard for motorcycle garments, riders have the ability to see that a product has been independently tested and certified for sale within the European Union. This EU legislation is recognised as the most relevant, up to date test standard worldwide.
THE EU PPE REGULATION
Motorcycle clothing sold within the EU falls under the scope of a PPE regulation; meaning that any motorcycle garment intended to provide protection, is deemed as personal protective equipment (PPE). Therefore, these types of products should be tested by an independent and notified body against a set of standards; relevant to garments, gloves and boots.
CE MARKING
When purchasing any product within the EU ranging from motorcycle apparel, toys, cookware or electronics, you’ll have seen the CE marking affixed to a product. CE stands for ‘Conformité Européenne’ (French for European Conformity). This CE mark is a product’s declaration of compliance to an EU agreed standard (with input from relevant institutions) within the PPE umbrella; covering health, safety and environmental.
For example, the set of standards that govern the EU PPE of motorcycle garments for ‘leisure use’ is CE EN17092 of the 2016/425 regulation.
A EUROPEAN HARMONISED STANDARD
CE certification and the requirements within each standard are incredibly complex and it is no easy feat for each EU member state and their relevant organisations and institutions to agree on one universally accepted set of rules. To have this ‘harmonised’ standard to which throughout the EU the standards are recognised and agreed means that a garments intended use and level of protection is understood by riders. Despite being an EU legislation Merlin sees this as a globally recognised seal of approval for consumers. CE certificates have a life of five years from the time the product is certified or modified and the harmonised standard can be seen in the Official Journal of the European Commission.
WHAT ABOUT THE CE EN 13595 STANDARD
In 1989 the PPE directive 89/686/EEC was introduced and fully implemented in 1994. This directive though was not ‘harmonised’ and very much open to interpretation, which caused much confusion across the industry contrary to its intended purpose. Both brand manufacturers and notified bodies could not comply and agree to a harmonised set of rules and criteria which meant that the directive was universally dismissed.
This issue saw the creation of the CE EN 13595 as a harmonized PPE standard, working to keep all EU notified bodies testing against a specific set of standards, specific to a products’ intended use. The four elements described in the standard CE EN 13595 were only applied to professional use garments though (for example, dispatch riders or emergency services). Since most riders are leisure riders, the standard was essentially ignored by the industry.
THE SHAKEUP
The industry overlooked the CE EN 13595 standard due to its professional designation and as a result, very few garments on the market were CE certified using the EN 13595.
Merlin observed the recent discussions and actions taken by the WG9 (working group of stakeholders) in creating a provisional set of standards that reflected the requirements of products for leisure riders under a new regulation, EN 17092. This brand-new standard is broken down into three tiers depending on their use. Typically these are described as ‘sport’ (heavy-duty), ‘adventure’ (mid-weight) and ‘urban’ (lightweight) but technically are broken down in the standards as AAA, AA, A, respectively. So not only is there one standard for garments but now as a rider, you can take into consideration the type of riding that you will be doing, enabling a more considered purchase.
The reason for each level; track riders obviously have higher demands in the event of an accident when compared to urban commuters and it’s a fine balance between making sure safety is a top priority, but also that comfort, waterproofing, breathability and flexibility is taken into consideration, all while offering the protection best suited to the riding style.
Thanks to the introduction of this harmonised standard and regulation riders’ can now see that as of independent testing methods via a notified body, Merlin was backing up and proving its claims of producing high quality and durable apparel; meeting the latest safety standards across on-trend style collections, through its continual investment in research and development.
Put simply, with the application of the CE EN 17092 standard Merlin is proving that its range of products which in many cases looks like they have come off the high street, are highly protective and certified for sale within the European Union.
CE DOES NOT STOP WITH GARMENTS
Whilst there is a focus on the introduction of the latest CE standard for garments of recent, boots, gloves and body armour have their own relevant set of standards. Please note that boots are to meet standard EN13634:2017 (previously EN13634:2015) and gloves EN 13594:2015. The body armour of shoulders, elbows, knees and hip must meet standard EN 1621-1:2012 with back protectors meeting standard EN 1621-2:2014.
THE MERLIN PROCESS
Through extensive R&D our materials and components are assembled and pre-tested by external laboratories accredited to certify to the CE regulation 2016/425. This ensures that the quality and performance from a mechanical and chemical requirement is met across a broad range of materials, components and hardware. When it then comes to developing each product we can assemble using our pre-tested parts database, with a strong consideration to zonal placement (and the corresponding performance criteria required in each of these areas).
Focussing on the garment standard, there are three zones that are designated within the standard according to their risk of impact and where most damage will occur. Zone 1 is a high-risk area, Zone 2 is a moderate risk area and Zone 3 is a low-risk area. Therefore, we not only pay attention to the materials and parts but to how these are positioned within a product to provide the highest level of safety.
CE FINAL STEPS
The CE PPE regulation dictates that only notified bodies within the EU have the authority to certify a product, whether that be garments, boots, gloves or body armour. Merlin works closely with these notified bodies to rigorously test materials and components so that once all the in-house development, testing and fine-tuning has been completed, the notified body can conduct independent tests and certify the product and entire production chain.
A notified body is a third-party organisation that has been designated by an EU member state to assess whether a manufacturer meets the requirements set out in legislation.
Key to the certification process at a notified body is the requirement for vast amounts of data through a technical file provided by Merlin, to include amongst other aspects; manufacturing location(s), material sources, quality control processes, construction information, material data and visuals, seam constructions, image libraries and declarations. This technical file is then used by the notified body to cross-check and compare against the actual submitted product. Simply, a product is tested and it either conforms to the CE PPE regulation standard or it fails a certain classification.
CE-CERTIFIED GARMENTS BY EU LAW
With the introduction of this harmonised standard effectively in the future, all the motorcycle clothing available in European retailers will be CE certified and clothing developed before 2018 which did not have to be compliant will be sold through. Any clothing produced pre-2018 is not necessarily inferior or unsafe, but only that it was not submitted to an EU notified body for certification as there was no set of rules and regulations (harmonised) to test against.
Depending on the country you live in there are already minimum legal requirements of what you must wear whilst riding, such as a helmet or gloves. There is not currently a legal requirement to wear garments tested to CE EN 17092 and what you choose to wear on the bike is still your choice.
For more information on the UKCA mark which is a new product marking for goods to be placed on the market in Great Britain (following the UK leaving the EU) click here.