The parties, and what each is responsible for
Several organisations touch a PPE product on its way to market. It helps to be exact about what each one does, and does not, answer for.
- The manufacturer or brand owner. Responsible for the product itself: its conformity, its technical documentation, its declaration of conformity, its marking, control of changes, and corrective action. It applies even when a factory designed and made it. Put your name on someone else’s product and you usually become the manufacturer in law, with every duty above.
- The authorised representative. Can carry out specified tasks for the manufacturer under a written mandate. The mandate covers what it says it covers. It does not move every manufacturer duty across.
- The importer. Checks, before placing the product on the market, that the conformity assessment, technical documentation, marking, instructions, Declaration of Conformity and manufacturer identity are all in place. Keeps records of those checks, and has to act where there is reason to believe a product is non-compliant or unsafe.
- The distributor, retailer or marketplace seller. Checks the product carries its marking and required information, and must not knowingly supply it where those are missing or visibly wrong. Also responsible for storage and transport not compromising its conformity. A business may take on manufacturer duties if it own-brands or modifies the PPE in a way that may affect conformity. Marketplaces may also require evidence before allowing a listing.
- The test house. Responsible for performing the tests requested, accurately, on the sample it was sent. Its responsibilities depend on the agreed service and applicable requirements. Agree test selection and sample suitability explicitly. A test report is a record of test activity and results. It is not a certificate, and it is not permission to place the product on the market.
- The certification body. Responsible for its independent conformity assessment within its authorised scope. Type examination includes the technical documentation and a representative specimen. The manufacturer keeps responsibility for the product itself, for production matching what was assessed, for the information supplied with it, and for any change made after assessment.
- The authorities. In Great Britain: the Health and Safety Executive (HSE) for workplace PPE, local Trading Standards for consumer PPE, and the Office for Product Safety and Standards (OPSS) for product-safety activity. They check products already on sale and can act where evidence is missing or a product falls short. The British Safety Industry Federation (BSIF) is a trade body, not a regulator.
For completeness: Trace is not on that list. I do not sell PPE, issue certificates, replace a test house or a certification body, or act as a regulator. I organise the evidence and coordinate the testing and certification on your side of it.
Agree who makes the handover
Testing and certification have different responsibilities, even within one organisation. They can communicate and coordinate work while preserving impartiality. Agree who sends the reports, who submits the documentation and who answers findings. Do not assume the next stage starts automatically. Read what happens when nobody moves.
What responsibility looks like after launch
Responsibility does not end at the first shipment. The brand controls changes to the product, and a change to a layer, a panel or a supplier can put the product outside the evidence that supports it. The brand also monitors complaints and incidents, and decides whether to correct, hold or stop supply. You can commission support, but the manufacturer’s responsibility remains.
If the technical file is held by the factory or the test house rather than by you, that gap is still yours to close.
Sources and further reading
For the legal requirements and their application, see the PPE Regulation (EU) 2016/425, the European Commission's PPE guidance and the GB PPE guidance.
