A message from General Manager Cofra Srl, Giuseppe Cortellino:
I am writing to you as the Managing Director of Cofra S.r.l., a company that manufactures and distributes Personal Protective Equipment.
As I already did in 2018 and again in June 2022, I would like to underline the difficulties that my company, and I think all companies, are forced to face after the decision to establish a five-year duration for EU examination certificates, as stated in Annex V, paragraph 6.1 of Regulation (EU) 2016/425 of the PPE (Personal Protective Equipment) sector.
The lifetime of Personal Protective Equipment does not exceed 10 years, from market entry, peak of the sales and exit. The natural course of the product’s life is also due, among others, to factors such as technical innovation and the style of products, which nowadays follow the modern trends of the safety sector. I would like to underline that our decades-long experience allows us to declare that the average life of PPE is 7/8 years at most; for this reason, the ideal duration of EU type examination certificates would be 10 years. In the absence of changes to the Regulation or to the products, certifying again after 5 years in the midst of the waning phase of a product’s life, is a waste of resources that can only fall on (companies and) end-user costs. Hundreds of re-certifications are currently in progress, which are causing problems for the laboratories in the first place, which cannot issue certificates quickly because they are overwhelmed with models to be certified again, and for my company in the second place, with disproportionate costs and pressing customers who continually ask for updates in this regard. But re-certifying the products close to the deadline and receiving all the certificates in short time is impossible! Authorized laboratories can’t do it!
Re-certifying all these products has only generated chaos in areas such as:
- Production: companies are forced to stop production and sales of expiring items, waiting for the re-
- Customers: they cannot get all the certificates in the expected time
- Internal organization
- Unnecessary waste of money, new samples leading to the interruption of production, re -certification
What is the benefit of all this? Who has benefited from this change? Who decided to implement this new regulation?
Therefore, I invite everyone once again to revise the Regulation (EU) 2016/425, in the above-mentioned points, by changing the duration of EU-type examination certificates from 5 to 10 years, without prejudice to the re-certification requirement in case of changes to the Regulation or to the products.
I am certain that my request will be carefully examinated, both to reduce costs for consumers and to lighten the bureaucracy for businesses.
The perception between us professionals is that, to date, we are witnessing a significant waste of efforts, for the sole benefit of the certification laboratories!
Since I already wrote a letter several years ago with the same remarks to all organizations and bodies to whom this letter is addressed, I hope that some of you will deign to reply, even though you are busy with your numerous tasks; and above all will take a moment to reflect on the reason for this unnecessary increase in costs.
Who benefits from this situation?
The only ones who will pay will be the CITIZENS CONSUMERS WORKERS. Awaiting your kind reply, with observance.