CE certification and PPE regulation explained

I would like to give an overview of the topic of personal protective equipment (PPE), the associated PPE regulation and the CE.

PPE and PPE Regulation

Any(!) clothing distributed by a manufacturer with a protective purpose falls under the 2018 renewed EU PPE Regulation (Regulation (EU) 2016/425) and is therefore extensively tested by an officially designated body according to strict specifications.

Here, I'd like to introduce you to the basic principles of CE certification and conformity and explain what they mean for you as a consumer. So you know what to look for when purchasing your equipment, whether in-store or online.

What does CE actually stand for?

You're probably familiar with the CE logo from many things you've purchased: children's toys, electrical appliances, cooking appliances, and much more. CE stands for "Conformité Européenne," French for European Conformity.

A CE label or CE marking on a product is a declaration of compliance with relevant or applicable health, safety, and environmental protection laws for products sold in the European Economic Area (EEA). The CE marking also applies to products sold outside the EEA that are manufactured in the EEA or manufactured for sale in the EEA.

How are CE standards and PPE related?

The connection is very significant. Manufacturers of protective equipment, like manufacturers of electrical equipment, must comply with certain rules and regulations depending on how these products are used and classified, and which group/subgroup they fall into. These categories are categorized according to Category III protection categories, which are completely independent of standards but are based solely on the hazard classifications of the PPE Regulation. Depending on the category, manufacturers may conduct the necessary tests themselves, or they must be carried out and certified by an independent "notified" (testing) body. Our fencing protective clothing always falls into Category II and must therefore be tested by a notified body.

• Category I covers only minor risks.
• Category II Includes risks not listed under Category I or Category III. Any PPE not covered by Category I and III is automatically Category II.
• Category III covers only risks that can lead to very serious consequences such as death or irreversible damage to health.

For certain areas, such as motorcycle protective clothing, there are specific, fixed specifications that have been agreed upon as a standard for this specific activity within the EU and laid down in a harmonized standard for the entire EU. In the area of ​​motorcycle protective clothing, for example, this is EN 17092. A harmonized standard means that it is recognized within the EU as a means of certifying PPE motorcycle clothing. For fencing as a martial art, this is EN 13567.

However, this article is not intended to provide legally binding information, but only a general overview of an incredibly complex topic that is both politically and economically charged. We want to make it clear that even an imperfect system like a CE certification label or CE marking means something. It indicates that a garment has been tested to meet at least a minimum level of safety requirements, so you actually know what the product is intended for. This is personal protective equipment with 800N puncture protection according to EN 13567, etc. Puncture-resistant protective clothing for fencing, and therefore also for historical fencing, is classified into category 2 or 3 depending on the product and the level of protection offered, and therefore must undergo more in-depth procedures and documentation to protect fencers/consumers. 

What if there is no norm for us?

For other areas, such as historical fencing, there may not be a specific standard. However, schools, clubs, and associations must still set safety requirements. To achieve these requirements, existing standards and their testing procedures are used. I work with my products entirely according to the principle of "best possible protection with best possible mobility." As developers and (co-)manufacturers, we therefore develop protection specifications that can provide the best possible protection in historical fencing. For example, our suits should provide the best possible protection in the area of ​​puncture resistance. The best possible EN standard with the associated testing procedures is EN 13567. This standard for fencing offers the highest quality testing procedure for puncture-resistant clothing, which is why it is also used for protective equipment for security forces. For other areas, such as throat protection, the standard for throat protection in ice hockey, with its testing procedures, can offer the best possible protection. You have to understand that most of these standards are simply collections of existing standards with their testing procedures, which are merely adapted.

EN 13567 for fencing also uses certain equipment and testing procedures, such as standards for hockey protective clothing and motorcycle protective clothing. These can be found there, for example, in genital protectors and chest protectors. 

I essentially do the same thing with my safety requirements and testing procedures, without having to write a new standard. I look for existing safety standards that can verify my requirements and safety promises for the equipment.

Time for new/better guidelines

While much of the industry largely ignored or overlooked existing regulations, for a long time there was virtually no way for consumers to know what protection a product actually offered. Many bought their clothing based on its appearance, feel, or questionable labels.

From the very beginning, it was important to me that my students and customers received the best possible protection so they could devote themselves to their hobby. Therefore, I began researching the necessary standards that could test and verify this. In addition, I found Uhlman Fencing, a partner with almost 80 years of experience in manufacturing protective clothing, who understands these high standards and can produce according to them.

The relevant standard for fencing jackets and trousers is therefore the one that also applies to Olympic fencing: EN 13567. To understand why this is the case, we will now introduce this standard.

EN 13567 presented

"Fencing, as a combat sport in which physical contact with the weapon outside of the protected zones occasionally (but usually not intentionally), occurs, is inherently dangerous. Protective clothing and equipment for fencers aim to prevent injuries as much as possible, or in the worst case, to minimize the severity of injuries, particularly those caused by the tip of the weapon.
Broken blades pose a particular threat. The circumstances of a blade breakage can lead to high tip speeds and high-energy impacts.
Broken blades are known to penetrate protective clothing, potentially with fatal consequences. There is no practical clothing that can withstand all the impacts of broken blades.
This standard takes into account the concept of "best possible level of protection". This concept means that the specified level of protection should be set as high as possible without making the wearer so uncomfortable or restricting movement during fencing that fencers do not use the protective clothing."

This is how the standard is introduced. The scope of the standard is also clearly described.

"This European Standard specifies the general requirements regarding ergonomics, size, circumference, and properties of protective clothing and equipment for fencing. The requirements for the marking of clothing and equipment and the manufacturer's information are specified. Test methods are described, and performance levels are defined."

One could also say that the basic idea behind the standard is tailor-made for us. Because historical fencing as a martial art is ultimately part of fencing as a martial art. And since there is no higher standard, it's the best there is.

Protective clothing is defined as "Clothing and special devices worn on the body, hands and legs, and over the face and neck, intended to reduce the severity of injuries caused by fencing weapons".

The standard describes how the protective zones on the body are classified, the performance levels, and the testing procedures applied for jackets, trousers, gloves, plastrons, and masks. It specifies where protection is provided, the performance levels (Level 1 350N, Level 2 800N), how these are tested, and represents the minimum level of protection. The main-related function of clothing is puncture protection. 

There is much more testing for your safety than you think!

However, the inspections and tests on the equipment don't just examine the materials. The finished product is also examined. Many more safety-relevant tests are performed, of which I would like to highlight the following.

Puncture resistance - Washed and dried fabric samples are cut out of the finished end product and then penetrated with a pointed spike simulating a broken pointed foil blade with a weight of at least 5 kg accelerated to a speed of 6-8 m/s.  

Seam strength – Seam strength is tested at structurally highly stressed areas, such as the sleeve-to-body connection. The force required to tear the seam is determined. 

There are a few other tests that must generally be met for protective clothing. 

EN 13567 as the basis for the specifications

It's important to note that the standard only provides a basis for the best possible protection. The responsibility for increasing and adapting protection rests with those responsible, namely clubs and national and international associations.

"As a guide, the following protection levels are suggested as suitable. However, the actual protection level suitable for each fencer depends on many factors, such as his weight, height, level of experience, and also the values ​​of his opponent, which cannot be determined by the manufacturer. The suitability of different protection levels may also be determined by opinions or regulations of a local, national, or international
Fencing organizations. In practice, it is the responsibility of the individual fencing associations to determine the performance levels they consider necessary for each fencing discipline, as well as the age and individual characteristics of the fencers. In some cases or for some products,
This may mean that it is necessary to wear a combination of Level 1 and Level 2 products, or two Level 2 products."

Currently, many historical fencing federations specify 350N as the stab protection level and only a few specify 800N. Since most national and international Olympic federations only consider 350N to be sufficient for children and there also 2 layers (jacket 350N + plastron 350N), I also consider this to be too low for adults in historical fencing. Together with my partners, I follow the high standards of the FIE federation for adults, which prescribes 800N jacket and trousers + 800N plastron.  

The zones and performance levels

The standard specifies the areas on the body that need to be protected and how jackets, trousers and undergarments must cover them. 

In addition, there are 2 performance levels, Level 1 (350N) and Level 2 (800N), which relate to puncture resistance. These two levels are generally Level 1 for children up to a maximum of 12 years and Level XNUMX for all older fencers depending on age and the forces involved. 

The fencing weapons used

The standard does not explicitly describe the characteristics of the weapons. It merely refers to the common fencing weapons: sabre, épée, and foil. When the standard was written, these were the common fencing weapons. The specifications for these weapons are set by the federations. The standard itself does not specify any specific fencing weapons, thus demonstrating that it is intended to be universal for the entire sport of fencing, rather than solely for the FIE's specifications. 

However, it can generally be said that the above-mentioned basic protection according to the standard is most effective when the weapons used in historical fencing adhere to the safety specifications of association weapons, such as the blade's stabbing flexibility. Here is an example of the flexibility test according to FIE regulations for a sabre, which I also use for my fencing weapons. The more uniform and safe the specifications for fencing weapons used in competitions are, the easier it is to establish the necessary protective specifications and to manufacture and certify equipment. 

What about impact protection?

Olympic fencing is also a combat sport that can certainly cause pain in the area of ​​impacts and strikes. However, this usually occurs when fencers behave incorrectly. EN 13567 only addresses impact protection in the chest and head area (mask), as this is considered acceptable and not relevant to injury in Olympic fencing with the associated fencing weapons. There are, of course, existing standards for testing impact protection, such as those in hockey or motorcycle racing. However, since safety in fencing is largely ensured by the safety of the weapon and the training of the fencers, who are expected to land a "sporting hit," the impact protection in our jackets and trousers is currently considered a comfort feature. The excellent padding built into our jackets and trousers absorbs energy to a certain comfortable level for the wearer. We have gathered extensive experience in this area. However, we have not yet tested it according to a standard, as there is currently no consensus on how much impact protection should be. If a value for minimum impact protection in certain zones is agreed upon in the future, our jackets and trousers will also be tested and certified according to the corresponding impact protection standards.

PPE tests are legally required!

In this bigger picture, it's important to note that all of this was created to protect you as a consumer. It's about your health. As soon as a manufacturer claims that a piece of equipment provides protection, it's considered protective equipment and must be tested and certified according to the PPE Regulation and applicable standards. Furthermore, the manufacturer/seller is obligated to provide proof of this with the relevant documentation. If your equipment doesn't have this, consider contacting your manufacturer/seller and requesting the documentation or returning the product.

Recognizing CE-certified clothing

Not everyone follows the rules. If you want to find out whether a piece of clothing, a protective gear, or a pair of gloves is actually CE-compliant, you should consider the following information. Part of CE compliance is correct labeling, and there are relatively easy ways to distinguish a fake label from a genuine one.

Every CE-certified garment/protector/glove you've purchased since April 2018 comes with a brochure explaining the product's certified protection class. This protection class is also indicated on markings or labels, along with the standards to which it was tested. Care and usage instructions are also included. 

Additionally, the brochure provides a website or contact address where you can request a DoC, the product's Declaration of Conformity, which you will then receive by email or post. If the product you're interested in isn't certified, there's no DoC; it's that simple. Want to know if the product you own is CE-compliant? Then ask your manufacturer/seller.

Isn’t there a need for a separate standard for historical fencing?

A new standard always makes sense when there are no existing standards. Furthermore, it is necessary that the same specifications apply, at least in the competition sector. Uniform properties of fencing weapons are particularly important in order to know the forces exerted. Currently, it would be perfectly sufficient if the associations' specifications linked the respective protection zones to the corresponding performance levels and any existing standards. As an example, I would like to draw on the neck guard, which in hockey, for example, already has to undergo very stringent testing for impact and shock protection. A standard would ultimately just list these specifications again.