With personal protective equipment, a close look is worthwhile. What matters is which change lies behind the new address and how it was documented with the responsible certification body.
Is a certificate with an old address automatically invalid?
A differing address alone does not allow a reliable statement about validity. The testing and certification regulations of DGUV Test distinguish between changes that must be reported and grounds for a certificate becoming invalid. Changes of address must be reported without delay; the certificate is not meant to lapse automatically because of a change of address alone. The conditions of the issuing body remain decisive. Source: DGUV Principle 300-003, sections 3.2 and 3.6 (German).
In practice: have a differing address explained in a way you can follow. Where necessary, request the updated certificate or a confirmation from the issuing body for the specific certificate.
What does the address on a PPE certificate mean?
An EU type-examination certificate documents the assessment of a specific PPE type by a notified body. Its mandatory details include the manufacturer and its address, the identification of the PPE and the expiry date. For an example of how such a certificate is laid out, see the certificate for HI561 and HI561S.
The EU declaration of conformity is a different thing: with it, the manufacturer takes responsibility for the PPE meeting the applicable requirements. It must be kept up to date. Certificate and declaration of conformity therefore serve different purposes. Source: Regulation (EU) 2016/425, Article 15 and Annex V.
Company move, relocated production or a new manufacturer?
Three situations should be kept apart:
- New administrative or contact address: It needs to be clarified how the changed details are recorded with the certification body and how the affected documents are updated.
- Relocation of production: Additional assessments or a visit to the new production site may be required. DGUV Test requires notification without delay.
- Change of company or certificate holder: A transfer must not be assumed. DGUV Test certificates are tied to their holder and, for product certificates, also to the tested product.
This distinction stops different kinds of change from being treated merely as a “new address”. Source: DGUV Principle 300-003, sections 3.2 and 3.5 (German).
Which documents should be checked after a change of address?
It makes sense to compare the certificate, EU declaration of conformity, manufacturer information and product marking together. It should be clear which company is responsible for which product.
The contact details on the product also matter: the manufacturer must give a postal address at which it can be reached on the PPE. If that is not possible, it may appear on the packaging or in the accompanying documents. Source: Regulation (EU) 2016/425, Article 8(6). What else appears on the glove is explained in Reading the marking on a glove.
A general letter about a move can explain a difference in address. As evidence of the status of a specific certificate, however, you should ask for a clearly assigned statement.
What the European Commission's Blue Guide says
The Blue Guide is the European Commission's guidance on EU product rules (Notice 2022/C 247/01). It has no legal force; only the legal act itself is binding. Three passages help with questions of address:
- Address on the product: The manufacturer's name and address are a basic traceability detail. They appear on the product or, where that is not possible, on the packaging or in an accompanying document, and the address must name a single point at which the manufacturer can be contacted. Source: Blue Guide, section 4.2.2.
- Declaration of conformity: It applies per product and must be kept up to date. If one of its elements changes, for example the manufacturer's contact details, the version must be updated for products placed on the market afterwards. It is kept for ten years from placing on the market. Source: Blue Guide, section 4.4.
- Allocating the certificate: The manufacturer who places the product on the market bears full responsibility for the conformity assessment. It must hold the certificates, but the EU type-examination certificate does not have to be in its name. What matters is that the certificate can be allocated to the product without any doubt. Source: Blue Guide, section 5.1.5.
A different holder on the certificate is therefore not a defect in itself. What remains open is whether the link to the product and the responsibility of the party placing it on the market are clearly documented.
How to check evidence with a differing address
For purchasing and quality assurance, we recommend this sequence:
- Match the product: Compare the model designation and article details with the documents you hold.
- Identify the certificate: Note the certificate number, the issuing body and the document version. The notified body's number (2777 for SATRA) can be looked up in the NANDO database: Checking a notified body.
- Clarify the difference in address: Ask whether only the address changed or also the manufacturer, production or company structure.
- Have the current status confirmed: Ask for the current version and, where appropriate, written confirmation from the certification body.
- Document the outcome: Keep the reply together with the product-related evidence.
For DGUV Test certificates, the public DGUV Test certificate search offers an additional check. Among other things, you can search by certificate number. The Hi5 certificate for HI561 and HI561S comes from SATRA; here the number 2777/14815-05/E79-01 is the reference point for queries.
Questions about Hi5 documents?
Have you received a product document with a different address, or do you need documents for your internal check? Send us the article designation, the certificate number and, if possible, the document concerned. That lets us match your enquiry clearly to the product and the evidence in front of you. The documents we hold are under Data sheets and Certificates; we send further ones on request.
This article offers guidance and is not legal advice. The conditions of the issuing body and the wording of the regulation are binding.
