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PPE: Type Review, Renewal and Production Surveillance
Follow the actual document and production procedure. A renewal invoice does not establish coverage of a changed design.
Separate the clocks and triggers
Annex V limits a newly issued or renewed EU type-examination certificate to no more than five years. Its actual expiry and conditions must be checked. Changes affecting conformity or validity conditions must be notified to the body holding the type file; do not wait for the expiry date to disclose them.
C2 requires supervised product checks at least annually at body-determined random intervals; D requires at least annual periodic audits and allows unexpected visits. These production controls are distinct from type review and the manufacturer’s ten-year documentation retention.
Case: changed webbing and a payment described as renewal
Hypothetically, a fall-arrest harness changes its webbing supplier while a production-surveillance invoice is described as renewing every model. Compare material specification, approved type, affected models/lots and production programme. Ask which change review and decision actually occurred; do not infer type approval from the payment or report date.
Maintain a change register, actual certificate/annexes, production-control reports and open corrective actions. Obtain the applicable issuer review and outcome before claiming a changed type is covered; do not backdate evidence or invent a completed audit.
Make the next action conditional
The manufacturer reports changes and maintains production conformity. The designated body determines the applicable review, assessment and document status. Renewal does not guarantee unlimited use of an item whose condition or instructions prohibit it.
For Kayra, define the requested tracking or enquiry activity and verify its permitted scope and independence. Provide the real modification and procedure rather than asking for an automatic annual all-product certificate.
Questions for this purpose
Does every PPE certificate last exactly five years?
The legal maximum concerns EU type-examination certificates; read the actual expiry and conditions.
Are C2 checks the same as renewing Module B?
No. Production checks and type review have distinct purposes and outputs.
May a design change wait until renewal?
Changes that may affect conformity or validity conditions require notification and applicable review.
Official sources
- EUR-Lex — PPE Regulation, consolidated text 29 May 2026
- European Commission — PPE scope and resources
- European Commission — PPE harmonised standards references
- European Commission — notified bodies and actual tasks
- EUR-Lex — original PPE Regulation reference
- Your Europe — technical documentation duties
- EUR-Lex — PPE Regulation reference
Related PPE guides
- PPE: Protective Claims, Risk Categories and CE Conformity
- PPE: Technical Documentation and Traceable Records
- PPE: Cost Inputs and an Evidence-Based Schedule
- PPE: Verifying Documents, Scope and Current Status
- PPE: Conformity Assessment and Evidence Closure
- PPE: When the Regulation Applies and Which Conditions Matter
- PPE Questions: Claims, Categories and Product Evidence
- 07PPE Scope and Key DifferencesOpen guide →
- PPE Application: From Product Inputs to the Required Route
- PPE: Manufacturer, Notified Body and Decision Roles
PPE enquiry: product, risk and requested activity
Send the certificate/annexes, change register and actual production programme to clarify the requested follow-up activity.