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European Safety Federation

ESF

The European Safety Federation promotes workplace health and safety through legislation and standardization of personal protective equipment.

Lobbying Activity

Meeting with Piotr Müller (Member of the European Parliament) and 3M

27 Jan 2026 · Omnibus Digitalisation & Common Specifications

European Safety Federation Urges Simplified Rules for Medical PPE

6 Oct 2025
Topic — This initiative evaluates EU medical device rules to improve safety and sector competitiveness.
Message — The federation calls for proportionate rules for products like surgical masks and gloves. They argue that current clinical evaluation obligations for these items are disproportionate. They also seek alignment between medical device and protective equipment digitisation rules.12
Why — Reducing clinical testing for basic products would significantly lower business compliance costs.3
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European Safety Federation Urges Digital-First Rules for Safety Equipment

3 Sept 2025
Topic — The regulation aligns product legislation with digital technologies through increased electronic documentation.
Message — The federation requests removing the distinction between professional and consumer users to allow digital-only instructions. They also seek clearer definitions for machine-readable codes and consistent terminology across EU laws.123
Why — Manufacturers would avoid the costs and logistical complexity of providing mandatory paper documents for consumer products.45
Impact — The single market faces fragmentation if national authorities apply inconsistent rules for consumer products.6
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

please find attached the feedback of the European Safety Federation (suppliers of Personal Protective Equipment).
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

5 Jun 2025 · PPE Seminar in Genval

Response to EU Strategy on medical countermeasures

9 May 2025

The European Safety Federation (ESF), as representative organisation of suppliers of Personal Protective Equipment (PPE) for professional use, is a member of the JICF of HERA, and as such has shared views on the topic of this consultation at several occasions. We appreciate these possibilities and will continue to cooperate both in JICF and in individual conversations with the relevant EC services, in order to further improve the preparedness of the EU in any type of crisis, including public health threats.
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Response to Communication on the EU Stockpiling Strategy

9 May 2025

The European Safety Federation (ESF) welcomes the Commissions initiative to develop an EU stockpiling strategy as one of the elements of crisis preparedness. Personal Protective Equipment (PPE) should be central in the EU stockpiling strategy: PPE are essential for protecting individuals from safety and health hazards, including infectious diseases and chemical exposures. In emergencies, such as pandemics or natural disasters, having a stockpile of PPE ensures that first responders, military personnel, healthcare workers and the general public can be protected. Basic PPE for health hazards (such as respirators / FPP2 masks, gloves), should be included in any EU recommendation and initiative for stockpiling and for 72-hour survival kit. Indeed the COVID-19 crisis learned that the EU has vulnerabilities concerning availability of crisis relevant products. As representative organisation of suppliers of PPE for professional use, we want to stress the importance of the availability of the correct and compliant PPE in any type of crisis which requires protection of individuals. At the same time, we want to draw the attention to the need for continuous training of those persons that will need to use the PPE during a crisis situation, so correct use of the PPE can be guaranteed. All too often we have seen PPE for which there were shortages being non-compliant or used incorrectly, making them at best less effective or even worse, completely useless to protect the wearer. Knowing how and when to use specific types of PPE is essential for the success of any crisis preparedness, and therefore we strongly recommend to include the need for training of decision makers as well as users of PPE in the stockpiling strategy. Any EU stockpiling and procurement initiatives should put at its core compliance and product quality. After Covid pandemic, the European Commission released a report on PPE compliance, specifically looking at those respirators used during the pandemic. The report revealed that 85% PPE face masks (i.e. FFP1, FFP2 and FFP3) did not meet the EU health and safety requirements for total inward leakage and penetration of the filter material (link to the report: https://ec.europa.eu/safety-gate/#/screen/pages/casp2020Corona). The quality of the PPE should also be assessed with respect to their durability and shelf-life to avoid waste and to use resources efficiently. In function of the type of product, different (combination of) options need to be possible : pure stockpiling (buy product and put it somewhere in a warehouse till needed), dynamic stockpiling (agreements with economic operators to keep minimum levels of stock that are managed, so that the available PPE are at all times in correct fit-for-use condition (meaning not expired and maintained when necessary)), management of supply chains (meaning quick deliveries from sources available during crisis possible, including raw materials and transport), or any other suitable option. , ). Careful selection of PPE necessary and the most suitable stockpiling option, depending on the type of PPE, is essential for the success of the strategy. Therefore, we believe cooperation with industry representative organisations to define priorities as well as requirements for recommendations of specific products (including compliance, quality, sustainability, maintenance) is very important and even essential. Avoiding duplication of stockpiles in EU, at member states and on regional level must be avoided. Therefore, all levels must be involved in the preparation of the strategy, and even more important, all levels must follow this strategy. For that reason, it must also be defined which entities will have access to the stockpiles and how the functioning will be in times of crisis.
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Meeting with Anna Athanasopoulou (Director Internal Market, Industry, Entrepreneurship and SMEs)

15 Apr 2025 · Meeting with European Safety Federation on Simplification

Response to Permanent anchor devices and safety hooks – applicable thresholds and classes

31 Jul 2024

The European Safety Federation (ESF) welcomes the publication of the standard EN 17235:2024 and the related draft delegated regulation under Regulation (EU) No 305/2011. It is an important step towards improving the safety of users of personal protective equipment against falls from a height, for which the permanent anchor devices are an essential element. The adoption will improve workers safety and support the development of high-quality products across the EU. This draft delegated regulation is important to ensure that safety hooks and anchor devices, meet high safety standards. Given that these products are used with personal fall protection systems, having stringent safety measures in place is essential for helping preventing injuries and fatalities. The legislative draft ensures that the design and testing of these products are robust enough to withstand the demands of real-world use, significantly reducing the risk of failure and enhancing overall workplace safety. The draft clearly defines different levels of performance for safety devices. By setting specific classes based on mechanical resistance, it helps manufacturers and users know exactly what standards products need to meet. The new standard EN 17235:2024 was developed based on input from experts representing different stakeholders, including voting in different stages of the development of the document. It clearly addresses market needs. This ensures that the products are not only safe but also practical and effective for users. Including the harmonised standard EN 17235:2024 on permanent anchor devices and safety hooks in the Official Journal of the European Union ensures that all EU countries follow the same rules. This consistency helps to improve safety, facilitates trade, and supports fair competition across Europe, which are the cornerstones of the Single Market.
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European Safety Federation urges consistent terminology for protective equipment

23 Jan 2024
Topic — Revision of EU rules protecting workers from exposure to carcinogens and mutagens.
Message — The federation suggests using 'Personal Protective Equipment' consistently throughout the text. This aligns terminology with existing EU regulations to prevent conflicting interpretations.12
Why — Uniform terminology provides legal certainty for the equipment manufacturers and suppliers.3
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Nov 2023

the European Safety Federation wants to express some concerns about the current proposal. Some proposed amendments in the EU Parliament already respond partially to our concerns. More clarification on the scope (only consumer products are also technical / professional products ? The CN codes in the annex are not suitable to define the scope as the range of products covered by the CN codes is too wide. See attached full document with additional explanation on the above.
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Response to Revision of EU rules on textile labelling

29 Sept 2023

see attached document
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European Safety Federation urges simple green claim rules for SMEs

21 Jul 2023
Topic — Consultation on requiring companies to substantiate environmental claims using specific footprint methods.
Message — ESF stresses the importance of harmonizing environmental measurement rules across the EU and globally. They request that authorities provide practical tools and keep systems simple for small businesses. Finally, they advocate for enforcement to ensure a level playing field.123
Why — Keeping rules simple prevents small businesses from being disadvantaged compared to large corporations.4
Impact — Companies from third countries would lose their ability to sell products without verification.5
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European Safety Federation seeks safety-specific rules for protective packaging

24 Apr 2023
Topic — The European Commission is reviewing rules to reduce packaging waste and increase recycling.
Message — The federation wants safety equipment packaging classified as contact sensitive. They also request harmonized EU labels and longer transition periods.12
Why — This would reduce regulatory costs and prevent the loss of product stock.3
Impact — National governments lose the power to set distinct environmental labeling systems.4
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Response to Single Market Emergency Instrument (SMEI)

13 Jan 2023

please find feedback from the European Safety Federation (ESF) in attached document.
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European Safety Federation urges mandatory respirator fit testing

1 Dec 2022
Topic — Revision of EU directive protecting workers from health risks of asbestos exposure.
Message — The federation calls for mandatory respiratory face fit testing and specialized training for those using protective gear. They urge lawmakers to provide incentives and time for industry to adapt to new limits.12
Why — Stricter safety mandates will increase sales of high-quality protective equipment and specialized training services.3
Impact — Building owners face rising costs, potentially leading them to bypass certified removal specialists to save money.4
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European Safety Federation seeks specific codes for protective equipment

19 Sept 2022
Topic — The European Commission is revising customs rules to improve risk management and e-commerce.
Message — The federation recommends updating customs codes for personal protective equipment to reflect current innovations. They suggest linking codes to product legislation to improve data collection and surveillance. The group urges for global harmonization and collaboration with industry sectors on specific codes.123
Why — Precise codes would reduce administrative burdens and prevent legitimate products from being wrongly blocked.4
Impact — Consumers and compliant businesses lose when non-compliant products enter the market via vague codes.5
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Response to Review of the Construction Products Regulation

12 Jul 2022

The European Safety Federation welcomes this initiative of the European Commission to further improve the legislation of construction products, including sustainability and recognizing delays in the European standard development system and OJEU citation. While reviewing the CPR, we wish the EU legislators to consider the following: • Some products included in the scope of the construction product regulation are destined to be used with Personal Protective Equipment (PPE) as defined in Regulation (EU)2016/425. This is specifically the case for protection against falls from a height where the fixed anchor points are in the CPR. In this case, the PPE is, as protecting against a mortal risk, in the highest category, thus conformity assessment (module B + module C2 or D) by a Notified Body. As the weakest link defines the protection, it is important that those construction products are suitable to be used with the PPE under the foreseeable use conditions. Therefore, we urge the legislators to ensure that for those specific products, technical requirements can only be provided in European Standards developed by a recognised European Standardisation Organisation (ESO). This while making sure there is coordination between the respective Technical Committees to guarantee that the standards for the different parts of the complete protective system are adjusted to one another. • More general : ensure that standard development is up to speed, transparent and led by Technical Committees at ESOs to guarantee a common technical language and industry participation. The current European standardisation system is transparent, based on consensus between all stakeholders as well as on clear processes and criteria for the development and publication of harmonized technical standards. Mirroring the CEN and CENELEC process by empowering the European Commission to adopt delegated acts containing technical specifications might be inefficient and harm the balance and transparency of the existing process, while not addressing the critical cause of the delay. Additionally, harmonized standards provide a common language to be used by manufacturers to express the technical performance of their products and by regulators to express their requirements, which is recognized and valued worldwide, therefore it shall be protected. The European standardisation system promotes EU global leadership in competitiveness and consumer and worker safety, which is also reflected in the EU Standardisation Strategy. EU institutions must ensure that the system does not fall behind. An increasing use of alternative route for standardisation, can ultimately harm EU interests. • Still looking at standard development and citation in the OJEU, we call to keep the dialogue open with all involved stakeholders, on improving and speeding up citation of standards for the benefits of industry, consumers and workers and consider to develop EU guidance on standard development for construction products, e.g. rules on drafting and presentation of candidate harmonized standards, also using experiences with various issues identified by the Commission and HAS consultants. • We welcome the European Commission's commitment to improve the protection of health, safety and the environment, in line with the different initiatives on sustainability (e.g. Green Deal, Ecodesign, …). Nevertheless, looking at product requirements, the legislators must ensure a system of hierarchy based on functionality of products. While sustainability is very important, it should never get priority over the (protection of the) health and safety of consumers and (construction) workers. Health and safety performance of construction products must be prioritized in relation with other essential characteristics and requirements.
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Response to Procedures for the designation of Union testing facilities

30 Mar 2022

• the European Safety Federation welcomes the initiative to designate EU testing facilities to ensure the reliability and consistency of testing on behalf of Market Surveillance authorities. We strongly suggest to include the EU accreditation system set by Regulation (EC) No 765/2008 as a basis for recognizing testing laboratories for all product groups. Even if there is room for improvement for the accreditation process, it is a strong basis for providing reliable testing. • Additionally, existing European/international standards that enable laboratories to demonstrate a consistently high level of product testing should be considered in the designation procedure. At the same time, knowledge and use of sector agreements, such as Recommendation for Use sheets from Notified Body Coordination groups, need to be taken into account as part of the conditions. • The system of designated union testing facilities should not create unfair competition with existing private laboratories. Market surveillance authorities should always keep the possibility to contract private laboratories (irrespective of the ownership of the laboratory, as long as impartiality of results is guaranteed) for their testing needs. Of course, these private laboratories need to comply with the same rules, hence also the importance of accreditation as this is an excellent basis for comparison of quality of provided testing services.
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Response to Fight against counterfeiting

3 Mar 2022

As representative organisation of suppliers of Personal Protective Equipment, we are aware of multiple cases of counterfeit PPE in the strictest sense of the definition. This with higher volume A-brand products. However, certainly in times of the COVID-19 crisis, we saw a lot of products (specifically FFP masks, single-use protective gloves and clothing, as well as face shields) with markings that were ‘copied’ from compliant examples. Even if the brand is not copied, but markings such as CE-mark, number of the notified body, reference of the standard or performance levels are copied or falsified, this causes an important potential safety problem for the user, but also a loss of trust in the specific type of products as well as the need to deal with compliant manufacturers. A lack of market surveillance invites producers of non-compliant products to offer their products on the EU market with false or non-compliant claims that could directly and/or indirectly jeopardize the safety & health of users. This also leads to unfair competition as such products are typically offered at much lower prices. While in ‘normal’ times we would expect this type of products offered mainly through internet sales, during the crisis, they found easily their way into the EU market, even in large volumes bought by healthcare authorities (including national ministries) but also beyond. Due to the COVID-19 crisis, a lot of PPE have been sold through the internet, certainly to the general public, but also to professional users in need of equipment. If market surveillance in the regular supply chain is already poor, it is even worse in the online world. We do recognise that it is extremely difficult to do market surveillance in the online world, and therefore this should be tackled on EU level to be as effective as possible. Remarks from national market surveillance authorities such as “we can only act against websites with the extension of our own country”, give zero confidence to the industry or consumers. Issues on internet platforms offering PPE are even more difficult to tackle, but are certainly contributing to the raise of the number of non-compliant and/or unsafe products on the market. As usual, there are 2 sides to tackle the issue. And we believe both need to be tackled indeed. On the one hand on the supply side, with strong market surveillance. And on the other hand on the demand side, by clear information campaigns, not only to the consumers, but also to the professional users and influencers (for instance, healthcare experts are not experts in PPE, even if they give the impression they are). We strongly urge the EU to work on this with the highest priority, and not only directly linked to IPR, but in a broader perspective of safety for all citizens in all situations, not only as consumers, but also in B2B and public purchases.
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Response to Standardisation Strategy

9 Aug 2021

see attached document
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Response to European Health Emergency Response Authority

22 Feb 2021

The idea of such an authority has its merits. However, lessons learned from the COVID-19 pandemic show clearly a lack of knowledge of all aspects (including EU law) by existing agencies and authorities (both EU and national member states). For this initiative to be effective it is essential that it is a multi-disciplinary authority (not only medical background, but e.g. also experts on PPE, on logistics, ...). Also cooperation with industry representatives (associations) is key to success. Sub-option 2.1 seems at this moment the best option.
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Response to Proposal for a Regulation establishing a European Centre for Disease Prevention and Control (ECDC)

2 Feb 2021

The European Safety Federation (ESF) welcomes the European Commission proposals on “European Medicines Agency – strengthened role to address public health emergencies”. Being the European organisation representing the Personal Protective Equipment (PPE) suppliers, ESF is very much pleased by the Commission’s intention to devote proper support to the European health system, especially with the unprecedented COVID-19 crisis we are facing since the beginning of 2020. However, bearing in mind the lessons learnt during the ongoing pandemic, ESF would like to drive the EU legislators’ attention to some aspects that should be reflected in the final Regulations to ensure a safe and operational European healthcare sector. Topics : - Crisis relevant products - Confusion Medical Devices and Personal Protective Equipment legislation - Need for training - Sustainable solutions - Cooperation with relevant industry experts Even the best performing healthcare system risks to fail if its workforce is understaffed or does not have the adequate protection readily available. PPE are a fundamental part of this protection and therefore must be properly included in any health crisis preparedness programme. See attached file for complete feedback.
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Response to Proposal for a Regulation on serious cross-border threats to health

2 Feb 2021

The European Safety Federation (ESF) welcomes the European Commission proposals on “European Medicines Agency – strengthened role to address public health emergencies”. Being the European organisation representing the Personal Protective Equipment (PPE) suppliers, ESF is very much pleased by the Commission’s intention to devote proper support to the European health system, especially with the unprecedented COVID-19 crisis we are facing since the beginning of 2020. However, bearing in mind the lessons learnt during the ongoing pandemic, ESF would like to drive the EU legislators’ attention to some aspects that should be reflected in the final Regulations to ensure a safe and operational European healthcare sector. Even the best performing healthcare system risks to fail if its workforce is understaffed or does not have the adequate protection readily available. PPE are a fundamental part of this protection and therefore must be properly included in any health crisis preparedness programme. See attached file for complete feedback.
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Response to Proposal for a Regulation on a Union framework addressing public health emergencies (EMA)

2 Feb 2021

The European Safety Federation (ESF) welcomes the European Commission proposals on “European Medicines Agency – strengthened role to address public health emergencies”. Being the European organisation representing the Personal Protective Equipment (PPE) suppliers, ESF is very much pleased by the Commission’s intention to devote proper support to the European health system, especially with the unprecedented COVID-19 crisis we are facing since the beginning of 2020. However, bearing in mind the lessons learnt during the ongoing pandemic, ESF would like to drive the EU legislators’ attention to some aspects that should be reflected in the final Regulations to ensure a safe and operational European healthcare sector. Even the best performing healthcare system risks to fail if its workforce is understaffed or does not have the adequate protection readily available. PPE are a fundamental part of this protection and therefore must be properly included in any health crisis preparedness programme. See attached file for complete feedback.
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