Selling personal protective equipment manufactured for military purposes to consumers
Personal protective equipment (PPE) refers to devices, equipment and protective clothing designed to be worn or held by a person for protection against one or more risks to that person's health or safety. Personal protective equipment on the market must comply with European safety requirements. Military surplus stores and online stores market products manufactured for military purposes to be used as collector's items, decorative objects or props.
There are also unused and used PPE manufactured for military purposes on the market that do not fulfil the requirements for PPE. These items include, for example, body armours and helmets. Products intended for military purposes have not been designed or tested for the conditions and hazards against which the consumers use PPE. This means that PPE intended for military purposes has not been designed and manufactured in accordance with the requirements for PPE intended for consumer use.
For example, the use of old gas masks can have adverse effect on health because old masks do not necessarily fulfil the requirements given in the current chemicals legislation. Tests carried out elsewhere in the EU on World War II gas masks have revealed that, for example, the filters of such masks can contain asbestos fibres which are released into the air the user breathes. It is prohibited to asbestos fibres in the manufacturing of new products or place old products that contain asbestos fibres on the market.
Marketing personal protective equipment manufactured for military purposes as collector's items and decorative objects
If products are marketed for use as PPE, they must fulfil the requirements for PPE. Information on the requirements for PPE can be found on page Requirements for personal protective equipment (Personal protective equipment page on tukes.fi). If the seller cannot establish that the product fulfils the requirements for PPE, the seller must ensure that product-specific information and also other marketing, product presentation and the procedures for selling multiple items in a bundle are such that the risk of confusion is eliminated. For example, decorative objects and collector's items must be clearly separated from PPE in online stores.
The marketing material must not provide conflicting information on the product’s purpose of use and must not imply in any way that the product could be suitable for use as PPE. It is also prohibited to imply that the products sold as collector's items or decorative objects could possibly be used as PPE by marketing related accessories, such as replacement filters for gas masks or ballistic panels for body armours, together with the said products.
Similarity must not pose a risk
Consumers may have difficulties distinguishing between compliant PPE and products that resemble PPE but are intended as props, decorative objects, etc. The consumer's life or health may be in danger if he uses a product that resembles PPE in conditions that require the use of PPE.
When products that resemble PPE but that have some other purpose than to protect the user are sold to consumers, the following information must be clearly stated on the labelling and product information:
- the product does not constitute PPE
- product's intended purpose, i.e. other than to protect the user against risks, such as decorative object
- warning that the product does not protect its user and that the product must not be used in conditions that require the use of PPE
- the product must not bear the CE marking.
In addition to the information mentioned above, the product must be accompanied by all the necessary instructions and information.
Requirements for personal protective equipment
Products that are designed exclusively for military purposes or for use in the maintenance of law and order (such as police) are not considered PPE. This means that PPE originally manufactured for military purposes is not necessarily manufactured in accordance with the requirements for PPE intended for consumer or professional use.
However, if items of PPE originally designed for military purposes or for use in the maintenance of law and order (such as helmets and body armours) are sold or otherwise handed over to customers to be used as protectors (for example, in airsoft or paintball games), they must fulfil the requirements for PPE.
Second-hand and old personal protective equipment
The performance of PPE may deteriorate with use and due to the ageing of materials. A new user cannot know for sure how the previous owner has stored and used the PPE. For example, a helmet may look intact but its performance can be adversely affected or lost completely due to hard hits, wear and tear and exposure to bright sunlight. It is not advisable to acquire second-hand PPE.