Reflective products and their marketing
If a product is intended to signal the presence of the user with its visibility or if the information provided in its marketing can give such impression, the product is considered personal protective equipment and it is subject to the requirements imposed on personal protective equipment in the relevant legislation.
Reflective materials are often used in outdoor clothing. The marketing of items of clothing such as knit hat and jackets may give the consumer the impression that the reflective material on the item could replace an appropriate reflector or a reflective vest; for example:
- “the jacket has a reflective print that improves safety in the dark”
- “a reflective tape increasing visibility has been attached to the outdoor outfit”
- “the reflective pattern acts as a reflector in the dark”
- “a knit hat with a reflector”.
Reflective products that do not constitute personal protective equipment
Personal protective equipment (PPE) refers to devices designed and manufactured to be worn or held by a person for protection against one or more risks to that person's health or safety. Information on the requirements for PPE can be found on page Requirements for personal protective equipment.
Items of clothing intended for personal use, such as headwear, seasonal clothing and footwear with reflective or fluorescent parts added as decoration are not considered PPE. Handmade products intended for decorative use that are not claimed to protect or increase the visibility of persons in the dark are not considered PPE, either.
Marketing reflective products
Clothing and equipment intended to signal the presence of the user with their visibility, such as reflective vests and reflectors for pedestrians, are considered PPE.
A product must comply with the relevant legal requirements if
- the product is sold as reflective clothing or equipment, or
- it is marketed for use as PPE, or
- the information provided on the product can give the impression that the product could be used as a reflector.
The marketing material must not provide conflicting information on the product’s purpose of use.
If a reflective product does not fulfil the requirements for PPE, consumers must not be given the false impression that such a product would constitute PPE. An item of clothing with reflective material may increase the visibility of a person, but a pedestrian should also use an appropriate reflector or reflective vest with a CE marking that fulfils the requirements for PPE while on a road in the dark.
The product descriptions of clothing with decorative reflective parts must not include claims about protective characteristics, such as “the reflective pattern on the product acts as a reflector”, “the product increases the visibility of a person” or “safety in the dark”, and the description must not imply in any other way that the product could be suitable for use as PPE.
If the marketing states that the reflective material on the item of clothing has been tested by a testing institute, it could create an impression that the product would increase the visibility of a person in the dark. In that case, the product information must clearly state that the product is not intended for use as PPE and that the consumer must also use an appropriate reflector or a reflective vest.
