CE marking on hearing protection: category III explained

Why category III?

Regulation (EU) 2016/425 on personal protective equipment sorts PPE into categories. Category III covers risks that may cause very serious consequences such as death or irreversible damage to health. Annex I expressly lists “harmful noise” there. DGUV Rule 112-194 (section 3.1) therefore assigns hearing protectors to risk category III.

Conformity assessment

For category III, Article 19 of the Regulation requires an EU type-examination (module B) by a notified body. It is followed either by conformity to type based on internal production control plus supervised product checks at random intervals (module C2) or by conformity to type based on quality assurance of the production process (module D). The notified body supervises production on an ongoing basis. EC type-examination certificates under the earlier Directive 89/686/EEC could remain valid until 20 April 2023 at the latest.

How to recognise a conforming product

When the identification number follows the CE marking

According to the Commission’s Blue Guide (section 4.5.1.5), the identification number of a notified body follows the CE marking only if the body is involved in the production phase, for example under module C2 or D. The number of a body that only examines the design (module B) does not follow the CE marking by itself. Because category III always adds supervision of production, hearing protection should carry an identification number after the CE marking. It tells you which body supervises ongoing production and can be looked up in the NANDO database.

Checking the notified body in NANDO

The European Commission publishes the lists of notified bodies in the NANDO database (New Approach Notified and Designated Organisations). It can be searched by legislation, country, body number and keyword and is updated continuously (Blue Guide, section 5.3.3). A body number is assigned only once and is not reused. If a notification is suspended or withdrawn, its details stay in the database, in a separate section for withdrawn or expired notifications.

An example: entering body number 2777 in NANDO returns satra Technology Europe Ltd, Bracetown Business Park, Clonee, Dublin 15, Ireland. Under Regulation (EU) 2016/425 it is listed there for, among others, “Equipment providing hearing protection” and “Protective Equipment against harmful noise”, in each case with EU type-examination (annex V), quality assurance of the production process (annex VIII) and supervised product checks at random intervals (annex VII). Those are the procedures under modules B, D and C2. Viewed on 18 October 2026.

Warning from the Commission: certificates of conformity for harmonised products may only be issued by notified bodies, and only within their area of notification. So-called voluntary certificates from other bodies do not prove conformity under EU law and have no value in checks by market surveillance authorities and customs. A CE marking on the certificate itself is not acceptable. Source: notice on the NANDO page.

The EU declaration of conformity: the manufacturer’s duties

The manufacturer draws up and signs the EU declaration of conformity before the product is placed on the market. With it the manufacturer takes responsibility for conformity. It keeps it, like the technical documentation, for ten years from placing on the market (Regulation (EU) 2016/425, Article 8(3)) and keeps it up to date at all times (Article 15). According to the Blue Guide (section 4.4), it needs a new version for products placed on the market afterwards as soon as one of its elements changes, for example the legislation, the version of a harmonised standard or the manufacturer’s contact details. What that means for a new address is set out in New company address: is the certificate still valid?.

Example: EarProtect

The EarProtect hearing protectors have been type-examined by SATRA Technology Europe (notified body, identification number 2777). Declarations of conformity, user instructions and data sheets are on the data sheets page, the tested values under attenuation values. The underlying standard is explained in EN 352; how a certificate is structured is shown in Reading an EU type-examination certificate using the EP1227.

What this means for employers

• Under section 2 of the German PPE Use Ordinance, only PPE that conforms to Regulation (EU) 2016/425 may be used.
• For category III, DGUV Rule 112-194 (section 9.2) requires training with practical exercises before first use and at least once a year (training).
• When buying, check and file the declaration of conformity, the certificate and the user instructions.

Great Britain

For the Great Britain market the UK government publishes its own guidance on the UKCA marking and on the continued recognition of CE marking; see the link in the sources.