High visibility clothing and reflective tags

Product definition

High visibility clothing and reflective accessories such as tags and slap bands are products that are intended to increase the visibility of a user and thereby protect the person against being hit by cars under conditions with poor lighting, for instance in dark streets. When products are designed to provide protection to the user, they are usually regulated under the Regulation (EU) 2016/425 on personal protective equipment.

Personal Protective Equipment (PPE) are classified in three categories depending on the risk against which they protect. The appendix of the PPE Regulation Guidelines includes a guide for the categorization of PPE. PPE intended to protect the user under poor lighting conditions like for instance high visibility clothing and reflective accessories fall in category II.

Garments or gadgets with reflective properties where the reflective part solely serves decorative purposes are not considered to be PPE. Such products are in scope of the General Product Safety Regulation. Note, if the manufacturer claims that the reflective parts provide any kind of increased visibility, the garment or the accessory is always considered to be PPE, and consequently it must comply with the legal requirements in Regulation (EU) 2016/425.

When under the scope of Regulation (EU) 2016/415, high visibility clothing and reflective accessories are subject to mandatory conformity assessment by a notified body. More information on how to involve a notified body (a third party) can be found here.

The clothing is intended for children up to 14 years of age

If the garment is intended for children up to 14 years of age, it must also comply with the requirements for children’s clothing. More information can be found here.

Common risks of high visibility clothing and reflective accessories

The manufacturer shall carry out an assessment of the reflective garment or tab in order to identify the essential health and safety requirements from Annex II in the PPE regulation that apply to it. These will address the intrinsic safety of the product to ensure that it doesn’t injure its user. They will also establish requirements for the intended protection so the equipment will protect the user adequately.

The most obvious risk with high visibility clothing and reflective accessories is that it does not offer the level of visibility claimed or expected by the user. This may be the case if a new product doesn’t meet the legal requirements, or an old product has degraded unacceptably over time due to wear, washing and cleaning without the user noticing. In either case, the user may put himself into situations with poor lighting conditions trusting that the clothing will ensure that he is clearly visible whereas the reality is that other road users (cars, motorbikes, mopeds or trucks) don’t notice the person before a collision is inevitable. Depending upon the circumstances this may lead to even very severe outcomes including fatalities. 

In addition, some products may present a risk to the wearer just by being worn, and these are independent of the protective mechanism. The most common risks are related harmful chemicals that can cause short- and long-term adverse health effects if they exceed allowed limits.

Examples of dangerous products

Specific examples of measures taken against dangerous high visibility clothing and reflective accessories offered for sale in the European Union are available on the Safety Gate website. Type ‘safety vest’, ‘reflective clothing’ or just ‘reflective’ into the free text search box (but without the quotation marks). A better understanding of mistakes made in the safety assessment of such products, or their manufacture can help avoid their repetition.

Main applicable legislation

These products are regulated mainly by the Personal Protective Equipment Regulation (EU) 2016/425. The legislation lays down requirements for the design and manufacture of PPE that are necessary to allow these products to be sold and used in the EU market.

Other guidance is also available:

• PPE Regulation guidelines, which includes a categorization guide with examples.

Applicable standards

“Harmonised standards” exist in the EU for high visibility clothing and reflective accessories. A product claiming a particular level of protection and complying with those harmonised standards is presumed to be in conformity with the essential health and safety requirements set out in the Personal Protective Equipment Regulation if the standards are referenced in the Official Journal of the European Union (OJEU). Further information on, and the list of harmonised standards for PPE is available from here.

Note: The site of CEN (the European standardisation organisation) provides links to the national standardisation bodies’ websites. In addition, the China Standards Information Services Network can be used to access European standards.

The following standards can be applied to high visibility clothing and reflective accessories:

EN 13356:2001

This standard lays down safety and performance requirements for visibility accessories intended to be worn, attached to or carried by people and designed for non-professional use.

EN ISO 20471:2013 incl. A1:2016

This standard specifies requirements for high visibility clothing intended to provide visibility of the wearer under high-risk situations in any light condition when viewed by drivers during daylight conditions and under illumination of headlights in the dark.

EN 17353:2020

This standard specifies requirements for enhanced visibility garments or devices to be used in medium risk situations.

Both EN 17353 and EN 20471 include an annex with guidance on how to determine the appropriate level of risk for different situations.

Other legislation of relevance:

While manufacturer’s need to familiarise themselves with all the laws which apply to their specific products, the following summarises some further key applicable laws:

• The REACH regulation restricts chemical substances in goods. REACH stands for “Registration, Evaluation, Authorisation and Restriction of Chemicals”, and it places responsibility on the industry to manage the risks from chemicals and to provide safety information on the substances. The European Chemicals Agency (ECHA) maintains a list of substances of very high concern (the “SVHC list”). According to article 56(1) of the Regulation, manufacturers shall not place products containing any of the substances on this list on the market. The updated list of substances of very high concern can be found on ECHA’s website.
• Please note that every product must be safe for the consumers. If a particular safety aspect of a piece of PPE is not covered by the PPE regulation, then the General Product Safety Regulation (GPSR) applies.

Mandatory labelling & warnings

The following are obligatory:

• CE Marking is obligatory for all PPE. The conformity assessment of PPE CAT II and CAT III requires the intervention of a notified body. When a notified body has been involved in the conformity assessment (high visibility clothing and reflective accessories usually requires the intervention of a notified body), its number should be affixed after the CE marking (when CAT III) and at least on the EU type examination certificate and instructions.
• Before marking the PPE with the CE marking, the manufacturer needs to classify the product and identify all the applicable legal requirements, verify the conformity of the PPE with these requirements using the appropriate conformity assessment procedure, compile a technical documentation that evidences this and create a written declaration of conformity. When this has been done, he should affix the CE marking on the product. Refer to the factsheet on CE marking.
• Information on the manufacturer and the importer in the EU is obligatory.
• Warnings and instructions for use need to draw attention of users to the inherent hazards and associated risks and how to avoid injury. Safety warnings are obligatory for many types of helmets, and the specific wordings which may be used are provided in the relevant harmonised standard applicable to the type of product.
• All specific labelling recommended by the standard.

In addition, the following information must be provided with the PPE:

1. Instructions for storage, use, cleaning, maintenance, servicing and disinfection. Cleaning, maintenance or disinfectant products recommended by manufacturers must have no adverse effect on the PPE or the user when applied in accordance with the relevant instructions;
2. Performance as recorded during relevant technical tests to check the levels of classes of protection provided by the PPE;
3. Where applicable, accessories that may be used with the PPE and the characteristics of appropriate spare parts;
4. Where applicable, the classes of protection appropriate to different levels of risk and the corresponding limits of use;
5. Where applicable, the month and year of period of obsolescence of the PPE or of certain of its components;
6. Where applicable, the type of packaging suitable for transport;
7. The significance of any markings;
8. The risk against which the PPE is designed to protect;
9. The reference to the PPE Regulation and, where applicable, the references to other Union harmonisation legislation;
10. The name, address and identification number of the notified body or bodies involved in the conformity assessment of the PPE;
11. References to the relevant harmonised standard(s) used, including the date of the standard(s), or references to other technical specifications used;
12. The internet address where the EU declaration of conformity can be accessed.

The information in points (i), (j), (k) and (l) need not accompany the product if it is supplied with a copy of the EU declaration of conformity.

General safety requirements

To ensure safety of protective gloves, there is also a range of general requirements to be fulfilled. These are explained in the following factsheets and need to be read in conjunction with this factsheet:

• CE marking
• Conformity assessment
• Declaration of conformity
• EU consumer protection
• EU market surveillance
• Product safety checklist
• Recall procedures
• Risk management
• Safety Gate/RAPEX
• Selling online
• Technical documentation
• Testing
• Using a third party