CE Marking and PPE Category II: An EU Importer's Guide to Eclipse Glasses

If you import eclipse glasses into the European Union, you are not a middleman in the eyes of the law. You take on obligations of your own, and they start before the container sails. This is a plain summary of what those obligations are and what to demand from a supplier so you can meet them.

Solar viewers are PPE, and they are Category II

Eclipse glasses are personal protective equipment under Regulation (EU) 2016/425. They protect the eye against a hazard that is not trivial and not immediately obvious to the user, which places them in Category II. That classification decides everything that follows.

Category II products cannot be self-declared by the manufacturer on the basis of internal testing alone. They require EU type-examination, module B, carried out by a notified body, which issues a certificate for the type. Only after that can the manufacturer draw up an EU Declaration of Conformity and affix the CE mark.

The practical consequence: a supplier who offers you a test report but no type-examination certificate has not completed the conformity assessment route for the EU market, no matter how good the test report is.

What the importer has to do

Regulation 2016/425 puts specific duties on importers, not just manufacturers. In summary:

• Place only compliant PPE on the market. Ignorance of the supplier's failure is not a defence.
• Verify the manufacturer carried out the correct conformity assessment and that the technical documentation exists and is available.
• Verify the CE marking is affixed and that the product is accompanied by an EU Declaration of Conformity and the required instructions.
• Put your own name, registered trade name or trademark and postal address on the product, or on its packaging or accompanying documents where the product is too small.
• Ensure the instructions and safety information are in a language easily understood by consumers in each member state where you sell.
• Keep a copy of the EU Declaration of Conformity for ten years after the product is placed on the market, and make the technical documentation available to market surveillance authorities on request.
• Make sure storage and transport do not jeopardise conformity. For a laminated optical filter in a paper frame, that mostly means dry and not crushed.
• Act if something is wrong. If you have reason to believe a product is not compliant you must not place it on the market, and if it is already out you must take corrective action and inform the authorities.

Someone must be established in the EU

Beyond the PPE regulation, EU market surveillance rules require that there be an economic operator established in the Union responsible for a product like this. For a direct import, that operator is normally you, the importer. If you are selling into the EU from outside it, you need an established party in that role before the goods go on sale. The General Product Safety Regulation, (EU) 2023/988, which has applied since 13 December 2024, reinforces the same idea for consumer products and adds requirements about the information shown to consumers in distance and online sales.

The document pack to demand before you pay a deposit

Document	What to check
EN ISO 12312-2:2015 test report	Full report, not a summary page. Sample description matches the product you are buying. Accredited laboratory, with the accreditation scope covering solar viewers.
EU type-examination certificate (module B)	Issued by a notified body. The four-digit identifier at the start of the number should be verifiable in the European Commission's NANDO database, with PPE in scope. Check the expiry date.
EU Declaration of Conformity	Names the product, Regulation 2016/425, the harmonised standard applied, and the notified body and certificate number. Signed on behalf of the manufacturer.
Technical documentation availability	You do not need the file itself, but you need written confirmation the manufacturer holds it and will produce it for authorities.
Artwork proof of the frame	CE mark, warnings, standard reference, manufacturer identification, lot number, and your own name and address as importer.
Instruction sheet	In the language of every member state you will sell in.
Batch test record	Ties the lot number on your cartons to a test result. This is what makes the report about your goods rather than about a sample from last year.

Where importers actually get caught

Two failures account for most of it. The first is the missing importer identification: the frame carries the Chinese manufacturer's details and nothing else, which is a straightforward non-compliance that a customs officer or a market surveillance inspector can see without opening a file. Get your name and address onto the print at the artwork stage. It costs nothing and it cannot be retrofitted to goods already printed.

The second is language. A single English instruction sheet shipped to a Spanish or French retailer does not satisfy the requirement. Decide your destination markets before artwork approval, not after the sample.

What we provide

We are the manufacturer, so the conformity assessment and the technical file are ours. We hold EU type-examination certificate 0068-PPE-0187 and we test to EN ISO 12312-2:2015(E), with every filter batch tested in our own laboratory before production and random samples from finished runs sent to MTIC, an EU notified body. The test report, the certificate and the Declaration of Conformity go out on request with no NDA, before you place an order.

We will also print your importer details, your CE-required markings and multilingual instruction text into the frame artwork as part of a custom job, at no extra cost above the custom minimum. That is usually the cleanest way to get compliant goods rather than fixing it with stickers in a European warehouse.