France: PAPR Rules for Welders — Code du travail, INRS ED 6106 and Welding-Fume Requirements

In France, powered air-purifying respirators (PAPR) used in welding sit at the intersection of the EU PPE Regulation 2016/425 (CE certification, Category III), the Code du travail rules on providing and maintaining PPE (articles R4321-4 to R4322-3 and R4323-91 to R4323-106), and the chemical-agents rules including binding exposure limits for chromium VI and nickel (R4412-149). Welding fumes are IARC Group 1 carcinogens; France tightened its general dust limits in 2023 (4 mg/m3 total, 0.9 mg/m3 respirable) and added CMR exposure-traceability duties in 2024. The INRS guide ED 6106 is the national reference for selecting respiratory protective devices, including TH-class (EN 12941) and TM-class (EN 12942) powered devices, and the regional CARSAT funds provide welding-fume prevention support, guidance and subsidies.

Which rules apply to respiratory protection in France

Respiratory protective equipment (appareils de protection respiratoire, APR) in French workplaces is governed by the Code du travail. The INRS guide ED 6106 states that EU Directive 89/656/EEC on PPE use is transposed into French law at articles L4321-1 to L4321-5, R4321-4 to R4322-3 and R4323-91 to R4323-106 of the Code du travail. These articles set the employer’s obligations on risk assessment, selecting the best-adapted PPE, issuing and maintaining equipment, and informing and training workers in correct use. Welding fume exposure additionally triggers the chemical-agents rules in Part 4, Book IV of the Code (R4412 series), including binding occupational exposure limit values (VLEP contraignantes) listed at article R4412-149. Two national institutions shape practice: INRS (Institut national de recherche et de sécurité) publishes the reference technical guidance (ED 6106 for respirator selection, ED 668 and ED 6484 for welding fumes), and the regional CARSAT funds deliver prevention advice, sector recommendations and financial incentives. This description is current as of July 2026.

Certification: how PAPR is approved for the French market

France applies Regulation (EU) 2016/425 on personal protective equipment directly; ED 6106 confirms it fixes the design, market-placement and certification conditions for PPE sold in France. Respiratory equipment protecting against harmful substances is Category III (the highest risk category) under Annex I of the Regulation. Category III PPE requires EU type-examination (module B) by a notified body, plus ongoing production control — either supervised product checks at random intervals (module C2) or quality assurance of the production process (module D). The CE marking on Category III PPE must be followed by the identification number of the notified body involved in production surveillance, and each device must come with manufacturer instructions in a language easily understood by end-users, as determined by the Member State, plus access to the EU declaration of conformity. The applicable product standards, per ED 6106, are NF EN 12941 for powered filtering devices with helmet or hood (classes TH1, TH2, TH3) and NF EN 12942 for powered devices with full, half or quarter masks (classes TM1, TM2, TM3).

Employer duties: provision, maintenance, training and checks

Under the Code du travail EPI-use rules (R4323-91 to R4323-106), employers must provide PPE free of charge, keep it working properly and in satisfactory hygienic condition through necessary maintenance, repairs and replacements, and ensure equipment is appropriate to the risks and ergonomically compatible with the work. Workers must be informed of the risks the PPE protects against and its conditions of use, and given adequate training including practical wearing training, renewed as often as necessary. Where several PPE items are worn together — routine for welders combining eye, face, hearing and respiratory protection — they must be mutually compatible without loss of protection. A separate arrêté of 19 March 1993, taken under what is now article R4323-99, subjects specific PPE to 12-monthly periodic verifications; the list includes stocks of gas filter cartridges for respiratory protective devices and self-contained escape respirators, though not standard workshop PAPR itself. INRS ED 6106 additionally advises a written respiratory protection programme covering selection, training, correct use and maintenance rules, with a register of all devices and a follow-up sheet for each reusable respirator.

Welding fumes: carcinogen status and exposure limits

INRS states that IARC classified welding fumes as Group 1 (carcinogenic to humans) in 2017 (monograph 118), but that they are not classified as such by the European Union. In 2022, the French agency Anses formally recommended adding work exposing workers to welding fumes and related metal fumes (including brazing, gouging, oxy-cutting, thermal spraying) to the French arrêté listing carcinogenic substances, mixtures and processes under the Code du travail; our checks did not find a finalised arrêté enacting this as of July 2026. Concrete limit values still apply. Décret 2021-1763 of 23 December 2021 lowered the general dust concentrations in workrooms with specific pollution to 4 mg/m3 (total dust) and 0.9 mg/m3 (respirable dust) from 1 July 2023; INRS describes the old 5 mg/m3 welding-fume value as obsolete. For fume constituents, article R4412-149 sets binding VLEPs including hexavalent chromium at 0.001 mg/m3 (8h) and 0.005 mg/m3 (short-term), and nickel compounds at 0.01 mg/m3 (respirable) and 0.05 mg/m3 (inhalable, 8h) applicable from 18 January 2025 — both directly relevant to stainless-steel welding.

Controls hierarchy: ventilation first, PAPR as a complement

French guidance is explicit that respiratory protection comes after collective measures. INRS ED 6484 (Prévenir les risques liés aux fumées de soudage des métaux, June 2022) sets the order: first reduce emissions (less-emissive joining processes and consumables, electronically managed arcs, optimised parameters, surface preparation), then capture fumes at source (extraction backdrops, fume-extraction torches, extraction tables) supplemented by general ventilation, with polluted air discharged outdoors and recirculation ruled out, and forced mechanical ventilation in confined spaces. ED 668 (Opérations de soudage à l’arc et de coupage, Guide pratique de ventilation no. 7) is the reference design guide for those ventilation installations. Only in complement to collective measures does ED 6484 direct employers to supply filtering respiratory protective devices — free-ventilation (negative pressure) or powered ventilation-assisted (ventilation assistée) depending on the duration of the work — fitted with class P3 anti-aerosol filters, with gas filters combined where the pollutants emitted require it. Where ambient oxygen is depleted or pollution is very high, supplied-air (adduction d’air) respirators are indicated instead of filtering devices. Welders must be trained on the risks and on correct use of both collective and individual protection.

Selecting a PAPR: ED 6106 method and protection factors

INRS ED 6106 (Les appareils de protection respiratoire — Choix et utilisation, 64-page guide, latest catalogue edition April 2020) is the national selection reference. It describes a four-step method ending with fit trials (essais d’ajustement) for tight-fitting facepieces. The required minimum protection factor is calculated from workplace concentration versus the limit value, then compared with the device’s assigned protection factor (FPA) where one exists — INRS notes France has no harmonised regulatory FPA table, so it points to INRS-advised values, the lowest FPA used by other bodies (EN 529 Annex C), or the nominal protection factor. ED 6106’s selection tables cap use of powered devices with P filters at: TH1 P up to 5x the limit value, TM1 P up to 10x, TH2 P and TM2 P up to 20x, TH3 P and TM3 P (half mask) up to 40x, and TM3 P full mask 40x to 60x. Total inward leakage limits translate to aerosol retention of 90/98/99.8 percent for TH1/TH2/TH3 P and 95/99.5/99.95 percent for TM1/TM2/TM3 P. For welding, ED 6106 notes devices must resist heat and molten-particle projections, and integrated products combining head, eye, hearing and respiratory protection exist.

CARSAT: regional prevention support for welding fumes

The CARSAT funds (Caisses d’assurance retraite et de la santé au travail) are the regional arm of the French occupational risk insurance system and run active welding-fume prevention programmes. CARSAT Pays de la Loire, for example, states that welding fumes are a confirmed human carcinogen (IARC Group 1), sets out a stepped prevention approach (risk awareness, assessment of welding workstations, evaluation and testing of technical solutions, installation, annual verification by competent personnel and worker training), and gives priority to collective protection. CARSATs point employers to Recommandation R443 (arc welding and cutting, adopted by the national technical committee for the metal industries) and to INRS guides such as ED 668. They also operate financial incentives — the page references a Subvention Prévention for welding-fume capture equipment — helping smaller companies fund at-source extraction. For a PAPR-focused buyer this matters in two ways: CARSAT support is aimed first at capture and ventilation rather than respirators, and CARSAT advisers may review whether respiratory protection is being used as a complement to, not a substitute for, collective measures.

What changed recently and what may change next

Three recent shifts are relevant to French welding operations, current as of July 2026. First, the tightened workroom dust limits from décret 2021-1763 became fully applicable on 1 July 2023: 4 mg/m3 total dust and 0.9 mg/m3 respirable dust, replacing transitional values of 7 and 3.5 mg/m3 — a substantial effective tightening for fume-heavy workshops. Second, décret 2024-307 of 4 April 2024, transposing Directive (EU) 2022/431, added binding VLEPs (including for nickel compounds, with the transitional inhalable value ending 18 January 2025) and created a traceability duty: employers must keep an updated list of workers liable to be exposed to carcinogenic, mutagenic or reprotoxic (CMR) chemical agents, recording the substances and, where known, the nature, duration and degree of exposure. Third, the Anses 2022 opinion recommending that welding-fume work be added to the arrêté listing carcinogenic processes remains, to our knowledge, not yet enacted; if adopted, the reinforced CMR provisions of the Code du travail would apply to welding as a process, regardless of the metals involved. Operators should monitor Légifrance and INRS for that change.

Sources & disclaimer

This page is information, not legal or safety advice. It summarises the cited public sources as of the date above; regulations change — verify against the primary source before relying on it. Product-level approval status is covered by our four-tier compatibility system.