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SEC 05 // EU COMPLIANCE HUB · 2026-07-06

Welding PAPR in the EU: PPE Regulation, EN 12941/12942 and the carcinogens rules on welding fume

The EU governs welding powered air-purifying respirators (PAPR) through two separate legal pillars. On the product side, Regulation (EU) 2016/425 treats respiratory protective equipment as Category III PPE, requiring EU type-examination plus ongoing production surveillance by a notified body before CE marking. The relevant harmonised standards are EN 12941 (loose-fitting helmet/hood devices) and EN 12942 (tight-fitting mask devices). The 2023 editions of these standards were first cited in the Official Journal by Commission Implementing Decision (EU) 2024/2599 of 4 October 2024 (OJ L, 8.10.2024), which set 8 October 2026 as the withdrawal date for the older 1998-series editions; presumption of conformity for the 2023 editions has therefore run since October 2024. They are currently listed in Commission Implementing Decision (EU) 2026/1279 (adopted 12 June 2026), which consolidated and repealed the intervening Decision (EU) 2023/941 without changing that withdrawal date. On the workplace side, Directive 2004/37/EC (the Carcinogens, Mutagens and Reprotoxic substances Directive) sets binding exposure limits for hexavalent chromium and nickel found in welding fume, and its pending sixth revision — provisionally agreed by Council and Parliament on 23 June 2026 — adds welding-fume work to the directive’s scope, driven by IARC’s 2017 classification of welding fumes as a Group 1 human carcinogen. This hub summarises what the regulators and standards state; it is information, not compliance advice. Current as of 6 July 2026.

The EU separates the rules for the respirator as a product from the rules for using it at work. Regulation (EU) 2016/425 is product law: it sets the essential health and safety requirements a PAPR must meet before it can carry a CE mark and be sold anywhere in the EU/EEA. The workplace side is set by directives that each Member State transposes into national law, principally Directive 89/656/EEC (use of PPE at work) and Directive 2004/37/EC (protection from carcinogens, mutagens and reprotoxic substances, the ‘CMRD’). Framework Directive 89/391/EEC underpins the general duty to assess and control risk. A CE-marked PAPR satisfies the product law, but that alone does not discharge an employer’s separate workplace duties — the two pillars operate together. This distinction matters for welders because fume control is governed by the workplace directives, while the respirator hardware is governed by the PPE Regulation.

Certification: Category III, notified bodies and CE marking

Regulation (EU) 2016/425 classifies respiratory protective equipment as Category III — PPE against risks that may cause ‘very serious consequences such as death or irreversible damage to health’, a list that expressly includes ‘substances and mixtures which are hazardous to health’ and ‘atmospheres with oxygen deficiency’. Article 19 requires Category III PPE to undergo EU type-examination (module B) by a notified body, plus one of two ongoing production-surveillance routes: supervised product checks (module C2) or quality assurance of the production process (module D). Under Article 17, the CE marking on Category III PPE must be followed by the four-digit identification number of the notified body carrying out that surveillance. The manufacturer must draw up an EU declaration of conformity. Notified bodies designated for the PPE Regulation are listed in the Commission’s NANDO information system. Conformity with a harmonised standard whose reference is published in the Official Journal gives a presumption of conformity with the corresponding essential requirements.

The harmonised standards: EN 12941 and EN 12942

Two harmonised standards cover welding PAPR. EN 12941 specifies requirements for powered filtering devices incorporating a loose-fitting respiratory interface (helmet or hood) — the common welding-helmet PAPR. EN 12942 covers powered (or power-assisted) filtering devices incorporating a tight-fitting full face mask, half mask or quarter mask. A related supplied-air standard, EN 14594:2018 (continuous-flow compressed airline breathing apparatus), is also harmonised. EN 12941 sorts devices into classes TH1, TH2 and TH3 and EN 12942 into TM1, TM2 and TM3, with the higher class number denoting lower permitted total inward leakage and therefore higher protection. Meeting these standards is voluntary, but doing so provides the Article 14 presumption of conformity with Regulation (EU) 2016/425. The general RPE-programme guidance standard EN 529:2005 sits alongside them, giving Europe-wide recommendations on selecting, using, caring for and maintaining respiratory protective devices.

Welding-fume specifics: carcinogen classification and exposure limits

IARC (part of the WHO) classified welding fumes — and ultraviolet radiation from welding — as carcinogenic to humans, Group 1, in Monograph Volume 118 (evaluated 2017, monograph published 2018), an upgrade from the previous Group 2B. Welding fume can contain hexavalent chromium (Cr(VI)) and nickel compounds, both regulated carcinogens under Directive 2004/37/EC. Directive (EU) 2017/2398 set the Cr(VI) binding limit at 0.005 mg/m³ (8-hour TWA), with a transitional value of 0.025 mg/m³ for ‘welding or plasma cutting processes or similar work processes that generate fume’ (and a general transitional value of 0.010 mg/m³ for other processes) that expired on 17 January 2025 — so the 0.005 mg/m³ limit now applies across all sectors. Directive (EU) 2022/431 set nickel-compound limits of 0.01 mg/m³ (respirable) and 0.05 mg/m³ (inhalable), applicable from 18 January 2025, and renamed the directive to add reprotoxic substances. The CMRD requires a hierarchy of controls: substitution and engineering controls (such as local exhaust ventilation) come before respiratory PPE, which is the last line of defence.

Selection and protection factors

EN 12941 and EN 12942 define device classes by permitted total inward leakage, but the practical protection credited to each class — the assigned protection factor (APF) — is set by national guidance, not by the harmonised standards themselves, and varies between Member States. EN 529:2005 exists precisely to guide that national selection. Published manufacturer compilations (for example GVS’s positive-pressure FAQ, 2024) illustrate the variation: a TH3 loose-fitting PAPR is credited with an APF of 200 in Finland, Italy and Sweden, 100 in Denmark, and 40 in the UK and France; a TM3 tight-fitting PAPR ranges from 1000 (Finland, Sweden) down to 40 (UK) and 60 (France). Selectors should therefore use the APF from their own country’s guidance, then confirm it exceeds the ratio of measured exposure to the relevant limit. Loose-fitting hood/helmet PAPR generally does not require face-fit testing (its interface does not seal to the face); tight-fitting mask devices do. Facial hair under a sealing mask compromises the seal.

What changed recently and what is changing

Two significant changes are current. First, the harmonised standards were updated in stages. Commission Implementing Decision (EU) 2024/2599 of 4 October 2024 (published in the OJ on 8 October 2024) first cited EN 12941:2023 and EN 12942:2023 in the Official Journal — inserting them into Annex I of the then-current Decision (EU) 2023/941 — and fixed 8 October 2026 as the withdrawal date for the superseded 1998-series editions (EN 12941:1998 +A1:2003 +A2:2008 and EN 12942:1998 +A1:2002 +A2:2008); manufacturers and notified bodies have been able to rely on the 2023 editions for presumption of conformity since October 2024. Decision (EU) 2023/941 was subsequently consolidated and repealed by Commission Implementing Decision (EU) 2026/1279 (adopted 12 June 2026, published 16 June 2026), which now carries the current listing of EN 12941:2023 and EN 12942:2023 (Annex I, rows 113 and 114) and EN 14594:2018 (row 162), preserving the same 8 October 2026 withdrawal date rather than resetting it. After that date, only the 2023 editions confer presumption of conformity. Second, the sixth revision of the CMRD is advancing: the Commission’s proposal COM(2025)418 (18 July 2025) adds welding-fume work to Annex I and sets new limits for cobalt, PAHs and 1,4-dioxane; Council and Parliament reached a provisional political agreement on 23 June 2026, which also adds an OEL for isoprene, extends the PAH transitional period, and introduces an obligation for regular breaks for workers wearing PPE. It still requires formal adoption before it becomes law.

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.