A Decision Published in June, Felt From Autumn
On 16 June 2026 the European Commission published Implementing Decision (EU) 2026/1279, the legal act that lists which harmonised standards currently support CE marking for personal protective equipment under Regulation (EU) 2016/425. It replaces Decision (EU) 2023/941 and gathers the valid references into one document. One line concerns hand protection, and it will follow chemical protective glove suppliers into next year.
That line splits the general requirements for protective gloves across two annexes. EN ISO 21420:2020, together with amendment A1:2024, now sits in Annex I, the list whose citations carry presumption of conformity. EN 420:2003+A1:2009 moves to Annex II, the transition list, where its presumption of conformity ends on 16 December 2027. After that date a glove certificate resting on the older reference no longer delivers automatic conformity with the regulation.
Nothing has been recalled, and nothing sold today becomes unlawful overnight. The issue is timing, not legality.
Why Handwear for Chemical Agents Feels It First
CBRN gloves sit in the highest risk category of the regulation. Compliance is normally demonstrated through a type-examination by a notified body, backed by continuing production surveillance, and the technical file leans heavily on laboratory evidence: permeation data, penetration results, degradation assessment. The certificate is tied to the standard edition named on the day it was issued.
Public procurement moves slower than standards do. CBRN framework agreements and national stockpile contracts commonly run three to five years. A tender issued this quarter, citing EN 420 in its technical specification, will still be delivering in 2028 - by which point the citation inside the contract has lapsed. In practice this surfaces late, during a renewal audit or incoming inspection, with no room left to re-document and re-test a product line.
What the Replacement Standard Demands
EN ISO 21420 keeps the architecture of its predecessor while hardening several requirements that matter to buyers drafting specifications. Innocuousness testing has been widened: dimethylformamide is now limited on polyurethane, polycyclic aromatic hydrocarbons on plastics and rubber, nickel release on metal parts, and azo dyes on textiles. Chromium VI testing is applied per leather type and per colour. The pH window has been extended to rubber and plastic, tested per material.
Sizing now spans 4 to 13 including half sizes rather than the old 6 to 11 range. The dexterity test still uses pins but with a five-second hold at the fingertips. Multi-layer constructions must be built so the liner cannot pull out during removal, a requirement that directly affects lined butyl and laminate glove designs. Traceability has moved from expectation to obligation: batch number and date of manufacture must both be present. The information notice has also grown to cover storage conditions, obsolescence, latex content, and donning and removal.
There is a companion trap in the chemical test family. The parts of the EN ISO 374 series carry different publication dates, so a document citing only "EN 374" does not tell a buyer which part was tested or against which edition. Specificity is now the difference between an acceptable technical file and an arguable one.
A Second Clock Is Already Running
Five days before the decision was published, the Commission opened an initiative to review how PPE risks are classified under Regulation (EU) 2016/425, with a delegated regulation expected in the fourth quarter of 2026. If the assessment route for chemical protective handwear shifts, the documentation already in circulation may need to be revisited again.
For purchasing teams, three moves reduce exposure: name the exact standard edition and part in new specifications, require batch-linked test reports rather than catalogue claims, and ask suppliers to state in writing when their certificates will be renewed against the current edition. Suppliers who can answer that question before it is asked will hold an advantage as the December 2027 deadline approaches.