EU market surveillance: 82% of the safety footwear models tested showed at least one non-compliance

What happened

In autumn 2026 the European Commission published the final report on safety footwear of the JACOP 2025 market-surveillance action. JACOP (Joint Action on the Compliance of Products) is financed and coordinated by the Commission; national market-surveillance authorities check one product group with a shared method. Product-Specific Activity 11 covered safety footwear with a protective toe cap for workplace use — Category II PPE under Regulation (EU) 2016/425, which needs EU type-examination by a notified body, after which the manufacturer is responsible for keeping serial production in conformity with the type.

Ten authorities from eight countries (Cyprus, Germany, Luxembourg, the Netherlands, Norway, Portugal, Spain and Sweden) sampled 83 models: 54 from web shops and online marketplaces, 29 from physical stores. Most were S3 (62 models), the rest SB, S1 and S5. Laboratory testing covered selected mandatory requirements of EN ISO 20345:2022 (the 2011 edition for models placed on the market earlier): impact and compression resistance, perforation resistance, antistatic properties and, in one case, cut resistance — 313 tests in an accredited laboratory. The authorities also checked documentation and markings against a common checklist.

The report stresses that sampling was risk-based and not representative: the percentages describe the models selected for checking, not the whole market.

The results

Check	Did not meet	Share
At least one performance requirement (83 models)	53	64%
Formal checks: CE marking, instructions, protection category (83 models)	48	58%
At least one non-compliance overall (83 models)	68	82%

Among the performance tests, antistatic properties failed most often: 28 of 68 models tested (41%). Impact resistance failed in 20 of 83 (24%), perforation resistance in 14 of 78 (18%), compression resistance in 5 of 83 (6%); the single cut-resistance test passed.

In the formal checks the typical defects were a missing or incorrect CE marking, instructions not available in the required national language(s) and an unmarked protection category. In the risk assessment of the 68 non-compliant models, 12 were rated serious and 13 high.

The authorities’ measures: sales bans or withdrawals for 24 models, warnings — some with fines — in 15 cases, 4 recalls; 6 models were brought into conformity as a result of the investigation. Several online marketplaces were instructed to delist the products. The report notes that some withdrawn products reappeared through other sales channels.

Why does a certified product fail?

The report’s most important finding is a pattern, not a number: discrepancies between the product assessed at EU type-examination and the product placed on the market. A notified body assesses the sample presented for type-examination; market surveillance tests a pair taken from the shelf or the web shop. Between the two lies serial production — material and component substitutions, supplier changes, process variation. For antistatic properties and perforation resistance, the report says, how the protective components are integrated into the finished shoe matters particularly.

Hence the reminder to manufacturers and other economic operators: serial production must stay in conformity with the certified type, technical and supply-chain documentation must be kept current, and markings, instructions and marketing claims must reflect the protection actually provided.

What it means for manufacturers and importers

The report’s recommendations come down to four duties. None is new — they follow from Regulation (EU) 2016/425 — but the campaign shows where practice drifts from them.

1. Check serial production on the critical properties. A fixed specification, documented material and supplier changes, and periodic batch tests of the properties that failed most often: antistatic behaviour, toe-cap impact and compression resistance, perforation resistance. A laboratory report records the technical facts; conformity remains the manufacturer’s responsibility.
2. Markings and instructions. CE marking, protection category and manufacturer details on the footwear; instructions for use in the language of the country of sale. In the campaign every second model failed here — no laboratory needed.
3. A responsible economic operator in the EU. For a non-EU manufacturer, the importer’s or authorised representative’s name and EU address on the product and in the documentation.
4. Verify the certificate. Before sourcing or distributing, the validity of the EU type-examination certificate can be checked with the issuing notified body; Safety Gate alerts and recalls are public.

BIMEO works on both sides of this: as a notified body (NB 1524) we carry out EU type-examination of safety footwear, and as a laboratory we test the properties above on samples from serial production — for manufacturers, importers and distributors alike. The report supports the technical investigation; whether the product may be sold is the manufacturer’s decision and responsibility.

What it means for users

The report also speaks to end users: choose the protection category for the workplace risk; before buying, check the CE marking, the EU declaration of conformity and instructions in your language, the protection category and manufacturer details on the tongue label; be wary of vague or exaggerated performance claims; and consult Safety Gate alerts before purchasing.

What comes next

The report asks standardisation bodies for test methods closer to real use — a dynamic perforation test, antistatic assessment on aged sole and upper materials — and for clear rules on measurement uncertainty. It asks authorities to check footwear more often and to pair documentary checks with laboratory testing, since one fifth of the samples passed the paperwork and failed in the laboratory.