Where are they now? Level 3 armour

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Hot_Air
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Re: Where are they now? Level 3 armour

Post by Hot_Air »

Mascagman wrote: Tue Jul 07, 2020 8:54 pm But here we are in 2020, we have motorcycle stores that still don't require clothing and gloves to be CE marked before selling it to the public.
@Mascagman Would you have any clue how Rukka is managing to sell its new garments without certification (EN 17092)? Is there a "loophole" via a Notified Body in Finland?

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With this garbage from a premium-priced brand, as well as A-rated race suits :shock: now on the market, the latest CE regulations are starting to look like an Omnishambles.
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MrLongbeard
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Re: Where are they now? Level 3 armour

Post by MrLongbeard »

Hot_Air wrote: Thu Oct 22, 2020 9:27 am
Mascagman wrote: Tue Jul 07, 2020 8:54 pm But here we are in 2020, we have motorcycle stores that still don't require clothing and gloves to be CE marked before selling it to the public.
@Mascagman Would you have any clue how Rukka is managing to sell its new garments without certification (EN 17092)? Is there a "loophole" via a Notified Body in Finland?

Image

With this garbage from a premium-priced brand, as well as A-rated race suits :shock: now on the market, the latest CE regulations are starting to look like an Omnishambles.
Maybe because the old PPE directive is still valid up till 2023.
Maybe because the EN 17092 series of standards are not published in the OJ as a harmonised standard yet.
Maybe because they comply with the essential health and safety requirements of either the old or new directives by other means.
The Spin Doctor
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Re: Where are they now? Level 3 armour

Post by The Spin Doctor »

Interesting - in an old post on another forum from 2007, I found a response from Rukka to a direct question about CE approval for one of their jackets, where they said the product: "complies with Directive 89/686/EEC which indicates that the jacket and trousers have been accepted for professional use. It has not been constructed EN 13595."

According to the BSI: "‘EC type-examination certificates and approval decisions issued under Directive 89/686/EEC shall remain valid until 21 April 2023 unless they expire before that date."

I wonder if they are still using that directive? If they got their kit tested at the last moment, it would give them another three years to produce 'approved' kit.

https://advrider.com/f/threads/halvarss ... 096/page-2
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Hot_Air
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Re: Where are they now? Level 3 armour

Post by Hot_Air »

Since Rukka sells to the UK police and emergency services – who require CE certification for professional use – this situation must affect Rukka's sales significantly. Thus, Rukka needs to appear compliant with CE regulations for professional use.

The Advrider thread highlights that Rukka secured CE-labelling via Directive 89/686/EEC (circa 1989). And it's worth posting a comment from the discussion:
Another forum wrote: "Whereas this Directive defines only the basic requirements to be satisfied by personal protective equipment." and appears to be a generic PPE directive for anything on the market that provides some protection. In fact, if you go through the text, the term "motorcycle" is nowhere to be found! Clearly, the Directive is nowhere near the motorcycle-specific standards of the EN standard and thus, advertising their garments in both print and online as meeting the professional use standards could be argued in court as inappropriate and fraudulent.
Wasn't there a rumour that Trading Standards asked Rukka to withdraw this advertising? Whether or not Rukka was fraudulent, it's undoubtedly misleading and damages my trust in Rukka. Others will know better than me, but isn't 89/686/EEC the Directive that applies to gardening gloves?
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Re: Where are they now? Level 3 armour

Post by The Spin Doctor »

Hot_Air wrote: Fri Oct 23, 2020 9:33 am Since Rukka sells to the UK police and emergency services – who require CE certification for professional use – this situation must affect Rukka's sales significantly. Thus, Rukka needs to appear compliant with CE regulations for professional use.

The Advrider thread highlights that Rukka secured CE-labelling via Directive 89/686/EEC (circa 1989). And it's worth posting a comment from the discussion:
Another forum wrote: "Whereas this Directive defines only the basic requirements to be satisfied by personal protective equipment." and appears to be a generic PPE directive for anything on the market that provides some protection. In fact, if you go through the text, the term "motorcycle" is nowhere to be found! Clearly, the Directive is nowhere near the motorcycle-specific standards of the EN standard and thus, advertising their garments in both print and online as meeting the professional use standards could be argued in court as inappropriate and fraudulent.
Wasn't there a rumour that Trading Standards asked Rukka to withdraw this advertising? Whether or not Rukka was fraudulent, it's undoubtedly misleading and damages my trust in Rukka. Others will know better than me, but isn't 89/686/EEC the Directive that applies to gardening gloves?
Dunno about any rumours.

I saw how their top of the range jacket / trousers combo disintegrate in a 40 mph crash in about 2000 - a mate lost it on a bend in N Spain. He showed me the results when he got back, he wasn't impressed as it was only the armour and luck that kept him undamaged. Bit of his arm and leg were left exposed. The shoulder had come to pieces. IIRC he'd paid the best part of £2k for it.

Amusingly we visited the site a couple of years later and the bend had been totally reprofiled, but sticking out of the spoil heap at the end of the road was a piece of his CBR6 fairing :)
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Mascagman
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Re: Where are they now? Level 3 armour

Post by Mascagman »

Just because EN 17092 has not yet been harmonised, it is a bit of a cop out not to be certifying to it. No one in their right mind would buy impact protection without certification, although they are not harmonised nor are inserted protectors actually required to be certified. But everyone does it to prove they are compliant.

Rukka are notoriously dodge in this area. Hopefully quality will again be demonstrated when the high performance standard enters the fray next year.
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MrLongbeard
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Re: Where are they now? Level 3 armour

Post by MrLongbeard »

Mascagman wrote: Fri Oct 23, 2020 8:50 pm Just because EN 17092 has not yet been harmonised, it is a bit of a cop out not to be certifying to it.
It's a cop out, but it doesn't give a presumption of conformity, and no one is UKAS accredited for it yet.
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Re: Where are they now? Level 3 armour

Post by Mascagman »

MrLongbeard wrote: Fri Oct 23, 2020 9:02 pm
Mascagman wrote: Fri Oct 23, 2020 8:50 pm Just because EN 17092 has not yet been harmonised, it is a bit of a cop out not to be certifying to it.
It's a cop out, but it doesn't give a presumption of conformity, and no one is UKAS accredited for it yet.
Not for a few more months, but there are accredited foreign NBs. Its not like the NBs need to be accredited to ceritfy using their own testing anyhow
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Re: Where are they now? Level 3 armour

Post by dayglo jim »

Halvarssons are very progressive on meeting standards but lost ground to Rukka with their waterproofing. Their armour, although badged up, was Forcefield/Davies Odell and they never shied away from admitting this.
When I sold Halvarssons clothing the company was very good at informing and giving dealers opportunity to find why a particular item met or failed to meet a particular standard; I incorporated a lot of their supporting info within lesson plans for trainees.