INSST-Commerce Agreement 2026: What Changes for PPE Manufacturers

Key data

Manufacturers and importers of personal protective equipment (PPE) operating in Spain face a strengthened supervisory framework from May 4, 2026. The National Institute for Occupational Safety and Health (INSST) has formalized an agreement with the State Secretariat for Commerce to provide specialized technical assistance in the testing and certification processes for these products.

The agreement, published in the BOE on May 9, 2026 through a Subsecretariat Resolution (reference BOE-A-2026-10093), makes the INSST the reference technical body to support quality control and compliance verification of PPE circulating in the Spanish market. For companies in the sector, this means greater rigor in inspections and the need to ensure that their technical documentation and products are in order.

What does this regulation establish?

The agreement formalizes collaboration between two public bodies with complementary roles:

• The INSST provides its accredited technical capacity to conduct testing and support PPE certification processes.
• The State Secretariat for Commerce receives this specialized technical assistance to strengthen its mechanisms for verifying and controlling compliance of these products in the market.

The stated objective of the agreement is to guarantee the safety of workers using this equipment in their workplaces, strengthening the technical standards that PPE marketed in Spain must meet.

In practical terms, the agreement creates a stable institutional channel between the reference technical body for occupational safety and the body responsible for market control of these products. This means that PPE compliance verification processes will have INSST technical support systematically, not sporadically.

Economic and operational impact

The agreement does not establish new fees or direct sanctions on companies in the sector. However, its operational impact is clear: compliance controls on PPE will be more rigorous and technically supported.

For companies, this translates into the following practical effects:

• Greater likelihood of technical inspections on marketed products, as the State Secretariat for Commerce will have specialized INSST support.
• Requirement for complete and updated technical documentation: declarations of conformity, technical files and test certificates must be in order.
• Risk of market withdrawal for products that do not meet the technical standards evaluated under this collaboration framework.
• Adaptation costs for companies that have not updated their certification processes in accordance with current standards.

Companies already operating with robust certification processes and updated technical documentation will not see significant operational changes. The impact falls mainly on those marketing PPE with deficient or outdated certification processes.

Who does it affect?

The agreement has direct implications for the following categories of companies and professionals:

• PPE manufacturers that produce and market personal protective equipment in the Spanish market.
• PPE importers that introduce equipment manufactured outside the country into Spain, especially from non-EU markets.
• PPE distributors that place these products on the market and are co-responsible for their compliance.
• Occupational risk prevention managers in companies that purchase PPE, as the quality and certification of the equipment they buy directly affects their compliance with labor safety regulations.
• Certification bodies and testing laboratories working in the PPE field, which will see how the INSST strengthens its technical presence in this sector.

Practical example

A Spanish importer bringing chemical protection gloves manufactured in a non-EU country and marketing them in Spain must have complete technical documentation: EU declaration of conformity, technical file and type examination certificate issued by a notified body.

With the new agreement, the State Secretariat for Commerce can request the INSST to conduct technical testing on a sample of those gloves to verify that they meet the declared standards. If testing detects that the product does not comply with technical requirements, the importer faces product market withdrawal and corresponding administrative consequences under current market surveillance regulations.

This scenario, which previously depended on the internal technical capacity of the State Secretariat for Commerce, now has the specialized support of the INSST, making controls more solid and technically grounded.

What should companies do now?

1. Audit your technical documentation: review that all PPE you manufacture, import or distribute have EU declaration of conformity, technical file and current and updated test certificates.
2. Verify the validity of your certifications: check that the type examination certificates for your products have not expired and that the notified bodies that issued them remain valid.
3. Review applicable technical standards: ensure that your products comply with the current harmonized standards for each PPE category, as the INSST will evaluate products according to these standards.
4. Train your compliance team: personnel responsible for PPE management must understand the implications of this strengthened market control and be prepared to respond to possible requests from the State Secretariat for Commerce.
5. Establish an internal market surveillance process: implement periodic controls on the products you market to detect deviations before external inspection does.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. The information is based on the official text of the Resolution of May 4, 2026, published in the BOE on May 9, 2026 (BOE-A-2026-10093). For specific legal or compliance advice regarding your company's situation, consult with a labor law specialist or compliance advisor. Regulations may be subject to updates or amendments. Always verify the current status of applicable regulations through official sources.