We review your PPE documents against EU rules — and draft what is missing.

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What we review today

Arulero AS is established in Norway, in the European Economic Area. We review product documentation against the EU requirements that apply to personal protective equipment, and we draft what is missing for the manufacturer to issue.

The work is the same whichever way your goods reach the market: an importer or wholesaler in the EU has asked for your file, a marketplace has asked for your documents, or a new model or a new country has made the question live. Send what the request names and what you already hold.

Right now we review personal protective equipment. Typical examples are shown below. PPE category is determined by the protective function and the risks claimed for the specific product, not by the product name alone. The same glove can fall in a different category depending on what it is sold as protecting against.

We do not review Category III PPE. Category III is the regulation's closed list of risks that may cause death or irreversible damage to health. PPE in that category includes respiratory protection, fall-arrest PPE, lifejackets, hearing protection, PPE against hand-held chainsaw cuts and certain PPE against extreme heat. It adds ongoing notified-body involvement in production (Module C2 or Module D) on top of the type-examination, rather than a single examination.

Your product is not on this list? Write anyway. Tell us what it is and where it ships from, and we will say plainly whether we can review it.

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Our Services

We do not act as your authorised representative, and we do not act as a Responsible Person.

Arulero holds no economic-operator role for any client. Whether your goods need an operator established in the EU depends on the law and on how they reach the market; the answer is under FAQ. The documents are yours to issue and the product is yours to place on the market. What we deliver is the review and the drafts.

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Price

One price per product family, paid before the review starts.

Review of one product family

from €59

Each further language of the drafts

€9 per language per product family

A product family is a group of related models and variants from one manufacturer that share an intended use, a construction and materials, and the requirements that apply. We confirm the family scope and exact price with you before the review starts and before you are charged. The rate falls with the number of families reviewed in the past twelve months. Prices are in euro and exclude VAT. We sell to businesses only.

The price covers the gap report and the drafts the report calls for, in English: the EU Declaration of Conformity, the instructions and safety information, the label text and the risk analysis, for you to review and issue as the manufacturer. Re-checks of the same product family, after you have corrected or added documents, are included as long as you keep a prepaid balance of at least €49.

The gap report comes as a PDF, in English. The drafts come as editable files: DOCX for the Declaration of Conformity and for the instructions and safety information, and PDF with the marks as vector files for the label text. An incomplete set is reviewed as it is: the report names what is missing, and what you find later goes in as a re-check.

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Frequently Asked Questions

Do we need an EU authorised representative?

Not because of the PPE Regulation. Article 9 of Regulation (EU) 2016/425 says a manufacturer may appoint one by written mandate: an operator established in the EU that keeps the Declaration of Conformity and the technical documentation at the disposal of market-surveillance authorities, provides information on reasoned request and cooperates on corrective action. It is not a role every supply chain has to fill. The requirement that can apply is Article 4 of Regulation (EU) 2019/1020: PPE may be placed on the EU market only if an economic operator established in the EU is responsible for the tasks that Article sets out, and that operator can be a manufacturer established there, an importer, an authorised representative holding a written mandate, or, where none of those exists, a fulfilment service provider. If an importer established in the EU places your goods on the market, the importer meets it. If you sell direct, through a marketplace or your own site, with no such operator, you need one. We are not that operator, and we do not arrange one. What we do is review and draft the documents that importers, marketplaces and authorities ask for.

Are you a notified body or a test laboratory?

No. We issue no certificates and run no tests. We read the laboratory's test report and check whether the tests performed, the methods used, the edition of the standard applied and the results actually support the product's Declaration of Conformity.

Can you get us a "CE certificate"?

There is no such document to get. CE marking is affixed by the manufacturer on the basis of its own declaration that the product conforms. It is not a certification granted by an EU body. What genuinely exists is a Declaration of Conformity, a technical file, and — for Category II and Category III — an EU type-examination certificate issued by a notified body, whose reference Annex IX requires in the Declaration where applicable. So if you hold a type-examination certificate, it is real and it matters. What does not exist is a single document called a "CE certificate" that confers the marking. If someone offers you a generic "CE certificate" as proof of the marking, they are at minimum confusing the CE marking with the conformity assessment documents that actually exist.

Can you be our GPSR Responsible Person?

No. We do not act as Responsible Person under the General Product Safety Regulation, and we hold no other economic-operator role. If a marketplace has asked you for a Responsible Person, that is an appointment you make elsewhere. If it has asked you for documents, that is the work we do.

Does the review cover extended producer responsibility?

No. Those are separate obligations. Packaging, batteries, electronics and other product streams can trigger separate EPR registrations and, in some countries or regimes, a separate EPR authorised representative — the Batteries Regulation defines that role expressly, and WEEE provides a mechanism for it in Article 17. Where your documents show a likely obligation we say so. Registering, or appointing a representative for it, remains yours to do, and we do not hold that role.

Who signs what you draft?

You sign the Declaration of Conformity, and no one signs the rest. Under Article 8 of the PPE Regulation the manufacturer draws up the technical documentation, and under Article 15, by drawing up the EU Declaration of Conformity, the manufacturer assumes responsibility for the product's compliance. We draft the Declaration, the instructions, the label text or the risk analysis for you to review. The Declaration is the one document that carries a signature, and you sign it as the manufacturer. The instructions go with the product, the label text goes on it and the risk analysis goes into the technical documentation, none of them signed. Signing the Declaration does not move that responsibility to us.