--- title: "TPED — Transportable Pressure Equipment Directive" description: "The Transportable Pressure Equipment Directive makes the ADR, RID and ADN conformity assessment and inspection requirements binding EU-wide for pressure receptacles, tanks and gas containers, adds the Pi marking and binds manufacturers, importers, distributors, owners and operators. It has applied since 1 July 2011; Directive (EU) 2024/2749 adds emergency procedures that apply from 30 May 2026." type: "guide" url: "https://www.conphora.com/regulations/tped/" markdown: "https://www.conphora.com/regulations/tped.md" locale: "en" language: "en" published: "2010-07-20" updated: "2026-09-22" author: "Conphora compliance team" publisher: "Conphora" reference: "Directive 2010/35/EU" celex: "32010L0035" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010L0035" tags: ["TPED", "Maritime & Transport"] license: "Free to quote with attribution and a link to the page" --- # TPED — Transportable Pressure Equipment Directive The Transportable Pressure Equipment Directive makes the ADR, RID and ADN conformity assessment and inspection requirements binding EU-wide for pressure receptacles, tanks and gas containers, adds the Pi marking and binds manufacturers, importers, distributors, owners and operators. It has applied since 1 July 2011; Directive (EU) 2024/2749 adds emergency procedures that apply from 30 May 2026. ## Key facts - **Official title:** Directive 2010/35/EU of the European Parliament and of the Council of 16 June 2010 on transportable pressure equipment and repealing Council Directives 76/767/EEC, 84/525/EEC, 84/526/EEC, 84/527/EEC and 1999/36/EC - **Reference:** Directive 2010/35/EU - **CELEX:** 32010L0035 - **Act type:** Directive - **In force:** 2010-07-20 - **Applies from:** 2011-07-01 - **Enforced by:** National market surveillance authorities enforce the national laws transposing the directive over the whole life cycle of the equipment, not only at the point of sale: Article 2, point (26), defines market surveillance as the activities and measures to ensure that transportable pressure equipment during its life cycle complies with Directive 2008/68/EC and this Directive, and Articles 16 and 30 still cite Regulation (EC) No 765/2008, whose Chapter III, Articles 15 to 29, was deleted by Regulation (EU) 2019/1020 from 16 July 2021, and Article 39(2) of Regulation (EU) 2019/1020 provides that references to the deleted provisions of Regulation (EC) No 765/2008 are construed as references to the regulation and read in accordance with the correlation table in its Annex III: the Article 20 of Regulation (EC) No 765/2008 that Article 30(1) of the directive cites is now Article 19 of the regulation, and the Article 21 it cites for corrective action is now Article 18. Listing the directive as point 37 of Annex I is what brings it inside the regulation's market surveillance chapter in the first place. The directive is not in the Article 4(5) list of Regulation (EU) 2019/1020, so the duty to have an economic operator established in the Union responsible for a product does not follow from that article for transportable pressure equipment; it is instead listed as point 15 of Annex II to that regulation, the Union harmonisation legislation without provisions on penalties, so Article 41 of the regulation requires Member States to lay down effective, proportionate and dissuasive penalties for infringements of it. In Denmark the directive is implemented by executive order nr. 483 of 28 May 2026 on the construction of transportable pressure equipment (bekendtgørelse om indretning m.v. af transportabelt trykbærende udstyr), which reproduces the directive as amended as its annex 1, rests on the product act (lov om produkter og markedsovervågning, LBK nr. 22 of 8 January 2026) and replaced executive order nr. 685 of 10 June 2013 from 30 May 2026; the product act lists the directive in section 2 as product area nr. 6 and names Erhvervsstyrelsen as the control authority, a task carried out since 1 December 2018 by Sikkerhedsstyrelsen, since January 2026 the department Markedsovervågning of Erhvervsstyrelsen, while the control authority's own guidance on pressure equipment states that Arbejdstilsynet remains the market surveillance authority for pressure equipment and pressure vessels made to order and for equipment imported from third countries for offshore oil and gas activities under the offshore safety act. That guidance is written for pressure equipment and pressure vessels, not for transportable pressure equipment, whose scope is set by the ADR and RID annexes to Directive 2008/68/EC and knows no 'made to order' category; for transportable pressure equipment only the offshore leg is capable of applying. That split works through section 9(2) of the product act, under which the authority that supervises other legislation on specific risks for particular products is the relevant control authority; executive order nr. 483 of 28 May 2026 does not mention Arbejdstilsynet at all, and the product act does not name it for this product area. Erhvervsstyrelsen also designates the Danish notified bodies on the basis of DANAK accreditation, handles complaints against their decisions within 4 weeks, issues the Article 33c emergency authorisations and prioritises market surveillance under Article 33d. The toolkit is an evaluation of equipment presenting a risk, corrective action, withdrawal or recall within a period commensurate with the risk, provisional measures prohibiting or restricting the making available where the operator does not act, an order to end formal non-compliance such as a Pi marking affixed in violation of Articles 12 to 15, a missing Pi marking or missing or incomplete technical documentation, and national penalties that may include criminal sanctions for serious infringements. - **Category:** Maritime & Transport ## Who it applies to **Covered by the act:** New transportable pressure equipment that does not bear the conformity markings of Directives 84/525/EEC, 84/526/EEC, 84/527/EEC or 1999/36/EC, for the purpose of making it available on the market; Transportable pressure equipment bearing the conformity markings of this directive or of Directives 84/525/EEC, 84/526/EEC, 84/527/EEC or 1999/36/EC, for the purposes of its periodic inspections, intermediate inspections, exceptional checks and use; Transportable pressure equipment that does not bear the conformity markings of Directive 1999/36/EC, for the purposes of reassessment of conformity; The equipment itself: all pressure receptacles, their valves and other accessories when appropriate, as covered in Chapter 6.2 of the Annexes to Directive 2008/68/EC, and tanks, battery vehicles and wagons, multiple-element gas containers and their valves and other accessories when appropriate, as covered in Chapter 6.8 of those Annexes, when used in accordance with the Annexes for the transport of Class 2 gases, excluding gases or articles with figures 6 and 7 in the classification code, and for the transport of the dangerous substances of other classes specified in Annex I to the directive; gas cartridges of UN No 2037 are included; The economic operators in the chain and in use: manufacturers, authorised representatives, importers, distributors, owners and operators acting in the course of a commercial or public service activity, whether in return for payment or free of charge **Derived and downstream products:** The Annexes to Directive 2008/68/EC means Section I.1 of Annex I (the ADR for road), Section II.1 of Annex II (the RID for rail) and Section III.1 of Annex III (the ADN for inland waterways); since Commission Delegated Directive (EU) 2025/149, which Member States apply from 30 June 2025, those sections refer to the ADR, RID and ADN as applicable with effect from 1 January 2025 (Art. 2, point (2), of the directive; Annexes I to III to Directive 2008/68/EC); The directive contains no technical specifications of its own: conformity assessment, periodic inspection, intermediate inspection, exceptional check, the accreditation standard for notified bodies and the technical documentation and retention periods are all defined by reference to the Annexes to Directive 2008/68/EC (Art. 2, points (15) and (18) to (22), Art. 4(3), Art. 12 and Art. 20); Six UN numbers outside Class 2 are listed in Annex I and are therefore in scope: UN 1051 hydrogen cyanide stabilised containing less than 3 % water (class 6.1), UN 1052 anhydrous hydrogen fluoride (class 8), UN 1745 bromine pentafluoride (class 5.1), UN 1746 bromine trifluoride (class 5.1), UN 1790 hydrofluoric acid with more than 85 % hydrogen fluoride (class 8) and UN 2495 iodine pentafluoride (class 5.1); for UN 1745, UN 1746 and UN 2495 the entry excludes carriage in tanks (Annex I); Seven groups are carved out of the definition itself: aerosols of UN No 1950, open cryogenic receptacles, gas cylinders for breathing apparatus, fire extinguishers of UN No 1044, equipment exempted according to 1.1.3.2 of the Annexes to Directive 2008/68/EC, equipment exempted from the rules for construction and testing of packaging according to special provisions in 3.3 of those Annexes, and Class 2 gases or articles with figures 6 and 7 in the classification code (Art. 2, point (1)); The directive does not apply to equipment placed on the market before the date of implementation of Directive 1999/36/EC (1 July 2001, or 1 July 2005 for pressure drums, bundles of cylinders and tanks) that has not been subject to a reassessment of conformity, nor to equipment used exclusively for the transport of dangerous goods between Member States and third countries under Article 4 of Directive 2008/68/EC (Art. 1(3) and (4)); The directive's own term operator means any natural or legal person established in the Union using transportable pressure equipment, and use means filling, temporary storage linked to carriage, emptying and refilling; the owner is the person established in the Union who owns the equipment. Both are economic operators when they act in the course of a commercial or public service activity (Art. 2, points (5), (12), (13) and (14)); An importer or distributor that places equipment on the market under its own name or trademark, or modifies equipment already placed on the market in such a way that compliance may be affected, is considered a manufacturer and takes on the Article 4 obligations (Art. 10); Member States may establish on-site requirements for the mid- or long-term storage or the on-site use of transportable pressure equipment on their territory, but may not add requirements for the equipment itself (Art. 3); they may also maintain the national provisions listed in Annex II on connection devices and colour codes, and Member States in which the ambient temperature is regularly lower than – 20 °C may impose more stringent standards for the operating temperature of material intended for equipment used in national transport of dangerous goods, until reference temperatures for climatic zones are added to the Annexes to Directive 2008/68/EC; in that case the identification number of the notified body in the Pi marking is followed by '– 40 °C' or another relevant marking approved by the competent authority, on the equipment and on demountable parts with a direct safety function (Art. 34 and Annex II); Equipment that is not transportable pressure equipment is covered by other law: Directive 2014/68/EU on pressure equipment excludes equipment covered by Directives 2008/68/EC and 2010/35/EU from its own scope, so stationary vessels, piping and assemblies follow the Pressure Equipment Directive and simple welded air or nitrogen vessels follow Directive 2014/29/EU (Art. 1(2)(s) of Directive 2014/68/EU) **Roles under the act:** - **Manufacturer (including brand owners and anyone who modifies equipment already on the market)** — Any natural or legal person who manufactures transportable pressure equipment, or parts thereof, or who has such equipment designed or manufactured and markets it under his name or trademark; an importer or distributor that places equipment on the market under its own name or trademark, or modifies equipment already placed on the market in such a way that compliance may be affected, is considered a manufacturer and carries the Article 4 obligations. - **Authorised representative** — Any natural or legal person established within the Union who has received a written mandate from the manufacturer to act on his behalf in relation to specified tasks; the obligations to design, manufacture and document the equipment to the Annexes to Directive 2008/68/EC, to affix the Pi marking and to draw up the technical documentation cannot form part of the mandate. - **Importer** — Any natural or legal person established within the Union who places transportable pressure equipment or parts thereof from a third country on the Union market. - **Distributor (any supplier in the chain other than the manufacturer or importer)** — Any natural or legal person established within the Union, other than the manufacturer or the importer, who makes transportable pressure equipment or parts thereof available on the market. - **Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it)** — The owner is any natural or legal person established in the Union who owns transportable pressure equipment; the operator is any natural or legal person established in the Union using it, where use means filling, temporary storage linked to carriage, emptying and refilling. Both are economic operators when they act in the course of a commercial or public service activity, whether in return for payment or free of charge, and both carry duties under Articles 8, 9, 11 and 13. Note that the directive's own word operator means the user of the equipment, not the person who places it on the market. ## Key dates - 1999-04-29: Council Directive 1999/36/EC on transportable pressure equipment is adopted as a first step towards enhancing transport safety while ensuring free movement; it is the act Directive 2010/35/EU updates and repeals, and the date of its implementation is the cut-off for reassessment of conformity - 2001-07-01: 1 July 2001 — the date of implementation of Directive 1999/36/EC under its Article 17(1), and therefore the cut-off that Articles 1(2)(c), 1(3), 2(17) and 13 and Annex III of Directive 2010/35/EU refer to - 2005-07-01: 1 July 2005 — the deferred date of implementation for pressure drums, bundles of cylinders and tanks. Article 17(2) of Directive 1999/36/EC allowed the date to be deferred for equipment for which no detailed technical specifications existed; the Commission used it twice, deferring to 1 July 2003 by Decision 2001/107/EC and then to 1 July 2005 by Decision 2003/525/EC. That is why Annex III(1) to Directive 2010/35/EU speaks of the implementation dates in the plural: equipment reaching the market before 1 July 2001, or before 1 July 2005 if it is a pressure drum, a bundle of cylinders or a tank, is the equipment that can go through reassessment of conformity - 2008-10-20: Directive 2008/68/EC on the inland transport of dangerous goods enters into force, the twentieth day after publication in OJ L 260 of 30 September 2008; its Annexes extend the ADR, RID and ADN to national transport and supply every technical requirement that the Transportable Pressure Equipment Directive makes enforceable on the internal market - 2010-06-16: Directive 2010/35/EU adopted by the European Parliament and the Council on the basis of Article 91 TFEU, aligning the transportable pressure equipment rules with Directive 2008/68/EC and with the common marketing framework of Decision No 768/2008/EC - 2010-07-20: Entry into force, the twentieth day after publication in OJ L 165 of 30 June 2010 - 2011-06-30: Deadline for Member States to bring into force the laws, regulations and administrative provisions necessary to comply with the directive - 2011-07-01: Directives 76/767/EEC, 84/525/EEC, 84/526/EEC, 84/527/EEC and 1999/36/EC are repealed and references to Directive 1999/36/EC are construed as references to this directive; in Denmark executive order nr. 732 of 27 June 2011 implementing Directive 2010/35/EU applies until it is replaced in 2013 - 2012-01-01: Member States must apply Article 21(2)(d) from this date at the latest, so an application for notification has to carry an accreditation certificate from a national accreditation body attesting that the inspection body meets Article 20 - 2013-07-01: Member States must apply the national measures to pressure receptacles, their valves and other accessories used for the carriage of UN No 1745 bromine pentafluoride, UN No 1746 bromine trifluoride and UN No 2495 iodine pentafluoride from this date at the latest; in Denmark executive order nr. 685 of 10 June 2013 enters into force the same day and repeals executive order nr. 732 of 27 June 2011 - 2018-12-01: Sikkerhedsstyrelsen takes over the control of transportable pressure equipment in Denmark; under its pressure-equipment guidance Arbejdstilsynet keeps equipment made to order and equipment imported for offshore oil and gas activities under the offshore safety act - 2021-07-16: Regulation (EU) 2019/1020 applies: it deletes Chapter III, Articles 15 to 29, of Regulation (EC) No 765/2008, which Articles 16 and 30 of the directive cite, and lists the directive as point 37 of its Annex I and point 15 of its Annex II, the legislation without provisions on penalties; the directive is not in the Article 4(5) list, so that article's duty to have an economic operator established in the Union does not follow from it - 2024-11-28: Directive (EU) 2024/2749 enters into force, the twentieth day after publication in OJ L of 8 November 2024; it adds the definitions of crisis-relevant goods and internal market emergency mode and Chapter 5a on emergency procedures to the directive - 2025-04-22: Corrigendum to Directive (EU) 2024/2749 published in OJ L, 2025/90340 of 22 April 2025. It is an English-language corrigendum and corrects one thing in this directive: in the Article 33c(9) inserted into Directive 2010/35/EU, the cross-reference to the conformity assessment procedures was corrected from 'Article 18' to 'Article 12' — Article 12 being the conformity provision of this directive. It appears as the C1 mark at Article 33c(9) of the consolidated text - 2025-06-30: Deadline for Member States to apply Commission Delegated Directive (EU) 2025/149, which replaced Sections I.1, II.1 and III.1 of the Annexes to Directive 2008/68/EC with the ADR, RID and ADN as applicable with effect from 1 January 2025; those editions are the technical requirements the Pi marking now attests - 2026-01-01: Sikkerhedsstyrelsen becomes the department Markedsovervågning of Erhvervsstyrelsen and continues the same tasks, including the control of transportable pressure equipment - 2026-05-29: Deadline for Member States to adopt and publish the measures transposing Directive (EU) 2024/2749 - 2026-05-30: National measures transposing Directive (EU) 2024/2749 apply, so the emergency procedures of Articles 33a to 33d can be activated; in Denmark executive order nr. 483 of 28 May 2026 enters into force, repeals executive order nr. 685 of 10 June 2013, moves the Danish rules onto the product act, replaces Arbejdstilsynet by Erhvervsstyrelsen and adds the emergency procedures as § 7 and § 8 ## What you must do ### Manufacturer (including brand owners and anyone who modifies equipment already on the market) - When placing transportable pressure equipment on the market, ensure it has been designed, manufactured and documented in accordance with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive, which since 30 June 2025 means the ADR, RID and ADN as applicable with effect from 1 January 2025. The directive lays down no technical requirements of its own, so the construction, testing and marking rules come from Chapter 6.2 for pressure receptacles and Chapter 6.8 for tanks, battery vehicles and wagons and multiple-element gas containers. - Have the conformity of the equipment demonstrated through the conformity assessment process set out in the Annexes to Directive 2008/68/EC, carried out by a body notified for that activity under the directive; a separate conformity assessment may be carried out for demountable parts of refillable equipment, and certificates of conformity assessment issued by a notified body are valid in all Member States. - Affix the Pi marking, and only to equipment that meets the conformity assessment requirements in the Annexes to Directive 2008/68/EC and the directive or the reassessment requirements of Article 13. Respect the proportions of the graduated drawing in Article 15(1), a minimum height of 5 mm, or 2,5 mm for equipment with a diameter of 140 mm or less, affix it visibly, legibly and permanently to the equipment or its data plate and to demountable parts with a direct safety function, before the equipment or those parts are placed on the market, and follow it with the identification number of the notified body involved in the initial inspections and tests, affixed by that body or under its instructions. - Do not affix markings, signs or inscriptions that are likely to mislead third parties as to the meaning or form of the Pi marking, and affix any other marking so that the visibility, legibility and meaning of the Pi marking are not impaired; the Pi marking is the only marking that attests conformity for the purposes of the directive, and by affixing it or having it affixed you take responsibility for the conformity of the equipment with all applicable requirements. - Keep the technical documentation specified in the Annexes to Directive 2008/68/EC for the period specified therein, and give the competent national authority, on a reasoned request, all the information and documentation necessary to demonstrate conformity, in a language easily understood by that authority; cooperate with the authority at its request on any action taken to eliminate the risks posed by equipment you have placed on the market. - Keep the technical documentation specified in the Annexes to Directive 2008/68/EC for the period specified there. - On a reasoned request, give the competent national authority all information and documentation necessary to demonstrate conformity, in a language it easily understands, and cooperate at its request on any action to eliminate the risks posed by the equipment. - Where you consider or have reason to believe that equipment you placed on the market is not in conformity, immediately take the corrective measures necessary to bring it into conformity, to withdraw it or to recall it, and where it presents a risk immediately inform the competent national authorities of the Member States in which you made it available, giving details of the non-compliance and of the corrective measures; document all such instances of non-compliance and corrective measures. - Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive, and on request from the market surveillance authority identify, for a period of at least 10 years, every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. - Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. - On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. - During an activated internal market emergency mode for equipment designated as crisis-relevant goods, declare on your sole responsibility that equipment placed on the market under an Article 33c authorisation complies with all applicable requirements of the Annexes to Directive 2008/68/EC and the directive, complete the conformity assessment procedures the competent national authority indicates, and do not affix the Pi marking to that equipment. ### Authorised representative - Act only under a written mandate from the manufacturer, and remember what cannot be delegated: the obligations to design, manufacture and document the equipment in accordance with the Annexes to Directive 2008/68/EC, to affix the Pi marking after conformity has been demonstrated and to draw up the technical documentation stay with the manufacturer. - Act only under a written mandate from the manufacturer. - The obligations to design, manufacture and document the equipment in accordance with the Annexes to Directive 2008/68/EC, to affix the Pi marking after conformity has been demonstrated and to draw up the technical documentation stay with the manufacturer and cannot form part of your mandate. - Keep the technical documentation at the disposal of the national surveillance authorities for at least the period specified in the Annexes to Directive 2008/68/EC for manufacturers. - On a reasoned request from a competent national authority, provide all the information and documentation necessary to demonstrate the conformity of the equipment in a language easily understood by that authority, and cooperate with the competent national authorities at their request on any action taken to eliminate the risks posed by equipment covered by your mandate. - Make sure your identity and address are indicated on the certificate of conformity specified in the Annexes to Directive 2008/68/EC. - Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. - On request from the market surveillance authority, identify for a period of at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. ### Importer - Place on the Union market only transportable pressure equipment that is in conformity with the Annexes to Directive 2008/68/EC and with the directive, and before placing it ensure that the appropriate conformity assessment procedure has been carried out by the manufacturer, that the manufacturer has drawn up the technical documentation, that the equipment bears the Pi marking and that it is accompanied by the certificate of conformity specified in those Annexes. - Where you consider or have reason to believe that the equipment is not in conformity, do not place it on the market until it has been brought into conformity, and where it presents a risk inform the manufacturer and the market surveillance authorities. - Indicate your name and the address at which you can be contacted either in, or attached to, the certificate of conformity specified in the Annexes to Directive 2008/68/EC; this is the contact address distributors have to check before they make the equipment available. - Ensure that, while the equipment is under your responsibility, storage or transport conditions do not jeopardise its compliance with the requirements set out in the Annexes to Directive 2008/68/EC. - Where you consider or have reason to believe that equipment you placed on the market is not in conformity, immediately take the corrective measures necessary to bring it into conformity, to withdraw it or to recall it, and where it presents a risk immediately inform the manufacturer and the competent national authorities of the Member States in which you made it available, giving details of the non-compliance and of the corrective measures; document all such instances. - Keep a copy of the technical documentation at the disposal of the market surveillance authorities for at least the period specified in the Annexes to Directive 2008/68/EC for manufacturers, ensure it can be made available on request, and on a reasoned request provide all information and documentation necessary to demonstrate conformity in a language easily understood by the authority, cooperating on action to eliminate risks. - Keep a copy of the technical documentation at the disposal of the market surveillance authorities for at least the period specified in the Annexes to Directive 2008/68/EC for manufacturers, and ensure it can be made available on request. - On a reasoned request, give the competent national authority all information and documentation necessary to demonstrate conformity, in a language it easily understands, and cooperate at its request on any action to eliminate the risks posed by the equipment. - Provide operators only with information that complies with the Annexes to Directive 2008/68/EC and the directive, and identify your suppliers and customers to the market surveillance authority for at least 10 years. - Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. - On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. - If you place equipment on the market under your own name or trademark, or modify equipment already placed on the market in such a way that compliance with the applicable requirements may be affected, you are considered a manufacturer and carry the full Article 4 obligations. ### Distributor (any supplier in the chain other than the manufacturer or importer) - Make available on the Union market only transportable pressure equipment that is in conformity with the Annexes to Directive 2008/68/EC and with the directive, and before making it available verify that it bears the Pi marking and that it is accompanied by the certificate of conformity and by the importer's contact address. - Where you consider or have reason to believe that equipment is not in conformity, do not make it available until it has been brought into conformity, and where it presents a risk inform the manufacturer or the importer and the market surveillance authorities. - Ensure that, while the equipment is under your responsibility, storage or transport conditions do not jeopardise its compliance with the requirements set out in the Annexes to Directive 2008/68/EC. - Where you consider or have reason to believe that equipment you made available is not in conformity, make sure the corrective measures to bring it into conformity, to withdraw it or to recall it are taken, and where it presents a risk immediately inform the manufacturer, the importer where relevant and the competent national authorities of the Member States in which you made it available, giving details of the non-compliance and of the corrective measures; document all such instances. - On a reasoned request from the competent national authority, provide all the information and documentation necessary to demonstrate conformity in a language easily understood by that authority, and cooperate on any action taken to eliminate the risks posed by equipment you made available. - Provide operators only with information that complies with the Annexes to Directive 2008/68/EC and the directive, and identify your suppliers and customers to the market surveillance authority for at least 10 years. - Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. - On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. - If you sell equipment under your own name or trademark, or modify equipment already placed on the market in such a way that compliance may be affected, you are considered a manufacturer and carry the full Article 4 obligations. ### Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it) - As owner, do not make available or use transportable pressure equipment that you consider or have reason to believe is not in conformity with the Annexes to Directive 2008/68/EC, including the requirements for periodic inspection, or with the directive, until it has been brought into conformity; where it presents a risk inform the manufacturer, the importer or the distributor and the market surveillance authorities, and document all such instances of non-compliance and the corrective measures. - As owner, ensure that, while the equipment is under your responsibility, storage or transport conditions do not jeopardise its compliance with the Annexes to Directive 2008/68/EC, and give operators only information that complies with those Annexes and the directive. - As owner, ensure that, while the equipment is under your responsibility, storage or transport conditions do not jeopardise its compliance with the Annexes to Directive 2008/68/EC. - As owner, give operators only information that complies with the Annexes to Directive 2008/68/EC and the directive. - As operator, use only transportable pressure equipment that is in conformity with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive, and where the equipment presents a risk inform the owner and the market surveillance authorities. Use covers filling, temporary storage linked to carriage, emptying and refilling. - Keep equipment already bearing the Pi marking or the markings of Directives 84/525/EEC, 84/526/EEC, 84/527/EEC or 1999/36/EC inside its inspection regime: it must meet the specifications of the documentation according to which it was manufactured and be subject to periodic inspections, intermediate inspections and exceptional checks in accordance with the Annexes to Directive 2008/68/EC and Chapters 3 and 4 of the directive, and the inspection date is marked with the identification number of the notified body responsible for the periodic inspection. - Where older equipment does not bear the Directive 1999/36/EC markings, request a reassessment of conformity: make available to a type A notified body conforming to EN ISO/IEC 17020:2004 and notified for reassessment the information that identifies the equipment precisely, including origin, design rules, details of the porous material for acetylene cylinders, any prescribed restrictions on use and any notes on possible damage or repairs carried out. By affixing or having affixed the Pi marking after a satisfactory reassessment you take responsibility for the conformity of the equipment with all applicable requirements as they stand at the time of reassessment. - Cooperate as necessary with the market surveillance authorities when they evaluate equipment presenting a risk, including granting access to your premises and providing samples, ensure that all appropriate corrective action is taken in respect of equipment you have made available or are using throughout the Union, and identify your suppliers and customers to the authority for at least 10 years. - Cooperate as necessary with the market surveillance authorities when they evaluate equipment presenting a risk, including granting access to your premises and providing samples. - Ensure that all appropriate corrective action is taken in respect of equipment presenting a risk that you have made available or are using throughout the Union. - On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. - Check the national rules where the equipment is stored or used: Member States may establish on-site requirements for mid- or long-term storage or on-site use, may maintain the Annex II provisions on connection devices and colour codes, and Member States in which the ambient temperature is regularly lower than – 20 °C may impose more stringent standards for the operating temperature of material intended for equipment used in national transport of dangerous goods, until reference temperatures for climatic zones are added to the Annexes to Directive 2008/68/EC; in that case the identification number of the notified body in the Pi marking is followed by '– 40 °C' or another relevant marking approved by the competent authority, on the equipment and on demountable parts with a direct safety function. - Private individuals using transportable pressure equipment for personal or domestic use or for leisure or sporting activities are outside the owner obligations of Article 8; the equipment itself, and any business that fills, stores, empties or refills it, remain covered. ## Requirements Each duty above as an identified requirement (43); ids are permanent and shared with the compliance engine. ### evidence - `tped-mfr-ensure-has-been` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, before-market) — When placing transportable pressure equipment on the market, ensure it has been designed, manufactured and documented in accordance with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive, which since 30 June 2025 means the ADR, RID and ADN as applicable with effect from 1 January 2025. The directive lays down no technical requirements of its own, so the construction, testing and marking rules come from Chapter 6.2 for pressure receptacles and Chapter 6.8 for tanks, battery vehicles and wagons and multiple-element gas containers. [Art. 2, points (1) and (2), and Art. 4(1); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0068-20260512 · Annex I Section I.1, Annex II Section II.1 and Annex III Section III.1] - `tped-mfr-provide-compliant-operator-information` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, ongoing) — Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. [Art. 4(7)] - `tped-mfr-during-activated-internal` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, on-event) — During an activated internal market emergency mode for equipment designated as crisis-relevant goods, declare on your sole responsibility that equipment placed on the market under an Article 33c authorisation complies with all applicable requirements of the Annexes to Directive 2008/68/EC and the directive, complete the conformity assessment procedures the competent national authority indicates, and do not affix the Pi marking to that equipment. [Art. 33a, Art. 33c(5), (6) and (7)] - `tped-oth-act-under-mandate` (Authorised representative, company, before-market) — Act only under a written mandate from the manufacturer. [Art. 5(1)] - `tped-oth-provide-operators-information` (Authorised representative, product, before-market) — Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. [Art. 5(4)] - `tped-imp-provide-compliant-operator-information` (Importer, product, ongoing) — Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. [Art. 6(8)] - `tped-dist-provide-compliant-operator-information` (Distributor (any supplier in the chain other than the manufacturer or importer), product, ongoing) — Provide operators only with information that complies with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive. [Art. 7(5)] - `tped-op-provide-compliant-operator-information` (Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it), product, ongoing) — As owner, give operators only information that complies with the Annexes to Directive 2008/68/EC and the directive. [Art. 8(3)] ### data - `tped-oth-make-sure-identity` (Authorised representative, product, before-market) — Make sure your identity and address are indicated on the certificate of conformity specified in the Annexes to Directive 2008/68/EC. [Art. 5(3)] - `tped-imp-indicate-name-address` (Importer, product, before-market) — Indicate your name and the address at which you can be contacted either in, or attached to, the certificate of conformity specified in the Annexes to Directive 2008/68/EC; this is the contact address distributors have to check before they make the equipment available. [Art. 6(3) and Art. 7(1)] ### mark - `tped-mfr-affix-marking-equipment` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, before-market) — Affix the Pi marking, and only to equipment that meets the conformity assessment requirements in the Annexes to Directive 2008/68/EC and the directive or the reassessment requirements of Article 13. Respect the proportions of the graduated drawing in Article 15(1), a minimum height of 5 mm, or 2,5 mm for equipment with a diameter of 140 mm or less, affix it visibly, legibly and permanently to the equipment or its data plate and to demountable parts with a direct safety function, before the equipment or those parts are placed on the market, and follow it with the identification number of the notified body involved in the initial inspections and tests, affixed by that body or under its instructions. [Art. 14(1) to (6) and Art. 15(1) to (6)] - `tped-mfr-affix-markings-signs` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, before-market) — Do not affix markings, signs or inscriptions that are likely to mislead third parties as to the meaning or form of the Pi marking, and affix any other marking so that the visibility, legibility and meaning of the Pi marking are not impaired; the Pi marking is the only marking that attests conformity for the purposes of the directive, and by affixing it or having it affixed you take responsibility for the conformity of the equipment with all applicable requirements. [Art. 14(3), (4) and (5)] ### decision - `tped-imp-place-market-has` (Importer, product, on-event) — Where you consider or have reason to believe that the equipment is not in conformity, do not place it on the market until it has been brought into conformity, and where it presents a risk inform the manufacturer and the market surveillance authorities. [Art. 6(2)] - `tped-dist-make-available-has` (Distributor (any supplier in the chain other than the manufacturer or importer), product, on-event) — Where you consider or have reason to believe that equipment is not in conformity, do not make it available until it has been brought into conformity, and where it presents a risk inform the manufacturer or the importer and the market surveillance authorities. [Art. 7(1)] - `tped-op-owner-make-available` (Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it), product, on-event) — As owner, do not make available or use transportable pressure equipment that you consider or have reason to believe is not in conformity with the Annexes to Directive 2008/68/EC, including the requirements for periodic inspection, or with the directive, until it has been brought into conformity; where it presents a risk inform the manufacturer, the importer or the distributor and the market surveillance authorities, and document all such instances of non-compliance and the corrective measures. [Art. 8(1)] ### procedure - `tped-mfr-have-conformity-equipment` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, before-market) — Have the conformity of the equipment demonstrated through the conformity assessment process set out in the Annexes to Directive 2008/68/EC, carried out by a body notified for that activity under the directive; a separate conformity assessment may be carried out for demountable parts of refillable equipment, and certificates of conformity assessment issued by a notified body are valid in all Member States. [Art. 2, points (15) and (24), Art. 4(2), Art. 12(1) and (3) and Art. 26(1)] ### submission - `tped-mfr-immediately-take-corrective` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, on-event) — Where you consider or have reason to believe that equipment you placed on the market is not in conformity, immediately take the corrective measures necessary to bring it into conformity, to withdraw it or to recall it, and where it presents a risk immediately inform the competent national authorities of the Member States in which you made it available, giving details of the non-compliance and of the corrective measures; document all such instances of non-compliance and corrective measures. [Art. 4(4) and Art. 4(5)] - `tped-imp-immediately-take-corrective` (Importer, product, on-event) — Where you consider or have reason to believe that equipment you placed on the market is not in conformity, immediately take the corrective measures necessary to bring it into conformity, to withdraw it or to recall it, and where it presents a risk immediately inform the manufacturer and the competent national authorities of the Member States in which you made it available, giving details of the non-compliance and of the corrective measures; document all such instances. [Art. 6(5)] - `tped-dist-make-sure-corrective` (Distributor (any supplier in the chain other than the manufacturer or importer), product, on-event) — Where you consider or have reason to believe that equipment you made available is not in conformity, make sure the corrective measures to bring it into conformity, to withdraw it or to recall it are taken, and where it presents a risk immediately inform the manufacturer, the importer where relevant and the competent national authorities of the Member States in which you made it available, giving details of the non-compliance and of the corrective measures; document all such instances. [Art. 7(3)] - `tped-op-request-reassessment-conformity` (Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it), product, before-market) — Where older equipment does not bear the Directive 1999/36/EC markings, request a reassessment of conformity: make available to a type A notified body conforming to EN ISO/IEC 17020:2004 and notified for reassessment the information that identifies the equipment precisely, including origin, design rules, details of the porous material for acetylene cylinders, any prescribed restrictions on use and any notes on possible damage or repairs carried out. By affixing or having affixed the Pi marking after a satisfactory reassessment you take responsibility for the conformity of the equipment with all applicable requirements as they stand at the time of reassessment. [Art. 13 and Annex III, points 2, 4 and 8] - `tped-op-take-corrective-action` (Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it), product, on-event) — Ensure that all appropriate corrective action is taken in respect of equipment presenting a risk that you have made available or are using throughout the Union. [Art. 32(2)] ### verification - `tped-imp-place-union-market` (Importer, product, before-market) — Place on the Union market only transportable pressure equipment that is in conformity with the Annexes to Directive 2008/68/EC and with the directive, and before placing it ensure that the appropriate conformity assessment procedure has been carried out by the manufacturer, that the manufacturer has drawn up the technical documentation, that the equipment bears the Pi marking and that it is accompanied by the certificate of conformity specified in those Annexes. [Art. 6(1) and Art. 6(2)] - `tped-dist-make-available-union` (Distributor (any supplier in the chain other than the manufacturer or importer), product, before-market) — Make available on the Union market only transportable pressure equipment that is in conformity with the Annexes to Directive 2008/68/EC and with the directive, and before making it available verify that it bears the Pi marking and that it is accompanied by the certificate of conformity and by the importer's contact address. [Art. 7(1)] ### standing - `tped-mfr-keep-technical-documentation-adr` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), product, ongoing) — Keep the technical documentation specified in the Annexes to Directive 2008/68/EC for the period specified there. [Art. 4(3)] - `tped-mfr-provide-information-request` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), company, ongoing) — On a reasoned request, give the competent national authority all information and documentation necessary to demonstrate conformity, in a language it easily understands, and cooperate at its request on any action to eliminate the risks posed by the equipment. [Art. 4(6)] - `tped-mfr-identify-suppliers-customers` (Manufacturer (including brand owners and anyone who modifies equipment already on the market), company, ongoing) — On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. [Art. 11] - `tped-oth-keep-technical-documentation` (Authorised representative, product, ongoing) — Keep the technical documentation at the disposal of the national surveillance authorities for at least the period specified in the Annexes to Directive 2008/68/EC for manufacturers. [Art. 5(2)(a)] - `tped-oth-provide-information-documentation` (Authorised representative, company, ongoing) — On a reasoned request from a competent national authority, provide all the information and documentation necessary to demonstrate the conformity of the equipment in a language easily understood by that authority, and cooperate with the competent national authorities at their request on any action taken to eliminate the risks posed by equipment covered by your mandate. [Art. 5(2)(b) and (c)] - `tped-oth-identify-period-least` (Authorised representative, company, ongoing) — On request from the market surveillance authority, identify for a period of at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. [Art. 11] - `tped-imp-ensure-while-equipment` (Importer, company, ongoing) — Ensure that, while the equipment is under your responsibility, storage or transport conditions do not jeopardise its compliance with the requirements set out in the Annexes to Directive 2008/68/EC. [Art. 6(4)] - `tped-imp-keep-technical-documentation-copy` (Importer, product, ongoing) — Keep a copy of the technical documentation at the disposal of the market surveillance authorities for at least the period specified in the Annexes to Directive 2008/68/EC for manufacturers, and ensure it can be made available on request. [Art. 6(6)] - `tped-imp-provide-information-request` (Importer, company, ongoing) — On a reasoned request, give the competent national authority all information and documentation necessary to demonstrate conformity, in a language it easily understands, and cooperate at its request on any action to eliminate the risks posed by the equipment. [Art. 6(7)] - `tped-imp-identify-suppliers-customers` (Importer, company, ongoing) — On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. [Art. 11] - `tped-dist-ensure-while-equipment` (Distributor (any supplier in the chain other than the manufacturer or importer), company, ongoing) — Ensure that, while the equipment is under your responsibility, storage or transport conditions do not jeopardise its compliance with the requirements set out in the Annexes to Directive 2008/68/EC. [Art. 7(2)] - `tped-dist-provide-information-documentation` (Distributor (any supplier in the chain other than the manufacturer or importer), company, ongoing) — On a reasoned request from the competent national authority, provide all the information and documentation necessary to demonstrate conformity in a language easily understood by that authority, and cooperate on any action taken to eliminate the risks posed by equipment you made available. [Art. 7(4)] - `tped-dist-identify-suppliers-customers` (Distributor (any supplier in the chain other than the manufacturer or importer), company, ongoing) — On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. [Art. 11] - `tped-op-keep-storage-transport-conditions` (Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it), company, ongoing) — As owner, ensure that, while the equipment is under your responsibility, storage or transport conditions do not jeopardise its compliance with the Annexes to Directive 2008/68/EC. [Art. 8(2)] - `tped-op-cooperate-market-surveillance` (Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it), company, ongoing) — Cooperate as necessary with the market surveillance authorities when they evaluate equipment presenting a risk, including granting access to your premises and providing samples. [Art. 30(1) and (3)] - `tped-op-identify-suppliers-customers` (Owner or operator (the businesses that own transportable pressure equipment and the businesses that fill, store, empty and refill it), company, ongoing) — On request from the market surveillance authority, identify for at least 10 years every economic operator that supplied you with transportable pressure equipment and every economic operator to whom you supplied it. [Art. 11] ## Penalties The directive leaves penalties to the Member States. Article 14(7) requires them to ensure the correct implementation of the rules governing the Pi marking, to take appropriate action in the event of improper use of the marking and to provide for penalties for infringements, which may include criminal sanctions for serious infringements and which must be proportionate to the seriousness of the offence and constitute an effective deterrent against improper use. Because the directive is listed as point 15 of Annex II to Regulation (EU) 2019/1020, the Union harmonisation legislation without provisions on penalties, Article 41 of that regulation additionally requires Member States to lay down effective, proportionate and dissuasive penalties for infringements of it that impose obligations on economic operators. The enforcement route runs through Articles 30 to 33: market surveillance authorities evaluate equipment they have sufficient reason to believe presents a risk to the health or safety of persons or to other aspects of public interest protection, require the economic operator to take corrective action, to withdraw the equipment or to recall it within a reasonable period commensurate with the risk, inform the relevant notified body, and where the operator does not act take provisional measures prohibiting or restricting the making available on their national market, withdrawing or recalling the equipment and notify the Commission and the other Member States; a measure no Member State or the Commission objects to within two months is deemed justified, and disputes go through the Union safeguard procedure. Compliant equipment that still presents a risk can be dealt with the same way, and formal non-compliance, a Pi marking affixed in violation of Articles 12, 13, 14 or 15, a missing Pi marking, technical documentation that is not available or not complete, or any failure to comply with the Annexes to Directive 2008/68/EC and the directive, must be ended, failing which the equipment is restricted, prohibited, recalled or withdrawn. In Denmark, executive order nr. 483 of 28 May 2026 punishes with a fine, unless a higher penalty is due under other law, breaches of its § 4 on placing on the market, making available and use, of § 7, stk. 3, on the Danish or English information and labelling of crisis-relevant goods and of the directive reproduced in its annex 1, as well as failure to comply with decisions, orders or prohibitions, with corporate liability under chapter 5 of the criminal code; the product act lists the directive as product area nr. 6 and gives the control authority orders to warn users and to stop misleading marketing, prohibitions, and orders to remedy, to stop sales, to withdraw, recall or destroy, and fines. The product act's marking provision (section 15) reaches only the CE marking, which transportable pressure equipment does not bear; a Pi marking affixed in violation of Articles 12 to 15 is instead a breach of annex 1 to the executive order, punishable by a fine under its section 11(1)(1), and the control authority acts through the general orders and prohibitions in sections 14 and 16 of the product act. The executive order itself provides only for fines (section 11). The product act's own penalty provision can rise to imprisonment of up to 2 years in aggravating circumstances — danger to safety or health, an accident causing serious injury or death, repetition or systematic breaches for gain — but only for the offences listed in section 37(1)(1) and (3) to (10), that is breaches of the act's own product requirements, of the duty to give the control authority information and access and of its decisions, on product areas covered by section 2(1)(1) to (11) or (13) to (43); transportable pressure equipment is product area nr. 6 and therefore inside that band. It does not extend to breaches of the executive order's own rules, and the points that rest on Article 4 and Article 5 of Regulation (EU) 2019/1020 cannot apply here, because the directive is not in the Article 4(5) list. The control authority is Erhvervsstyrelsen, whose department Markedsovervågning continues the tasks of Sikkerhedsstyrelsen since January 2026; Arbejdstilsynet remains responsible for custom-made transportable pressure equipment and equipment imported for offshore oil and gas activities. ## Checklist 1. Confirm the equipment is transportable pressure equipment: a pressure receptacle with its valves and accessories under Chapter 6.2, or a tank, battery vehicle or wagon or multiple-element gas container with its valves and accessories under Chapter 6.8 of the Annexes to Directive 2008/68/EC, used for Class 2 gases other than those with figures 6 and 7 in the classification code, or for one of the six Annex I substances (Article 2, point (1), and Annex I). 2. Rule out the carve-outs before you invest in a conformity assessment: aerosols of UN No 1950, open cryogenic receptacles, gas cylinders for breathing apparatus, fire extinguishers of UN No 1044, equipment exempted under 1.1.3.2 of the Annexes and equipment exempted from the packaging construction and testing rules by special provisions in 3.3 are not covered at all (Article 2, point (1)). 3. Check the history of the item: new equipment without the old markings follows Article 1(2)(a), equipment already marked under this directive or Directives 84/525/EEC, 84/526/EEC, 84/527/EEC or 1999/36/EC follows Article 1(2)(b) for inspection and use, and pre-1999/36/EC equipment only comes in through the Annex III reassessment of conformity (Article 1(2) and (3) and Article 13). 4. Decide your role for every item, remembering that owners and operators carry duties of their own and that selling under your own brand or modifying equipment makes you the manufacturer (Articles 2, 8, 9 and 10). 5. Design, manufacture and document to the ADR, RID and ADN as brought in by Sections I.1, II.1 and III.1 of the Annexes to Directive 2008/68/EC, which since 30 June 2025 are the editions applicable with effect from 1 January 2025, and keep the technical documentation for the period those Annexes specify (Article 4(1) and (3)). 6. Engage a body notified for the right activity and the right equipment, and note two rules: a competent authority within the meaning of the Annexes to Directive 2008/68/EC may itself be a notified body provided it does not also act as the notifying authority, and a body notified by one Member State is authorised to work in all of them, with the notifying authority that assessed it keeping the monitoring responsibility (Articles 20(2), 21, 22 and 26(3)). 7. Affix the Pi marking correctly: right proportions, minimum height 5 mm or 2,5 mm below a diameter of 140 mm, visible, legible and permanent on the equipment or its data plate and on demountable safety parts, before placing on the market, followed by the notified body's identification number, with no misleading additional markings (Articles 14 and 15). 8. Put the certificate of conformity, the importer's contact address and, for authorised representatives, their identity and address in place, and set up the 10-year supplier and customer traceability the market surveillance authority can ask for (Articles 5(3), 6(3), 7(1) and 11). 9. Plan the service life: track periodic and intermediate inspection intervals and exceptional checks under the Annexes to Directive 2008/68/EC, keep the inspection date and notified body number on the equipment, and withdraw equipment from filling and use until it has been re-inspected (Articles 8, 9, 12(2) and 15(7)). 10. Set up the corrective-action and notification procedure for non-compliance and risk, document every instance, and check whether an internal market emergency mode has activated the Chapter 5a procedures for your equipment (Articles 4 to 9, 30 and 33a). ## Questions ### When did Directive 2010/35/EU on transportable pressure equipment start to apply? The directive was adopted on 16 June 2010, published in the Official Journal on 30 June 2010 and entered into force on 20 July 2010, the twentieth day after publication. Member States had to bring the transposing laws into force by 30 June 2011, and Directives 76/767/EEC, 84/525/EEC, 84/526/EEC, 84/527/EEC and 1999/36/EC were repealed with effect from 1 July 2011, with references to Directive 1999/36/EC construed as references to this directive. Two later dates complete the picture: Article 21(2)(d), the accreditation certificate in an application for notification, had to be applied from 1 January 2012 at the latest, and the rules had to be applied to pressure receptacles, valves and accessories for UN No 1745, UN No 1746 and UN No 2495 from 1 July 2013 at the latest. Directive (EU) 2024/2749 then added the emergency procedures, transposed by 29 May 2026 and applied from 30 May 2026. ### Does my equipment fall under TPED? The directive covers all pressure receptacles, their valves and other accessories when appropriate, as covered in Chapter 6.2 of the Annexes to Directive 2008/68/EC, and tanks, battery vehicles and wagons, multiple-element gas containers and their valves and other accessories, as covered in Chapter 6.8, when the equipment is used in accordance with those Annexes to transport Class 2 gases, excluding gases or articles with figures 6 and 7 in the classification code, and to transport the dangerous substances of other classes listed in Annex I, which are the six UN numbers 1051, 1052, 1745, 1746, 1790 and 2495. Gas cartridges of UN No 2037 are expressly included. Expressly excluded are aerosols of UN No 1950, open cryogenic receptacles, gas cylinders for breathing apparatus, fire extinguishers of UN No 1044, equipment exempted according to 1.1.3.2 of those Annexes and equipment exempted from the rules for the construction and testing of packaging by special provisions in 3.3. The directive also does not apply to equipment placed on the market before the date of implementation of Directive 1999/36/EC that has not been reassessed, or to equipment used exclusively for transport between Member States and third countries. ### What is the Pi marking and how does it differ from the CE marking? The Pi marking indicates that the transportable pressure equipment is in conformity with the applicable conformity assessment requirements set out in the Annexes to Directive 2008/68/EC and in the directive, and it is the only marking that attests that conformity for the directive's purposes; equipment under TPED does not carry a CE marking under this directive. It may be affixed only by the manufacturer, or in the case of reassessment as set out in Annex III, and for gas cylinders previously complying with Directives 84/525/EEC, 84/526/EEC or 84/527/EEC by or under the surveillance of the notified body. It must respect the proportions of the graduated drawing in Article 15(1), be at least 5 mm high, or 2,5 mm for equipment with a diameter of 140 mm or less, be affixed visibly, legibly and permanently to the equipment or its data plate and to demountable parts with a direct safety function before they are placed on the market, and be followed by the identification number of the notified body involved in the initial inspections and tests. Markings likely to mislead third parties as to its meaning or form are prohibited. ### Who carries out periodic and intermediate inspections, and what happens if a cylinder is overdue? Periodic inspection, intermediate inspection and exceptional check are defined by reference to the Annexes to Directive 2008/68/EC, which set both the procedures and the intervals, and they are carried out by bodies notified under the directive in accordance with the terms of their notification. Equipment that already bears the Pi marking or the markings of Directives 84/525/EEC, 84/526/EEC, 84/527/EEC or 1999/36/EC stays subject to them for its whole service life and must also meet the specifications of the documentation according to which it was manufactured. The date of the periodic or, where appropriate, intermediate inspection is marked together with the identification number of the notified body responsible. An owner who considers or has reason to believe that equipment does not comply with those Annexes, including the periodic inspection requirements, must neither make it available nor use it until it has been brought into conformity, and an operator may use only conforming equipment, so an overdue receptacle cannot lawfully be filled or used until it has been re-inspected. Reports of periodic inspections, intermediate inspections and exceptional checks issued by a notified body are valid in all Member States. ### How does reassessment of conformity work for older cylinders and tanks? Reassessment of conformity is the procedure undertaken at the request of the owner or operator for the subsequent assessment of equipment manufactured and placed on the market before the date of implementation of Directive 1999/36/EC (1 July 2001, or 1 July 2005 for pressure drums, bundles of cylinders and tanks), and Annex III sets it out. The owner or operator gives a type A notified body conforming to EN ISO/IEC 17020:2004 and notified for reassessment the information that identifies the equipment precisely, including origin, design rules and, for acetylene cylinders, details of the porous material, together with any prescribed restrictions on use and any notes on possible damage or repairs. The body assesses, on that information and where appropriate further inspections, whether the equipment affords at least the same degree of safety as equipment under the Annexes to Directive 2008/68/EC. If the result is satisfactory the equipment goes through a periodic inspection; if that is met, the Pi marking is applied by or under the surveillance of the notified body responsible for the periodic inspection, followed by its identification number, and a certificate of reassessment is issued. For series-produced pressure receptacles a Member State may allow individual receptacles to be reassessed by the body notified for periodic inspection once the type has been assessed by a type A body and a certificate of type reassessment issued, which must state that it does not authorise manufacture. ### Who enforces TPED in Denmark? The directive is implemented by executive order nr. 483 of 28 May 2026 on the construction of transportable pressure equipment, in force from 30 May 2026, which reproduces the directive as amended as its annex 1 and replaced executive order nr. 685 of 10 June 2013. The order rests on the product act, which lists the directive as product area nr. 6 and names Erhvervsstyrelsen as the control authority; Sikkerhedsstyrelsen has carried out the control of transportable pressure equipment since 1 December 2018 and is since January 2026 the department Markedsovervågning of Erhvervsstyrelsen, while the control authority's own guidance on pressure equipment states that Arbejdstilsynet remains the market surveillance authority for pressure equipment and pressure vessels made to order and for equipment imported from third countries for offshore oil and gas activities under the offshore safety act. That guidance is written for pressure equipment and pressure vessels, not for transportable pressure equipment, whose scope is set by the ADR and RID annexes to Directive 2008/68/EC and knows no 'made to order' category; for transportable pressure equipment only the offshore leg is capable of applying. That split works through section 9(2) of the product act, under which the authority that supervises other legislation on specific risks for particular products is the relevant control authority; executive order nr. 483 of 28 May 2026 does not mention Arbejdstilsynet at all, and the product act does not name it for this product area. Erhvervsstyrelsen designates the Danish notified bodies, which must be legal persons established in Denmark accredited by DANAK for the task and meeting Articles 20, 21, 26, 27 and 29 of the directive, supervises them, hears complaints against their decisions within 4 weeks, may allow the simplified reassessment of series-produced receptacles and issues the emergency authorisations. The road, rail and inland waterway carriage rules themselves are enforced by the transport and emergency-management authorities rather than by Erhvervsstyrelsen. ### What did Directive (EU) 2024/2749 change for transportable pressure equipment? It added the definitions of crisis-relevant goods and internal market emergency mode to Article 2 and inserted Chapter 5a, Articles 33a to 33d, together with a committee procedure in Article 38a that uses the committee on the transport of dangerous goods established by Article 9 of Directive 2008/68/EC. The measures apply only if the Commission has adopted an implementing act under Article 28 of Regulation (EU) 2024/2747 for transportable pressure equipment, only to equipment designated as crisis-relevant goods and only during an activated internal market emergency mode. Notified bodies then prioritise applications for such equipment without disproportionate extra cost and make reasonable efforts to increase testing capacity; a Member State may authorise the placing on the market on its territory of specific equipment for which the notified-body procedures have not been carried out but compliance has been demonstrated as the authorisation prescribes; the Commission can extend the authorisation Union-wide, in which case the equipment must carry the information that it is placed on the market as a crisis-relevant good; such equipment does not bear the Pi marking and Article 16 on free movement does not apply to it; and market surveillance for the listed equipment is prioritised with mutual assistance between authorities. Member States apply their transposing measures from 30 May 2026. ### Do owners and operators of gas cylinders have obligations of their own? Yes. The directive is unusual among the product directives in placing duties on the people who own and use the equipment, not only on those who place it on the market. An owner must not make available or use equipment it considers or has reason to believe is not in conformity with the Annexes to Directive 2008/68/EC, including the periodic inspection requirements, until it has been brought into conformity, must inform the manufacturer, importer or distributor and the market surveillance authorities where it presents a risk, must document those instances and the corrective measures, must keep storage and transport conditions from jeopardising compliance and may give operators only compliant information. An operator, meaning anyone who fills, temporarily stores in connection with carriage, empties or refills the equipment, may use only conforming equipment and must inform the owner and the market surveillance authorities where the equipment presents a risk. Both count as economic operators when they act in the course of a commercial or public service activity and must identify their suppliers and customers for at least 10 years. Article 8 does not apply to private individuals using the equipment for personal or domestic use or for leisure or sporting activities. ## What changed - 2026-09-13 (guidance): **Guide rebuilt on the SPEC-62 model from the consolidated text** — The guide was rewritten from the consolidated text of Directive 2010/35/EU of 30 May 2026, the base act, Directive (EU) 2024/2749, the consolidated text of Directive 2008/68/EC of 12 May 2026, Commission Delegated Directive (EU) 2025/149, Regulation (EU) 2019/1020, Directive 2014/68/EU, the Danish executive orders nr. 685 of 10 June 2013 and nr. 483 of 28 May 2026, the product act and the Sikkerhedsstyrelsen pages. Several statements in the earlier guide are corrected: the technical rules come from Chapters 6.2 and 6.8 of the Annexes to Directive 2008/68/EC rather than from ADR, RID and ADN in the abstract, and those Annexes have referred to the 1 January 2025 editions since Commission Delegated Directive (EU) 2025/149; the exact carve-outs of Article 2, point (1), and the six Annex I substances replace the earlier general description of the scope; the Pi marking rules of Articles 14 and 15, including the 5 mm and 2,5 mm minimum heights, are stated; the earlier claim that the repealed directive was Directive 1999/36/EC alone is corrected to the five repealed directives; the staggered application dates of 1 July 2011, 1 January 2012 and 1 July 2013 are added; the earlier statement that Sikkerhedsstyrelsen is the competent authority is corrected to Erhvervsstyrelsen as control authority through its department Markedsovervågning, with Arbejdstilsynet for custom-made and offshore equipment; the Danish implementing order is executive order nr. 483 of 28 May 2026; and the market surveillance reference in Articles 16 and 30 is read as Regulation (EU) 2019/1020. - 2026-05-30 (applies): **Emergency procedures apply; Danish executive order nr. 483/2026 in force** — Member States apply their measures transposing Directive (EU) 2024/2749 from 30 May 2026, so the Chapter 5a procedures for crisis-relevant transportable pressure equipment can be activated by the Commission during an internal market emergency mode. In Denmark executive order nr. 483 of 28 May 2026 enters into force, repeals executive order nr. 685 of 10 June 2013, places the Danish rules under the product act, replaces Arbejdstilsynet by Erhvervsstyrelsen as the authority that designates and supervises notified bodies and hears complaints, adds § 7 and § 8 on the emergency procedures with Danish or English labelling, and reissues the directive as amended as annex 1. - 2025-06-30 (applies): **The 1 January 2025 editions of the ADR, RID and ADN become the technical baseline** — Commission Delegated Directive (EU) 2025/149 of 15 November 2024 replaced Section I.1 of Annex I, Section II.1 of Annex II and Section III.1 of Annex III to Directive 2008/68/EC with the ADR, RID and ADN as applicable with effect from 1 January 2025, and Member States had to bring the transposing provisions into force by 30 June 2025. Because Directive 2010/35/EU defines conformity assessment, the technical documentation, periodic and intermediate inspection and exceptional checks by reference to those Annexes, the content of every one of those obligations moved with them. - 2025-04-22 (amendment): **Corrigendum to Directive (EU) 2024/2749 published** — Corrigendum to Directive (EU) 2024/2749 published in OJ L, 2025/90340 of 22 April 2025. It is an English-language corrigendum and corrects one thing in this directive: in the Article 33c(9) inserted into Directive 2010/35/EU, the cross-reference to the conformity assessment procedures was corrected from 'Article 18' to 'Article 12' — Article 12 being the conformity provision of this directive. It appears as the C1 mark at Article 33c(9) of the consolidated text. - 2024-11-28 (amendment): **Directive (EU) 2024/2749 enters into force** — The directive of 9 October 2024, published in OJ L on 8 November 2024, adds the definitions of crisis-relevant goods and internal market emergency mode to Article 2 of Directive 2010/35/EU and inserts Chapter 5a, Articles 33a to 33d, on the prioritisation of conformity assessment, national authorisations without the notified-body procedures, prioritised market surveillance and mutual assistance during an internal market emergency mode, together with the committee procedure of Article 38a; transposition by 29 May 2026. - 2021-07-16 (applies): **Regulation (EU) 2019/1020 replaces the market surveillance articles of Regulation (EC) No 765/2008** — Chapter III, Articles 15 to 29, of Regulation (EC) No 765/2008, which Articles 16 and 30 of the directive cite, is deleted, and Article 39(2) of Regulation (EU) 2019/1020 provides that references to the deleted provisions of Regulation (EC) No 765/2008 are construed as references to the regulation and read in accordance with the correlation table in its Annex III: the Article 20 of Regulation (EC) No 765/2008 that Article 30(1) of the directive cites is now Article 19 of the regulation, and the Article 21 it cites for corrective action is now Article 18. Listing the directive as point 37 of Annex I is what brings it inside the regulation's market surveillance chapter in the first place; the directive is also listed as point 15 of its Annex II, the Union harmonisation legislation without provisions on penalties, so Article 41 of the regulation requires effective, proportionate and dissuasive national penalties. The directive is not in the Article 4(5) list, so the regulation's duty to have an economic operator established in the Union responsible for the product does not arise from that article for transportable pressure equipment. - 2018-12-01 (applies): **Sikkerhedsstyrelsen takes over the control of transportable pressure equipment in Denmark** — From 1 December 2018 Sikkerhedsstyrelsen is responsible for the general market surveillance of transportable pressure equipment; under the control authority's guidance on pressure equipment Arbejdstilsynet keeps the responsibility for equipment made to order and for equipment imported from third countries for offshore oil and gas activities covered by the offshore safety act — for transportable pressure equipment only the offshore leg is capable of applying. Since January 2026 Sikkerhedsstyrelsen is the department Markedsovervågning of Erhvervsstyrelsen. - 2013-07-01 (applies): **The directive applies to equipment for UN No 1745, UN No 1746 and UN No 2495; Danish executive order nr. 685/2013 in force** — Member States had to apply the transposing provisions to pressure receptacles, their valves and other accessories used for the carriage of bromine pentafluoride, bromine trifluoride and iodine pentafluoride from 1 July 2013 at the latest. In Denmark executive order nr. 685 of 10 June 2013 entered into force the same day, reproducing the directive as its annex 1 and repealing executive order nr. 732 of 27 June 2011. - 2011-07-01 (applies): **Directive 2010/35/EU replaces the five older directives** — Member States had to bring the transposing laws into force by 30 June 2011, and Directives 76/767/EEC, 84/525/EEC, 84/526/EEC, 84/527/EEC and 1999/36/EC were repealed with effect from 1 July 2011, with references to Directive 1999/36/EC construed as references to this directive. EEC pattern approval certificates issued under Directives 84/525/EEC, 84/526/EEC and 84/527/EEC and EC design-examination certificates issued under Directive 1999/36/EC are recognised as equivalent to the type approval certificates of the Annexes to Directive 2008/68/EC and follow their time-limited recognition rules, and valves and accessories marked under Directive 97/23/EC in accordance with Article 3(4) of Directive 1999/36/EC may still be used. - 2010-07-20 (in-force): **Directive 2010/35/EU enters into force** — Adopted on 16 June 2010 on the basis of Article 91 TFEU to update Directive 1999/36/EC in the light of Directive 2008/68/EC and of the common marketing framework of Decision No 768/2008/EC, and published in OJ L 165 on 30 June 2010, the directive entered into force on the twentieth day after publication. Member States had until 30 June 2011 to transpose it, until 1 January 2012 to apply Article 21(2)(d) and until 1 July 2013 to apply it to equipment for UN No 1745, UN No 1746 and UN No 2495. ## TPED in plain terms The Transportable Pressure Equipment Directive (TPED), formally Directive 2010/35/EU, is the EU law for the receptacles and tanks that carry dangerous goods under pressure. It sets out detailed rules concerning transportable pressure equipment to enhance safety and ensure free movement of such equipment within the Union (Art. 1(1)). What makes it different from the other pressure legislation is that it contains no technical requirements of its own. Everything technical — construction, testing, conformity assessment, technical documentation, periodic inspection, intermediate inspection, exceptional checks and the qualification of inspection bodies — is defined by reference to the Annexes to Directive 2008/68/EC on the inland transport of dangerous goods, which means Section I.1 of Annex I (the ADR for road), Section II.1 of Annex II (the RID for rail) and Section III.1 of Annex III (the ADN for inland waterways) (Art. 2, points (2) and (15) to (22)). Since Commission Delegated Directive (EU) 2025/149, which Member States had to apply by 30 June 2025, those sections refer to the ADR, RID and ADN as applicable with effect from 1 January 2025, so the live technical content changes on the international cycle while the directive number stays the same. The directive replaced Council Directive 1999/36/EC, adopted on 29 April 1999 as a first step towards enhancing transport safety for this equipment, and aligned it both with Directive 2008/68/EC, which had extended the international agreements to national traffic, and with the common marketing framework of Decision No 768/2008/EC (recitals 1 to 6). It was adopted on 16 June 2010, published in OJ L 165 on 30 June 2010 and entered into force on 20 July 2010; Member States had to transpose it by 30 June 2011, and Directives 76/767/EEC, 84/525/EEC, 84/526/EEC, 84/527/EEC and 1999/36/EC — five acts in all — were repealed with effect from 1 July 2011 (Art. 39, Art. 42 and Art. 43). Directive (EU) 2024/2749 added Chapter 5a on emergency procedures, in force since 28 November 2024 and applied by the Member States from 30 May 2026 (Directive (EU) 2024/2749, Art. 3, Art. 11 and Art. 12). > **Official text** > Read the directive on EUR-Lex: [consolidated text of 30 May 2026 (CELEX 02010L0035-20260530)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02010L0035-20260530), which incorporates Directive (EU) 2024/2749 and the 2025 corrigendum; the [original act (CELEX 32010L0035)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010L0035) and the [document information page](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010L0035) list the amendment and the repeal of the five earlier directives. The technical requirements live in the [consolidated text of Directive 2008/68/EC](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0068-20260512). ## Scope Transportable pressure equipment means two families of hardware. The first is all pressure receptacles, their valves and other accessories when appropriate, as covered in Chapter 6.2 of the Annexes to Directive 2008/68/EC — the gas cylinders and similar receptacles the transport rules govern. The second is tanks, battery vehicles and wagons, multiple-element gas containers (MEGCs), their valves and other accessories when appropriate, as covered in Chapter 6.8 of those Annexes. Both count only when the equipment is used in accordance with the Annexes for the transport of Class 2 gases, excluding gases or articles with figures 6 and 7 in the classification code, and for the transport of the dangerous substances of other classes specified in Annex I to the directive (Art. 2, point (1)). Annex I lists six UN numbers outside Class 2: UN 1051 hydrogen cyanide stabilised containing less than 3 % water (class 6.1), UN 1052 anhydrous hydrogen fluoride (class 8), UN 1745 bromine pentafluoride (class 5.1), UN 1746 bromine trifluoride (class 5.1), UN 1790 hydrofluoric acid with more than 85 % hydrogen fluoride (class 8) and UN 2495 iodine pentafluoride (class 5.1); the entries for UN 1745, UN 1746 and UN 2495 exclude carriage in tanks (Annex I). The definition then draws its own lines: gas cartridges of UN No 2037 are included, while aerosols of UN No 1950, open cryogenic receptacles, gas cylinders for breathing apparatus, fire extinguishers of UN No 1044, equipment exempted according to 1.1.3.2 of the Annexes to Directive 2008/68/EC and equipment exempted from the rules for construction and testing of packaging according to special provisions in 3.3 of those Annexes are excluded (Art. 2, point (1)). Article 1(2) then sets out three situations the directive covers, and they matter as much as the hardware. It applies to new equipment that does not bear the conformity markings of Directives 84/525/EEC, 84/526/EEC, 84/527/EEC or 1999/36/EC, for the purpose of making it available on the market; to equipment bearing the markings of this directive or of those four, for the purposes of its periodic inspections, intermediate inspections, exceptional checks and use; and to equipment that does not bear the Directive 1999/36/EC markings, for the purposes of reassessment of conformity. It does not apply to equipment placed on the market before the date of implementation of Directive 1999/36/EC that has not been reassessed, nor to equipment used exclusively for the transport of dangerous goods between Member States and third countries carried out in accordance with Article 4 of Directive 2008/68/EC (Art. 1(3) and (4)). Equipment that is not transportable pressure equipment falls elsewhere: Directive 2014/68/EU on pressure equipment excludes equipment covered by Directives 2008/68/EC and 2010/35/EU from its own scope, so stationary vessels, piping and assemblies follow the Pressure Equipment Directive and simple welded air or nitrogen vessels follow Directive 2014/29/EU (Directive 2014/68/EU, Art. 1(2)(s)). The duties fall on six kinds of actor. Manufacturer, authorised representative, importer and distributor are the familiar chain, but the directive adds the owner, any person established in the Union who owns the equipment, and the operator, any person established in the Union using it, where use means filling, temporary storage linked to carriage, emptying and refilling (Art. 2, points (5) and (8) to (13)). All six are economic operators when they act in the course of a commercial or public service activity, whether in return for payment or free of charge (Art. 2, point (14)), and an importer or distributor that places equipment on the market under its own name or trademark, or modifies equipment already on the market so that compliance may be affected, is considered a manufacturer (Art. 10). Member States may set on-site requirements for mid- or long-term storage or on-site use, but may not add requirements for the equipment itself (Art. 3). ## What you must do ### Conformity assessment against the Annexes to Directive 2008/68/EC Manufacturers must ensure, when placing equipment on the market, that it has been designed, manufactured and documented in accordance with the requirements set out in the Annexes to Directive 2008/68/EC and in the directive (Art. 4(1)), and keep the technical documentation those Annexes specify for the period specified there (Art. 4(3)). New equipment under Article 1(2)(a) must meet the relevant conformity assessment, periodic inspection, intermediate inspection and exceptional checks requirements of those Annexes and of Chapters 3 and 4 of the directive; equipment under Article 1(2)(b), which already carries a conformity marking, must meet the specifications of the documentation according to which it was manufactured and stay within the inspection regime (Art. 12(1) and (2)). Certificates of conformity assessment and of reassessment of conformity and reports of periodic inspections, intermediate inspections and exceptional checks issued by a notified body are valid in all Member States, and a separate conformity assessment may be carried out for demountable parts of refillable equipment (Art. 12(3)). ### The Pi marking Equipment that has passed conformity assessment carries the Pi marking, which indicates conformity with the applicable conformity assessment requirements set out in the Annexes to Directive 2008/68/EC and in the directive (Art. 2, point (16)). It is affixed only by the manufacturer or, in cases of reassessment, as set out in Annex III, and for gas cylinders previously complying with Directives 84/525/EEC, 84/526/EEC or 84/527/EEC by or under the surveillance of the notified body; it may be affixed only to equipment meeting those requirements or the reassessment requirements of Article 13, and to no other equipment (Art. 14(1) and (2)). By affixing it or having it affixed, the manufacturer takes responsibility for the conformity of the equipment with all applicable requirements, and for the purposes of the directive it is the only marking that attests that conformity (Art. 14(3) and (4)). Markings, signs and inscriptions likely to mislead third parties as to the meaning or form of the Pi marking are prohibited, and any other marking must leave its visibility, legibility and meaning intact (Art. 14(5)). Demountable parts of refillable equipment with a direct safety function must themselves be Pi-marked (Art. 14(6)). The mechanics are in Article 15. The marking consists of the symbol in the form given in Article 15(1), with the proportions of the graduated drawing respected and the grid not forming part of the marking; the minimum height is 5 mm, or 2,5 mm for equipment with a diameter of 140 mm or less. It is affixed visibly, legibly and permanently to the equipment or its data plate and to demountable safety parts, before the equipment or those parts are placed on the market, and is followed by the identification number of the notified body involved in the initial inspections and tests, affixed by that body or, on its instructions, by the manufacturer. The date of a periodic or, where appropriate, intermediate inspection is accompanied by the identification number of the notified body responsible for it, and where gas cylinders previously complying with Directives 84/525/EEC, 84/526/EEC or 84/527/EEC do not bear the Pi marking, the first periodic inspection under this directive adds it before that number (Art. 15(2) to (8)). ### Periodic inspection, intermediate inspection and exceptional checks Periodic inspection, intermediate inspection and exceptional check are each defined as the procedure of that name set out in the Annexes to Directive 2008/68/EC (Art. 2, points (18), (19) and (20)), so the intervals and methods are the transport rules' own. Notified bodies carry them out in accordance with the terms of their notification and those procedures (Art. 26(1)). The practical consequence for a business is in Articles 8 and 9: an owner who considers or has reason to believe that equipment does not conform to those Annexes, including the requirements for periodic inspection, must neither make it available nor use it until it has been brought into conformity, and an operator may use only conforming equipment (Art. 8(1) and Art. 9(1)). A receptacle outside a valid inspection interval therefore cannot lawfully be filled or used until it has been re-inspected. ### Reassessment of conformity Reassessment of conformity is the procedure undertaken at the request of the owner or operator for equipment manufactured and placed on the market before the date of implementation of Directive 1999/36/EC (Art. 2, point (17), and Art. 13), and Annex III sets it out step by step. The owner or operator makes available to a type A notified body conforming to EN ISO/IEC 17020:2004 and notified for reassessment the information that enables the body to identify the equipment precisely — origin, design rules and, for acetylene cylinders, details of the porous material — including where appropriate any prescribed restrictions on use and any notes on possible damage or repairs carried out (Annex III, point 2). The body assesses, on that information and where appropriate further inspections, whether the equipment affords at least the same degree of safety as equipment referred to in the Annexes to Directive 2008/68/EC (Annex III, point 3). If the result is satisfactory the equipment undergoes the periodic inspection provided for in those Annexes; if that is met, the Pi marking is applied by or under the surveillance of the notified body responsible for the periodic inspection, followed by its identification number, and that body issues a certificate of reassessment with the identification of the bodies involved, the owner or operator's name and address, the identifying data including serial numbers and the date of issue (Annex III, points 4 and 6). Where pressure receptacles were manufactured in series, Member States may authorise the reassessment of individual receptacles, including their valves and other accessories, by a body notified for periodic inspection, provided the type has been assessed by a type A body responsible for reassessment and a certificate of type reassessment issued; that certificate must carry the words that it does not authorise the manufacture of transportable pressure equipment or parts thereof (Annex III, points 5 and 7). By affixing or having affixed the Pi marking, the owner or operator indicates that it takes responsibility for the conformity of the equipment with all applicable requirements as they stand at the time of reassessment (Annex III, point 8). In Denmark it is Erhvervsstyrelsen that may allow the simplified route for series-produced receptacles (executive order nr. 483/2026, § 5). ### Notified bodies A notified body is an inspection body meeting the requirements set out in the Annexes to Directive 2008/68/EC and the conditions of Articles 20 and 26, notified in accordance with Article 22 (Art. 2, point (24)). It must be established under national law and have legal personality, and it must take part in, or keep its assessment personnel informed of, the relevant standardisation work and the work of the sectoral coordination group and apply that group's administrative decisions and documents as general guidance (Art. 20(3) and (4)). A competent authority within the meaning of those Annexes may itself be a notified body, provided it meets the requirements and does not also act as the notifying authority (Art. 20(2)). The application for notification goes to the notifying authority of the Member State of establishment and must describe the conformity assessment, periodic inspection, intermediate inspection, exceptional check and reassessment activities, the procedures, the equipment claimed and an accreditation certificate from a national accreditation body attesting that the body fulfils Article 20 (Art. 21). The Commission and the other Member States are notified through the Commission's electronic tool, the body may act only if no objections are raised within two weeks, and in-house inspection services of the applicant cannot be notified (Art. 22). The Commission assigns a single identification number, even where the body is notified under several Union acts, and publishes and keeps up to date the list of bodies notified under the directive (Art. 23). A body notified by one Member State may work in all of them, with the notifying authority retaining responsibility for monitoring (Art. 26(3)). In Denmark, notified bodies must be legal persons established in Denmark, accredited by DANAK for the task in question and meeting Articles 20, 21, 26, 27 and 29; Erhvervsstyrelsen designates them, DANAK assesses and monitors them, and complaints against their decisions go to Erhvervsstyrelsen within 4 weeks (executive order nr. 483/2026, § 6 and § 10). ### Obligations by role Manufacturers design, manufacture and document to the Annexes, have the conformity assessment carried out, affix the Pi marking, keep the technical documentation, take corrective action and inform the authorities where equipment presents a risk, document every such case, answer reasoned requests in a language the authority understands and give operators only compliant information (Art. 4). Authorised representatives act under a mandate that cannot include the design, manufacture, documentation or marking duties and must at least cover keeping the technical documentation, answering reasoned requests and cooperating with the authorities; their identity and address appear on the certificate of conformity (Art. 5). Importers verify the manufacturer's conformity assessment, technical documentation, Pi marking and certificate of conformity before placing equipment on the market, add their contact details in or with that certificate, protect compliance during storage and transport, keep a copy of the technical documentation and take corrective action (Art. 6). Distributors verify the Pi marking, the certificate of conformity and the importer's contact address before making equipment available, protect it in storage and transport and see that corrective action is taken (Art. 7). Owners must not make available or use equipment they believe does not conform, including on periodic inspection, and protect compliance during storage and transport (Art. 8); operators may use only conforming equipment and must inform the owner and the authorities of a risk (Art. 9). Article 8 does not apply to private individuals using equipment for personal or domestic use or for leisure or sporting activities (Art. 8(4)). Every economic operator must, on request from the market surveillance authority, identify its suppliers and its customers for at least 10 years (Art. 11). ### Emergency procedures since 2026 Directive (EU) 2024/2749 inserted Chapter 5a. Its measures apply only if the Commission has adopted an implementing act under Article 28 of Regulation (EU) 2024/2747 for transportable pressure equipment, only to equipment designated as crisis-relevant goods under Article 18(4) of that regulation and only during an activated internal market emergency mode, with Article 33c(7) continuing to apply after the mode expires or is deactivated (Art. 33a). Notified bodies then process applications for that equipment as a matter of priority, irrespective of whether they were lodged before or after activation, without additional disproportionate costs for the manufacturers, and make reasonable efforts to increase their testing capacity (Art. 33b). A Member State may, on a duly justified request from an economic operator, authorise the placing on the market on its territory of specific listed equipment for which the notified-body procedures have not been carried out but compliance with the Annexes to Directive 2008/68/EC and the directive has been demonstrated in accordance with the procedures in the authorisation; the Commission is informed immediately and adopts an implementing act extending the authorisation Union-wide, after which the equipment must carry the information that it is placed on the market as a crisis-relevant good, clear and in a language easily understood by consumers and other end-users as the Member State determines (Art. 33c(1) to (4)). Manufacturers and importers declare compliance on their sole responsibility, the authorisation sets out the demonstration procedures, traceability requirements, an end date that cannot go beyond the emergency mode, continuous conformity assessment requirements and the measures to take when the mode ends, such equipment does not bear the Pi marking and Article 16 does not apply to it, and market surveillance authorities keep their full corrective and restrictive powers under Regulation (EU) 2019/1020 (Art. 33c(5) to (8)). Market surveillance for the listed equipment is prioritised, coordinated through the Union Product Compliance Network, with best efforts at mutual assistance including expert teams and testing capacity (Art. 33d). In Denmark Erhvervsstyrelsen issues the authorisations, informs the Commission and the other Member States and prioritises surveillance, and the information and labelling must be in Danish or English (executive order nr. 483/2026, § 7 and § 8). ## Enforcement and penalties Articles 16 and 30 still refer to Regulation (EC) No 765/2008, whose Chapter III, Articles 15 to 29, was deleted by Regulation (EU) 2019/1020 from 16 July 2021, and Article 39(2) of Regulation (EU) 2019/1020 provides that references to the deleted provisions of Regulation (EC) No 765/2008 are construed as references to the regulation and read in accordance with the correlation table in its Annex III: the Article 20 of Regulation (EC) No 765/2008 that Article 30(1) of the directive cites is now Article 19 of the regulation, and the Article 21 it cites for corrective action is now Article 18. Listing the directive as point 37 of Annex I is what brings it inside the regulation's market surveillance chapter in the first place (Regulation (EU) 2019/1020, Art. 39(1) and (2), Annex I point 37 and Annex III). Where the authorities of a Member State have acted under the market surveillance rules or have sufficient reason to believe that equipment presents a risk to the health or safety of persons or to other aspects of public interest protection, they evaluate it against all the requirements of the directive, with the economic operators cooperating as necessary including access to premises and samples; if it does not comply they require corrective action, withdrawal or recall within a reasonable period commensurate with the risk and inform the relevant notified body (Art. 30(1)). Where non-compliance is not restricted to their territory they inform the Commission and the other Member States; where the operator does not act they take provisional measures prohibiting or restricting the making available, withdrawing or recalling the equipment and notify them, stating whether the non-compliance is due to a failure of the equipment or to shortcomings in the standards or technical codes referred to in the Annexes to Directive 2008/68/EC (Art. 30(2) to (6)). A measure against which no Member State or the Commission objects within two months is deemed justified (Art. 30(7)). Objections trigger the Union safeguard procedure, in which the Commission decides whether the national measure is justified, in which case all Member States withdraw the equipment, and otherwise the Member State withdraws its measure (Art. 31). Compliant equipment that nonetheless presents a risk can be dealt with the same way (Art. 32), and formal non-compliance — a Pi marking affixed in violation of Articles 12, 13, 14 or 15, a missing Pi marking, technical documentation that is not available or not complete, or any failure to comply with the Annexes to Directive 2008/68/EC and the directive — must be ended, failing which the equipment is restricted, prohibited, recalled or withdrawn (Art. 33). Penalties are national. Article 14(7) requires Member States to ensure the correct implementation of the Pi marking rules, to act against improper use and to provide for penalties for infringements, which may include criminal sanctions for serious infringements and must be proportionate to the seriousness of the offence and an effective deterrent against improper use. The directive is also point 15 of Annex II to Regulation (EU) 2019/1020, the legislation without provisions on penalties, so Article 41 of that regulation adds the general duty to lay down effective, proportionate and dissuasive penalties for infringements that impose obligations on economic operators. In Denmark, executive order nr. 483 of 28 May 2026 implements the directive by reproducing it as annex 1 and punishes with a fine, unless a higher penalty is due under other law, breaches of its § 4, of § 7, stk. 3, on the Danish or English information and labelling of crisis-relevant goods and of the provisions of annex 1, and failure to comply with decisions, orders and prohibitions, with corporate liability under chapter 5 of the criminal code (executive order nr. 483/2026, § 11). The product act lists the directive in section 2 as product area nr. 6, names Erhvervsstyrelsen as the control authority and provides orders to warn users and to stop misleading marketing, prohibitions, and orders to remedy, to stop sales, to withdraw, recall or destroy, and fines. The product act's marking provision (section 15) reaches only the CE marking, which transportable pressure equipment does not bear; a Pi marking affixed in violation of Articles 12 to 15 is instead a breach of annex 1 to the executive order, punishable by a fine under its section 11(1)(1), and the control authority acts through the general orders and prohibitions in sections 14 and 16 of the product act. The executive order itself provides only for fines (section 11). The product act's own penalty provision can rise to imprisonment of up to 2 years in aggravating circumstances — danger to safety or health, an accident causing serious injury or death, repetition or systematic breaches for gain — but only for the offences listed in section 37(1)(1) and (3) to (10), that is breaches of the act's own product requirements, of the duty to give the control authority information and access and of its decisions, on product areas covered by section 2(1)(1) to (11) or (13) to (43); transportable pressure equipment is product area nr. 6 and therefore inside that band. It does not extend to breaches of the executive order's own rules, and the points that rest on Article 4 and Article 5 of Regulation (EU) 2019/1020 cannot apply here, because the directive is not in the Article 4(5) list (LBK nr. 22/2026, § 2, stk. 1, nr. 6, § 9, § 14, § 15, § 16 and § 37; executive order nr. 483/2026, § 11; Regulation (EU) 2019/1020, Art. 4(5)). Sikkerhedsstyrelsen has carried out the control of transportable pressure equipment since 1 December 2018 and is since January 2026 the department Markedsovervågning of Erhvervsstyrelsen, while the control authority's own guidance on pressure equipment states that Arbejdstilsynet remains the market surveillance authority for pressure equipment and pressure vessels made to order and for equipment imported from third countries for offshore oil and gas activities under the offshore safety act. That guidance is written for pressure equipment and pressure vessels, not for transportable pressure equipment, whose scope is set by the ADR and RID annexes to Directive 2008/68/EC and knows no 'made to order' category; for transportable pressure equipment only the offshore leg is capable of applying. That split works through section 9(2) of the product act, under which the authority that supervises other legislation on specific risks for particular products is the relevant control authority; executive order nr. 483 of 28 May 2026 does not mention Arbejdstilsynet at all, and the product act does not name it for this product area (LBK nr. 22/2026, § 9, stk. 1 and 2; executive order nr. 483/2026; Sikkerhedsstyrelsen, rules and control pages; Erhvervsstyrelsen, Sikkerhedsstyrelsen page). The carriage rules themselves — the ADR on the road, the RID on the railway and the ADN on inland waterways — are enforced by the transport and emergency-management authorities rather than by the product authority. ## Related guides - [Pressure Equipment Directive (PED)](/regulations/ped) - [Simple Pressure Vessels Directive (SPVD)](/regulations/spvd) - [ATEX equipment directive](/regulations/atex) ## How Conphora helps Conphora monitors Directive 2010/35/EU, the Annexes to Directive 2008/68/EC that carry the ADR, RID and ADN and the delegated directives that update them, and the Danish executive orders, and maps your transportable pressure equipment against the Article 2 definition, the Annex I substances, the carve-outs and the three Article 1(2) situations, flagging gaps in the conformity assessment, the certificate of conformity, the technical documentation, the Pi marking and notified body number and the inspection intervals before they become enforcement problems. The platform helps you keep the documentation and the 10-year supplier and customer records, combines the TPED file with the other declarations the same equipment may need, and alerts you when the ADR, RID and ADN editions referenced by Directive 2008/68/EC change, when a Danish executive order moves or when an emergency-mode activation reaches your equipment. [See how Conphora works](/how-it-works) · [See plans and pricing](/pricing) ## Sources - [Directive 2010/35/EU on transportable pressure equipment, consolidated text of 30 May 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02010L0035-20260530) - [Directive 2010/35/EU as published in OJ L 165, 30 June 2010 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010L0035) - [Document information, dates, corrigenda and relationships for CELEX 32010L0035 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010L0035) - [Directive 2008/68/EC on the inland transport of dangerous goods, consolidated text of 12 May 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0068-20260512) - [Inland transport of dangerous goods, summary of Directive 2008/68/EC (EUR-Lex)](https://eur-lex.europa.eu/EN/legal-content/summary/inland-transport-of-dangerous-goods.html) - [Commission Delegated Directive (EU) 2025/149 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025L0149) - [Directive (EU) 2024/2749 on emergency procedures for conformity assessment, presumption of conformity, common specifications and market surveillance during an internal market emergency (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L2749) - [Council Directive 1999/36/EC on transportable pressure equipment, repealed from 1 July 2011 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31999L0036) - [Commission Decision 2001/107/EC deferring the date of implementation of Directive 1999/36/EC for pressure drums, bundles of cylinders and tanks to 1 July 2003 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001D0107) - [Commission Decision 2003/525/EC deferring the date of implementation of Directive 1999/36/EC for pressure drums, bundles of cylinders and tanks to 1 July 2005 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32003D0525) - [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020) - [Notified bodies database, Single Market Compliance Space (European Commission)](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/notified-body-list) - [Bekendtgørelse nr. 483 af 28. maj 2026 om indretning m.v. af transportabelt trykbærende udstyr (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/483) - [Bekendtgørelse nr. 685 af 10. juni 2013 om indretning m.v. af transportabelt trykbærende udstyr (Retsinformation)](https://www.retsinformation.dk/eli/lta/2013/685) - [Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/22) - [Regler for transportabelt trykbærende udstyr (Sikkerhedsstyrelsen, Erhvervsstyrelsen Markedsovervågning)](https://www.sik.dk/erhverv/produkter/trykudstyr/love-og-regler/regler-transportabelt-trykbaerende-udstyr) - [Kontrol med transportabelt trykbærende udstyr (Sikkerhedsstyrelsen, Erhvervsstyrelsen Markedsovervågning)](https://www.sik.dk/erhverv/produkter/trykudstyr/vejledninger/kontrol-transportabelt-trykbaerende-udstyr) - [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Erhvervsstyrelsen)](https://erhvervsstyrelsen.dk/sikkerhedsstyrelsen-en-del-af-erhvervsstyrelsen) *This guide is for general information and is not legal advice.* ## Sources - [Directive 2010/35/EU on transportable pressure equipment, consolidated text of 30 May 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02010L0035-20260530) - [Directive 2010/35/EU on transportable pressure equipment as published in OJ L 165, 30 June 2010 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010L0035) - [Document information, dates, corrigenda and relationships for CELEX 32010L0035 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010L0035) - [Directive 2008/68/EC on the inland transport of dangerous goods, consolidated text of 12 May 2026, whose Annexes carry the ADR, RID and ADN (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0068-20260512) - [Inland transport of dangerous goods, summary of Directive 2008/68/EC (EUR-Lex)](https://eur-lex.europa.eu/EN/legal-content/summary/inland-transport-of-dangerous-goods.html) - [Commission Delegated Directive (EU) 2025/149 bringing the 1 January 2025 editions of the ADR, RID and ADN into the Annexes to Directive 2008/68/EC (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025L0149) - [Directive (EU) 2024/2749 on emergency procedures for the conformity assessment, presumption of conformity, common specifications and market surveillance during an internal market emergency (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L2749) - [Council Directive 1999/36/EC on transportable pressure equipment, repealed from 1 July 2011 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31999L0036) - [Commission Decision 2001/107/EC deferring the date of implementation of Directive 1999/36/EC for pressure drums, bundles of cylinders and tanks to 1 July 2003 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001D0107) - [Commission Decision 2003/525/EC deferring the date of implementation of Directive 1999/36/EC for pressure drums, bundles of cylinders and tanks to 1 July 2005 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32003D0525) - [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020) - [Notified bodies database, Single Market Compliance Space (European Commission)](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/notified-body-list) - [Bekendtgørelse nr. 483 af 28. maj 2026 om indretning m.v. af transportabelt trykbærende udstyr (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/483) - [Bekendtgørelse nr. 685 af 10. juni 2013 om indretning m.v. af transportabelt trykbærende udstyr, repealed from 30 May 2026 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2013/685) - [Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/22) - [Regler for transportabelt trykbærende udstyr (Sikkerhedsstyrelsen, Erhvervsstyrelsen Markedsovervågning)](https://www.sik.dk/erhverv/produkter/trykudstyr/love-og-regler/regler-transportabelt-trykbaerende-udstyr) - [Kontrol med transportabelt trykbærende udstyr (Sikkerhedsstyrelsen, Erhvervsstyrelsen Markedsovervågning)](https://www.sik.dk/erhverv/produkter/trykudstyr/vejledninger/kontrol-transportabelt-trykbaerende-udstyr) - [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Erhvervsstyrelsen)](https://erhvervsstyrelsen.dk/sikkerhedsstyrelsen-en-del-af-erhvervsstyrelsen) _Reviewed 2026-09-24 by Conphora compliance team_