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by 30 June 2011, and Directives 76/767/EEC, 84/525/EEC, 84/526/EEC, 84/527/EEC and 1999/36/EC — five acts in all — were repealed with effect from 1 July 2011 (Art. 39, Art. 42 and Art. 43).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), which incorporates Directive (EU) 2024/2749 and the 2025 corrigendum; the original act (CELEX 32010L0035) and the document information page list the amendment and the repeal of the five earlier directives. The technical requirements live in the consolidated text of Directive 2008/68/EC.
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)
- Simple Pressure Vessels Directive (SPVD)
- ATEX equipment directive
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.
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Sources
- Directive 2010/35/EU on transportable pressure equipment, consolidated text of 30 May 2026 (EUR-Lex)
- Directive 2010/35/EU as published in OJ L 165, 30 June 2010 (EUR-Lex)
- Document information, dates, corrigenda and relationships for CELEX 32010L0035 (EUR-Lex)
- Directive 2008/68/EC on the inland transport of dangerous goods, consolidated text of 12 May 2026 (EUR-Lex)
- Inland transport of dangerous goods, summary of Directive 2008/68/EC (EUR-Lex)
- Commission Delegated Directive (EU) 2025/149 (EUR-Lex)
- 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)
- Council Directive 1999/36/EC on transportable pressure equipment, repealed from 1 July 2011 (EUR-Lex)
- 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)
- 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)
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)
- Notified bodies database, Single Market Compliance Space (European Commission)
- Bekendtgørelse nr. 483 af 28. maj 2026 om indretning m.v. af transportabelt trykbærende udstyr (Retsinformation)
- Bekendtgørelse nr. 685 af 10. juni 2013 om indretning m.v. af transportabelt trykbærende udstyr (Retsinformation)
- Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)
- Regler for transportabelt trykbærende udstyr (Sikkerhedsstyrelsen, Erhvervsstyrelsen Markedsovervågning)
- Kontrol med transportabelt trykbærende udstyr (Sikkerhedsstyrelsen, Erhvervsstyrelsen Markedsovervågning)
- Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Erhvervsstyrelsen)
This guide is for general information and is not legal advice.