The Pressure Equipment Directive imposes specific NDT and personnel qualification requirements. This guide explains what the directive requires, what an RTPO is, and how it affects manufacturers exporting to Europe.
BY DAN YAMASHITA · ASNT/PCN LEVEL 3 · SIMPLE NDT · · 12 MIN READ
The Pressure Equipment Directive 2014/68/EU — known by the acronym PED — is the European directive regulating the design, manufacture, and conformity assessment of pressure equipment and assemblies placed on the market of the European Economic Area (EEA). It entered into force on 19 July 2016, replacing the previous directive 97/23/EC.
In practical terms: any manufacturer — European or foreign — wishing to sell pressure vessels, boilers, industrial piping, pressure accessories, or safety accessories to the European market must comply with the PED. For non-EEA manufacturers exporting equipment to Europe, PED compliance is not optional.
The directive applies to equipment with a maximum allowable pressure (PS) greater than 0.5 bar. Below that threshold, the PED does not apply — the manufacturer may follow sound engineering practice recognised by the Member State, with no obligation to CE mark the product.
The PED classifies equipment into four categories (I to IV) based on risk — the higher the category, the more stringent the conformity requirements. Classification is determined by the combination of: equipment type (vessel, piping, boiler), fluid group (Group 1 = hazardous fluids; Group 2 = other fluids), maximum allowable pressure (PS), and volume or nominal diameter.
Equipment falling below the limits set in Article 4.1 is covered by Sound Engineering Practice (SEP) under Article 4.3 — no formal conformity assessment is required, no CE marking is applied, but basic safety requirements must still be met.
The category matters because it determines which conformity assessment module must be applied and, directly, what role Nondestructive Testing plays in the manufacturing process.
The CE marking is not simply a logo. It is the manufacturer's legal declaration that the equipment meets all essential safety requirements (ESR) of the applicable directive. For the PED, this means the manufacturer has completed the conformity assessment process prescribed by the selected module, compiled the technical file, drafted and signed the EU Declaration of Conformity, and is authorised to affix the CE marking — followed by the Notified Body's identification number where applicable.
By using harmonised standards (such as EN 13445 for unfired pressure vessels, EN 13480 for industrial piping, or EN 12952/12953 for boilers), the manufacturer gains a presumption of conformity with the ESRs covered by those standards. Using harmonised standards is not mandatory, but it is the most practical and market-accepted path.
NDT requirements are concentrated in Annex I of the PED, which defines the Essential Safety Requirements (ESR) for manufacture. Two points are directly relevant to inspection:
Permanent joints — primarily welds — and the personnel executing them must be qualified before manufacturing begins. The requirement varies by category: for Category II, welding procedures and welder qualifications must be approved by a Notified Body (NB) or by an RTPO. For Categories III and IV, the requirement is more restrictive — both welding procedures and welder qualifications must be approved exclusively by an RTPO, the third-party organisation recognised by the Member State under Article 20 of the PED.
This directly affects manufacturers producing Category III and IV equipment: before production begins, welding procedures and welders must have specific RTPO approval — involvement of the Notified Body responsible for the conformity module is not sufficient for this purpose.
This is the most directly relevant point for NDT. Section 3.1.3 requires that nondestructive testing of permanent joints be performed by qualified personnel. For Category III and IV equipment, that qualification must be approved by a recognised third-party organisation under Article 20 of the PED — in other words, an RTPO.
Two important clarifications, based on official European Commission guidelines:
Guideline F-07: The requirement in Section 3.1.3 does not cover visual examination (VT) as classified by EN ISO 9712. Therefore, VT personnel are not subject to the RTPO approval requirement in Section 3.1.3 — although additional VT requirements may arise from other parts of the conformity assessment process.
Guideline F-09: The PED requires qualification of NDT personnel for permanent joints, but does not require accreditation of the NDT laboratory or company as an organisation. The focus is on the individual inspector's competence, not on corporate certification of the company.
The term RTPO — Recognised Third Party Organisation is defined in Article 20 of PED 2014/68/EU. It is a body appointed by the national authority of an EEA Member State specifically for the approval of permanent joining procedures, welding personnel qualification, and NDT personnel qualification approval.
Many confuse RTPO with Notified Body. The differences are clear:
The same organisation can act simultaneously as NB and RTPO — for example, TÜV, Bureau Veritas, DNV, and Lloyd's Register operate in both capacities. However, the functions are distinct and the appointments are separate. For the manufacturer, the key is to verify that the organisation holds an RTPO appointment for the specific scope required — NDT personnel approval, welding procedure approval, or both.
The PED does not directly prescribe which qualification standard must be used for NDT personnel — it states that the qualification must be approved by an RTPO (for Categories III and IV). In practice, ISO 9712 is the harmonised supporting standard for NDT personnel qualification in the European context, and is what RTPO bodies verify and approve.
ISO 9712 defines three qualification levels (Level 1, 2 and 3) by method and industrial sector. Each certification body defines the specific sectors it covers, but the sectors relevant to the PED are pressure vessels, piping, and welded products. An inspector certified in UT under ISO 9712 for the pressure vessel sector holds the specific qualification to inspect joints in those types of equipment — which is exactly what the PED requires for Categories III and IV.
In Brazil, ISO 9712 certification is issued by bodies such as ABENDI, SNQC, and CEBRACI — all accredited by INMETRO. In Europe, the main issuers are COFREND (France) and DGZfP (Germany). PCN (UK) deserves particular attention: following Brexit, the UK is no longer an EEA Member State, and PCN certificates are now recognised in the European market through LRQA Ireland, which validates those certificates for PED conformity purposes.
Critical point for non-EEA manufacturers: the fact that an inspector holds an ISO 9712 certificate issued by ABENDI, SNQC, or CEBRACI does not automatically satisfy PED requirements. None of those bodies is recognised as an RTPO or Notified Body by any EEA Member State. For an ISO 9712 qualification to be accepted in the PED context, it must be validated or recognised by an RTPO appointed within the EEA — such as LRQA Ireland, which validates PCN certificates for this purpose.
One practically relevant point: ISO 9712 defines that an inspector's certificate is issued by a third-party certification body independent from the employer — unlike the SNT-TC-1A framework, where certification is the employer's responsibility. This characteristic makes ISO 9712 more suitable and directly accepted in the PED context, where a third party (the RTPO) must approve the qualification.
For a manufacturer based outside the EEA wishing to access the European market with equipment subject to the PED, the path follows well-defined steps. The starting point is determining the equipment category — this drives everything that follows.
With the category established, select the appropriate conformity assessment module and engage a Notified Body qualified for that module. The NB will work with you throughout the manufacturing process, reviewing design, fabrication procedures, and documentation.
From an NDT perspective specifically, the critical points are: verify that your NDT inspectors hold valid ISO 9712 certification in the methods and industrial sectors applicable to the equipment being manufactured; for Categories III and IV, confirm with your NB or RTPO whether inspector qualifications satisfy the approval requirement in Section 3.1.3; and ensure that inspector qualification records form part of the technical file — PED Guideline F-02 clarifies that the final assessment documentation must include evidence of NDT personnel qualification and reports of the tests performed.
Manufacturers outside the EEA must also appoint an authorised representative established within the EEA. This representative is responsible for keeping the technical file available to authorities and may sign the EU Declaration of Conformity on behalf of the manufacturer.
Dan Yamashita holds ISO 9712 certification with PCN recognition in the European market via LRQA Ireland, allowing him to act as an approved inspector for PED purposes. SimpleNDT provides full technical consulting for manufacturers needing to comply with the directive: NDT personnel qualification review and verification, NDT procedure development, guidance through the conformity assessment process, and support in structuring the technical file. See the available PED compliance services.
NDT personnel qualification, procedure development, conformity assessment consulting. ISO 9712 certification with European recognition via LRQA Ireland.