CE marking of steel structures under EN 1090-1

Anyone placing structural steel or aluminium components on the European market must CE mark them in accordance with EN 1090-1, based on the Construction Products Regulation (CPR). CE marking is not a quality label but a declaration: the manufacturer declares that the product delivers the performance stated in the accompanying Declaration of Performance and that production is controlled accordingly.

In practice much goes wrong around CE marking: an incorrect scope, a declaration that does not match what is delivered, or production control that exists only on paper. This article explains how the system works, what the notified body actually does and where fabricators and buyers most often go wrong.

Who the CE obligation applies to

The obligation applies to manufacturers placing structural steel or aluminium components on the market as construction products: beams, columns, trusses, fabricated assemblies, platforms and similar products with a load-bearing function in construction works. A workshop producing exclusively for contractors is also covered as soon as the product leaves the factory as a structural component. Not covered: erection work on site itself and products falling under another harmonised standard. Borderline cases, such as repair or modification of existing structures, deserve an explicit assessment beforehand.

The Declaration of Performance (DoP)

The Declaration of Performance is the legal heart of CE marking. In it the manufacturer declares the performance of the product, for example on the basis of the client's structural specification (method 3a or 3b) or its own design (method 1 or 2). The DoP states the product type, intended use, execution class and essential characteristics such as load-bearing capacity, reaction to fire and weldability, or refers to the accompanying documentation. The CE marking on the product or its documents must match the DoP exactly. A DoP copied as a template without project-specific data is one of the most common shortcomings.

Factory Production Control (FPC)

The declaration rests on factory production control: a documented system ensuring that every delivered product achieves the declared performance. The FPC system covers personnel and qualifications, equipment, incoming material inspection, the welding process to the appropriate part of ISO 3834, dimensional checks, non-destructive testing and the handling of non-conformities. For everything welding-related, EN 1090-1 leans entirely on EN 1090-2 and ISO 3834. Our article on Factory Production Control explains how to set up such a system in practice.

The role of the notified body

For structural steel and aluminium components, system 2+ applies for the assessment and verification of constancy of performance. That means:

• The manufacturer carries out the determination of product type and the production control itself.
• A notified body performs an initial inspection of the factory and the FPC system and, if satisfactory, issues the FPC certificate.
• The notified body then carries out periodic surveillance, usually annually, and can suspend or withdraw the certificate.

The certificate states the scope: the maximum execution class and the declaration method. The notified body certifies the production system, not individual products: responsibility for every delivered component remains with the manufacturer.

Link with execution classes and welding coordination

The FPC certificate is limited to a maximum execution class. A company certified up to EXC2 may not CE mark EXC3 components. Through EN 1090-2 the class also drives the requirements for welding procedure qualification to EN ISO 15614-1, welder qualification to ISO 9606-1, the quality level to ISO 5817 and the required level of the welding coordinator. That coordinator is a key figure within the FPC system: during the initial inspection and surveillance the notified body explicitly checks whether the coordination matches the scope. See our article on the execution classes.

Common mistakes

The shortcomings we encounter most often in practice:

• Supplying outside the scope of the FPC certificate, for example a higher execution class or a different declaration method.
• No DoP, or an incomplete one, with the delivery, or a DoP that does not match the structural specification.
• Welder qualifications that have expired or do not cover what is actually welded.
• Material certificates that are missing or cannot be traced to the delivered components.
• An FPC manual that disappears into a drawer after certification and no longer reflects actual practice.
• Buyers failing to check whether their supplier is certified for the required class.

Structural EN 1090 support prevents these issues surfacing only during an audit or after damage has occurred.