CE Marking – EN 1090-1

In 2012 The Construction Products Regulations (CPR) was introduced, this places a requirement on construction products that have a harmonised standard to be CE Marked. 

BS EN 1090-1 is the harmonised standard for structural steel, as of 1st July 2014 it became illegal to supply structural steelworks without conformity to the standard and carrying the CE mark. 

BS EN 1090 consists of 3 parts: 

 1. EN 1090-1:2009+A1:2011  Requirements for conformity  assessment providing an outline of  a manufacturer’s FPC requirements  and provides guidance on how  products should be CE marked.

 2. EN 1090-2:2008+A1:2011  Steel technical requirements 

 3. EN 1090-3:2008  Aluminium technical  requirements  

 The regulations apply to a wide range of activities involving “series” manufactured items:-

• Importers of structural metalwork kits or components
• Stockholders and metal processors that modify stock – for example by drilling, painting, bending etc.
• Manufacturers of metal components or kits that have a structural use in civil engineering

 By “series”, the regulations mean an activity that an organisation carries out more than once, i.e. mass produced. 

Please click below to find a list of products identified within the scope of EN 1090-1

Step 1 - Determine if your products falls within the scope.

The Manufacturers responsibility to determine if the product falls within the scope of EN 1090. This can be a confusing situation as there can be items with multiple uses. It may help to use the above product identifier and consider the following:

• Is the construction product, as defined by the CPR, made from steel or aluminium?
• Is the product load-bearing?
• Has the product been installed in a permanent manner?
• Is the product within the scope of EN 1090-1?
• Does the product fall into the scope of another harmonized standard?

Step 2 - Determine the Execution Class 

BS EN 1090 sets out four Execution Classes (EXC’s), These classes are based on:   

1. Consequence Class (risk / impact assessment)

2. Service Category (what is the product used for)

3. Production Category (with reference to 1 and 2 above)

• EXC1 – e.g. Agricultural buildings (Welded construction up to and including Grade S275 material)
• EXC2 – e.g. Residential or Commercial structures
• EXC3 – e.g. Bridges or Stadia type buildings
• EXC4 – e.g. Special structures (long-span bridges, frames for structures within the nuclear sector and structures within high seismic active areas) etc.

Step 3 - Factory Production Control (FPC)

Factory Production Control (FPC) System BS EN 1090-1 defines the manufacturing controls required to ensure that structural steel components meet a range of clearly defined technical requirements relevant to their manufacture.

If you already have ISO 9001 in place, this is a great start, but there are a few more requirements of a FPC system, including clause 6.3 of EN 1090.

Where welding is part of the process, a Welding Quality Management system is needed and this must conform to BS EN ISO 3834.  Your company should either employ, or have access to, a Responsible Welding Coordinator (RWC) to control your welding quality management system. AJF Consultancy can install a WQM and assist in training programmes for your own staff. The RWC must be trained to the requirements of the EXC's of the product manufactured. the higher the EXC, the more stringent training requirements are for the RWC.

Step 4 - Assessment

A notified body, appointed by you will carry out:

• Initial inspection of your manufacturing plant
• Initial inspection of your FPC
• Continuous surveillance, assessment and approval of your FPC, which will typically include an annual audit to ensure continued competence to the declared Execution Class

The notified body will then issue an FPC certificate and Welding Certificate identifying the Execution Class that you have achieved.

Step 5 - Certification

To gain certification and be awarded a CE Mark, you are required to undertake the following:

• Initial type-testing of your products
• Factory Production Control which includes:
• Implementation of FPC system procedures
• Appointment of a responsible welding coordinator (RWC)
• Implementation of welding quality management system (WQMS) procedures
• Further testing of samples taken at the factory in accordance with the prescribed test plan

You can now start CE Marking and producing your declaration of performance for each product

For GB organisations placing products into the UK market, after the 1st January 2022, Businesses must use the UKCA marking. 

EU Regulations will still apply to organisations placing GB products onto the EU market after this date.

Products that meet UK requirements and bear the UK mark can only be placed on the GB market if third-party assessments have been carried out by a UK approved body.

Your Business must prepare for this transition date. 

AJF Consultancy Services can guide you through the process, assisting your team to identify the requirements that are appropriate to your business and develop a system with your team producing all procedures, manuals and documentation and implement training as required. 

Our services include, but not limited to:

• Gap analysis to identify and plan your required support.
• Set out the plans for all stakeholders to work to, including dates for milestones.
• Modify or produce new FPC and WQMS manuals, procedures and documentation
• Train Stakeholders in new procedures etc.
• Support with certification of welding procedures (WPQR) and welders (EN ISO 15614 series and EN ISO 9606 series)
• Support with RWC appointment or RWC training
• Carry out internal audits and pre-certification audit reviews