CE Marking For Structural Steel In The Eu
Does this steel product require EN 1090-1 CE marking?
CE marking of fabricated structural steel in the EU is a product-and-intended-use decision, not a licence for every welding workshop. First establish whether the supplied component or kit is load-bearing in permanent construction works, whether EN 1090-1 covers it, and whether a more specific harmonised product specification applies. Only then select the assessment route.
Regulation (EU) 2024/3110 has applied in large part since 8 January 2026, but its transitional rules preserve relevant CPR-2011 provisions and harmonised standards for product families that have not migrated. Do not assume that every steel product already requires a CPR-2024 declaration of performance and conformity (DoPC): verify the product-family citation and applicable regime on the date of placing on the market.
Route decision: product and intended use
Use the four cases below as a screening tool, not as a substitute for reviewing the product's declared intended use and the current Official Journal citation.
| Supply case | Likely route or risk | Next verification |
|---|---|---|
| Fabricated beam or column carrying building loads | Potential EN 1090-1 structural component under the retained CPR-2011 route. | Confirm permanent incorporation, structural function, EN 1090-1 scope and any more specific standard. |
| Ordinary barrier or balustrade only preventing falls | Not automatically an EN 1090-1 structural product; safety in use differs from resistance and stability. | Review whether it actually supports the structure and whether another specification applies. |
| Bolts, structural sections or other products with dedicated standards | An applicable product-specific harmonised standard may take priority over EN 1090-1. | Identify the precise product and search the currently cited harmonised standards. |
| Unique part fabricated or assembled on the building site | No automatic exemption simply because it is bespoke or site-made. | Analyse placing on the market, manufacturer identity, and narrowly defined CPR-2011 exceptions where relevant. |
A weld, a steel grade or the presence of a construction drawing does not itself prove EN 1090-1 applicability. The decisive facts are function, market supply and the applicable technical specification.
Who prepares which technical evidence?
For a product within EN 1090-1, System 2+ generally involves manufacturer performance assessment and factory production control (FPC), with certification of FPC by a notified body. It is not a notified body's individual CE approval for each beam. EN 1090-2 addresses technical execution of steel structures; the execution class (EXC) is a project specification, not a universal class chosen by the factory.
| Actor | Input or responsibility | Evidence to retain or check |
|---|---|---|
| Structural designer / specifier | State intended use, design responsibilities, execution class and relevant structural requirements. | Approved drawings, execution specification, load/design basis and interfaces. |
| Fabricator acting as manufacturer | Assess product type; operate FPC, purchasing controls, welding qualifications, inspection and traceability. | FPC records, material certificates, welding and inspection records, declared performance and CE information. |
| Notified FPC certification body | Where System 2+ applies, inspect and certify FPC and conduct continuing surveillance within its notified scope. | Valid FPC certificate, notified-body number and scope/EXC appropriate to the production. |
| Purchaser / importer / distributor | Match delivered item, declared performance, installation requirements and operator role; check relevant obligations. | DoP (or DoPC if migrated), CE details, identification, instructions and supply-chain records. |
Five-stage compliance route
Ask for a product-specific evidence pack before releasing the component for sale or installation:
- Product identity, intended structural use, drawings and whether a dedicated harmonised standard displaces EN 1090-1.
- Applicable OJ-cited standard and documented CPR-2011/CPR-2024 transitional route at the placing-on-market date.
- Specified execution class (EXC), design/fabrication allocation, steel grade and material traceability.
- Welding coordination, procedure/personnel qualifications, dimensional inspection and any required non-destructive testing.
- FPC procedures, nonconformity and subcontractor controls, and a notified FPC certificate where System 2+ applies.
- Product-type performance evidence, manufacturer declaration (DoP or DoPC as applicable), CE information and delivery instructions.
Work in this order; do not order certification before the scope and project requirements are stable.
- Classify the item: identify the customer, structural function, permanent incorporation and who places it on the EU market.
- Check the latest OJ harmonised-standard reference and product exclusions; document whether the 2011 or 2024 regime governs the family.
- Obtain the designer-approved execution specification and EXC; determine fabrication, welding, inspection and traceability requirements.
- Implement FPC and product-type assessment; engage a notified FPC body with the relevant scope if System 2+ is applicable.
- After supporting evidence is complete, issue the correct manufacturer declaration, apply CE marking as required, and transfer records to the buyer.
Changes that require a new check
Reassess before continuing to rely on the same technical file when any of these changes occurs:
- New load path, connection design, intended use or execution class.
- Changes to material grades, welding methods, significant subcontractors or traceability.
- New production premises or process changes affecting the scope or operation of FPC.
- A new or withdrawn harmonised-standard citation, product-family migration, or updated notified-body scope.
Record the change, identify affected declared characteristics, decide whether additional assessment or FPC review is needed, and update declarations/marking only on a supported basis. CE marking does not replace structural design approval or national rules for use in a building.
Boundary with general CE services
This page resolves the EN 1090-1 scope and steel-specific evidence decision. For cross-product declaration administration see the general CE documentation guide; for a general budgeting framework see the CE marking cost guide. Neither page replaces the steel classification and execution specification above.
Official sources
Next action: send your fabricator or compliance adviser the part drawing, intended load-bearing function, destination market, execution specification/EXC, manufacturing location, and the proposed harmonised standard. Request a written scope decision before placing the product on the EU market.
Questions manufacturers and buyers ask
Must every steel fabrication carry CE marking under EN 1090-1?
No. First verify that it is a structural construction product within that standard, supplied for the relevant intended use, and not covered by a more specific harmonised specification.
Who selects EXC1, EXC2, EXC3 or EXC4?
The execution class must follow the project structural/execution specification established by the competent designer/specifier; the fabricator must demonstrate that its processes cover the specified work.
Does the notified body issue the CE mark for each beam?
No. Under System 2+ the notified body certifies factory production control within its notified scope; the manufacturer remains responsible for the declaration and CE marking.
Is a one-off on-site component automatically exempt?
No. Any exception depends on specific legal conditions, the market-supply facts and applicable national rules. Obtain a documented assessment rather than using “bespoke” as a blanket exemption.
Did the new CPR automatically replace every EN 1090-1 DoP with a DoPC in 2026?
No. The transition is by product family and harmonised-standard citation. Verify the applicable route before choosing the declaration form.