Regulatory guidance and project coordination

CE Marking For Structural Steel In The Eu

Scope and evidence must be confirmed before any paid tests or filings.

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 caseLikely route or riskNext verification
Fabricated beam or column carrying building loadsPotential 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 fallsNot 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 standardsAn 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 siteNo 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.

ActorInput or responsibilityEvidence to retain or check
Structural designer / specifierState intended use, design responsibilities, execution class and relevant structural requirements.Approved drawings, execution specification, load/design basis and interfaces.
Fabricator acting as manufacturerAssess 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 bodyWhere 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 / distributorMatch 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.

  1. Classify the item: identify the customer, structural function, permanent incorporation and who places it on the EU market.
  2. Check the latest OJ harmonised-standard reference and product exclusions; document whether the 2011 or 2024 regime governs the family.
  3. Obtain the designer-approved execution specification and EXC; determine fabrication, welding, inspection and traceability requirements.
  4. Implement FPC and product-type assessment; engage a notified FPC body with the relevant scope if System 2+ is applicable.
  5. 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.

Responsible for publication: Khachatrian Razmik

Last updated: 2026-10-16

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