STEEL

CONSTRUCTION

CE Marking



2 CE MARKING

Foreword


The construction industry is facing one of 
the most significant changes for a decade as 
CE Marking of construction products

becomes mandatory in all Member States 
throughout the European Union and the 
European Economic Area.

 

CE Marking for all construction products, 
covered by a harmonised European standard 
or conforming to a European Technical

Assessment, became mandatory from 
1 July 2013. Manufacturers, such as Tata 
Steel, CE Marked their products well in 
advance of the deadline to ensure that there 
was no disruption to material supply.

 

For fabricated structural steelwork, 
CE Marking will become mandatory on 
1 July 2014. This represents a major development for engineers, contractors and 
steelwork specialists and it demands careful attention to

the new obligations imposed.

 

This supplement highlights how the steel construction sector has been working

behind the scenes towards achieving CE Marking. Perhaps more importantly, it

spells out in detail what it will mean for the rest of the construction sector and 
the straightforward process that you need to follow in order to comply with the 
Construction Products Regulation, which is the legal basis for the new regime.

 

The steel sector is already making excellent progress, so there will be no disruption 
to the regular supply of fabricated structural steelwork from accredited sources. 
The BCSA has made CE Marking compliance a condition of membership of the 
Association after 1 July 2014. By using a BCSA Members steelwork contractor, 
clients, main contractors and insurers can be assured that due diligence has already 
been undertaken by the BCSA as part of their membership audit.

 

I’m sure you will find this supplement helpful.

August 2013

Sarah McCann-Bartlett, 

Director General,

British Constructional 

Steelwork Association



CE MARKING 3

Contents

5 Introduction

6 CE Marking of products

7 CE Marking of fabricated structural steelwork

9 Engineer’s responsibility

 1. Determine Consequence Class

 2. Define Service Category

 3. Define Production Category

 4. Derive Execution Class

15 Client and/or main contractor’s responsibility

16 How to check compliance with the CPR and CE Marking

 What to check - Factory Production Control and 
Welding Certificates

 What to check - Declaration of Performance

18 Summary

This information 

on CE Marking 

in steel construction 

is available at

www.steelconstruction.info/ 
CE_marking



4 CE MARKING

CE Marking

Mandatory


Construction Products

1 July 2013


Fabricated Structural 
Steelwork

1 July 2014



Introduction


CE Marking (formerly Conformité Européenne) demonstrates compliance with the appropriate 
manufacturing standard for a product. As a symbol, it will be familiar as it has been a 
requirement for many years on products sold in the European Union such as toys and electrical 
goods. 

Under the Construction Products Regulation (CPR), new legal obligations have been placed 
on manufacturers, distributors and importers of construction products used within the EU to 
CE Mark their products where they are covered by either a harmonised standard or European 
Technical Assessment (ETA). This applies not only to constituent products (such as steel beams, 
bolts etc) but also to fabricated elements and systems made from CE Marked products. In 
the UK, penalties for non-compliance include suspension notices, prohibition notices, notices 
to warn and application for forfeiture. For certain offences the penalties may include a fine, 
imprisonment or both.

The CPR required the CE Marking of all construction products from 1 July 2013. CE Marking of 
fabricated structural steelwork will be mandatory from 1 July 2014.

The CPR describes the legal obligations it places on the construction supply chain in terms of 
‘manufacturers’, ‘distributors’ and ‘importers’. However, the construction supply chain in the UK 
would normally be described in terms of clients, designers, specifiers, contractors and specialist 
subcontractors. The purpose of this document is to provide some guidance to the UK supply 
chain on the implications of the CPR on steel construction.

The requirements of the CPR and CE Marking apply to construction products used on a project 
irrespective of whether that project has been designed to National Standards (i.e. BS 5950) or to 
the Eurocodes.



CE Marking of products

Under the CPR, all products used in 
construction must now have CE Marking 
to demonstrate compliance where either 
a harmonised standard or ETA is in force. 
All mainstream construction products are 
covered by harmonised standards and must 
therefore be CE Marked. 

For fabricated structural 
steelwork, engineers, contractors 
and steelwork contractors 
should have amended their 
specifications accordingly 
to ensure only CE Marked 
products are used on their 
projects. 

This has not caused any 
disruption in the supply 
of material as manufacturers, such as Tata 
Steel with their Advance section range and 
Celsius® 355 and Hybox® 355 structural 
hollow sections had been CE Marking 
their products for a number of years in 
anticipation of the CPR requirement and 
publish their declarations of performance at 
www.tatasteeleurope.com/dop

Product standards 
for CE Marking 

Mandatory for products 

open sections – BS EN 10025-1

hollow sections

• hot finished – BS EN 10210-1 

• cold formed welded – 
BS EN 10219-1

plates – BS EN 10025-1

structural bolts 

• non-preloaded structural bolting 
assemblies – BS EN 15048-1

• high strength structural bolting 
assemblies for preloading – 
BS EN 14399-1

Mandatory for steelwork delivered on 
or after 1 July 2014

fabricated structural steelwork – 
BS EN 1090-1

Note: 

1. a full list of harmonised standards can be found 
on the EU’s Nando website – www.ec.europa.eu/
enterprise/newapproach/nando/index.cfm?
fuseaction=cpd.hs 

2. a full list of ETAs can be found on the EOTA 
website – www.eota.be/pages/valideta


Specifications 
should have been 
amended to ensure 
only CE Marked 
products are now 
used on projects



CE Marking of fabricated structural 
steelwork

The harmonised standard covering fabricated structural steelwork is BS EN 1090: Execution of 
steel structures and aluminium structures. 

Part 1 of the standard is the Requirements for Conformity Assessment of Structural 
Components. It describes how manufacturers can demonstrate that the components they 
produce meet the declared performance characteristics (the structural characteristics which 
make them fit for their particular use and function). 

Part 2 is the Technical Requirements for Steel Structures. It specifies 
the requirements for the execution of steel structures to ensure 
adequate levels of mechanical resistance and stability, serviceability 
and durability. It determines the performance characteristics for 
components that the manufacturer must achieve and declare 
through the requirements of Part 1.

BS EN 1090-1 becomes mandatory on 1 July 2014. It will therefore 
be a legal requirement for all fabricated structural steelwork delivered 
to site from that date to be CE Marked.

The BCSA has made CE Marking compliance a condition of 
membership of the Association from 1 July 2014, so selection of 
any BCSA Member company will guarantee that the steelwork 
contractor will have the necessary certification to comply with the 
CPR requirements. Clients and main contractors will therefore have confidence in the complete 
supply chain for steel construction from manufacture of the steel sections through distribution 
to fabrication and erection on site.

Specifications

Contracts for fabricated structural steelwork 
to be delivered to site on or after 1 July 2014 
should include the following specifications, which 
incorporate the obligations of BS EN 1090-1 and 
BS EN 1090-2 on the steelwork contractor:

Buildings

• National Structural Steelwork Specification 
(NSSS) for Building Construction 5th Edition 
CE Marking Version

Bridges

• Model Project Specification for the Execution 
of Steelwork in Bridge Structures (SCI Guide 
P382) revised January 2012 

NSSS 5th Edition 

CE Marking Version 
should be used 

on contracts where 
steel is delivered to 
site on or after 

1 July 2014



8 CE MARKING



Engineer’s responsibility

For any project, the required quality of fabrication or Execution 
Class must be specified. BS EN 1090-2 requires the Execution 
Class to be specified for:

• the works as a whole

• an individual component

• a detail of a component

The engineer is responsible for specifying the Execution Class 
for the structure, the components and the details. In some 
cases the Execution Class for the structure, the components 
and the details will be the same while in other cases the 
Execution Class for the components and the details may be 
different to that for the whole structure.

The procedure for determining the Execution Class is a 
straightforward four step process:

1. Determine the Consequence Class 

2. Define the Service Category 

3. Define the Production Category

4. Derive the Execution Class

Whilst each building needs to be 
considered on its own merits, 
Execution Class 2 (EXC2) will 
be appropriate for the majority 
of buildings constructed in 
the UK. If the Execution 
Class is not specified on a 
project, Clause 4.1.2 of 
BS EN 1090-2 states that 
EXC2 shall apply.

It should also be noted that the NSSS for 
Building Construction 5th Edition CE Marking Version has 
been written for the steelwork contractor to deliver the 
requirements of EXC2. 

Consequence 
ClassTable B1BS EN 1990or 
Table A.1BS EN 1991-1-7Service 
CategoryTable B.1BS EN 1090-2Production 
CategoryTable B.2BS EN 1090-2ExecutionClassTable B.3BS EN 1090-2
Summary 

EXC2 will be 
the appropriate 
requirement for the 
majority of buildings 
constructed 

in the UK



1. Determine the Consequence Class

Step 1

CC2 will be 
appropriate for 
the majority 
of buildings 
constructed in the 
UK


The purpose of categorising the Consequence Class is to ensure that buildings (and other 
structures) are constructed with the appropriate level of quality control within the fabrication 
process. Consequence Classes are derived on the basis of building type, building height 
(number of storeys), floor plan area per storey (for retail) and occupancy. A structure, or a part 
of it, could also contain components with different Consequence Classes.

BS EN 1990 gives guidelines for the choice of Consequence Class in Table B1 (below). 

Table A.1 of BS EN 1991-1-7 (below) gives examples of categorisation of building type and 
occupancy according to Consequence Classes that assist with the implementation of Annex B of 
BS EN 1990.

Table B1

Definition of Consequence Classes

Consequence 
Class

Description

Examples of buildings and civil engineering works

CC3

High consequence for loss of human life 
or economic, social or environmental consequences very great

Grandstands, public buildings where consequences of 
failure are high (eg a concert hall)

CC2

Medium consequence for loss of human life; 
economic, social or environmental consequences considerable

Residential and office buildings, public buildings where 
consequences of failure are medium (eg an office building)

CC1

Low consequence for loss of human life 
and economic, social or environmental consequences small or negligible

Agricultural buildings where people do not normally enter 
(eg storage buildings), greenhouses





Table A.1

Categorisation of Consequence Classes

Consequence 
Class

Example of categorisation of building type and occupancy

1

Single occupancy house not exceeding 4 storeys.

Agricultural buildings.

Buildings into which people rarely go, provided no part of the building is closer to another building, or area where people do go, than a 
distance 1½ times the building height

2a
Lower Risk 
Group

5 storey single occupancy houses.

Hotels not exceeding 4 storeys.

Flats, apartments and other residential buildings not exceeding 4 storeys.

Offices not exceeding 4 storeys.

Industrial buildings not exceeding 3 storeys.

Retailing premises not exceeding 3 storeys or less than 1,000m² floor area in each storey.

Single storey educational buildings.

All buildings not exceeding 2 storeys to which the public are admitted and which contain floor areas not exceeding 2,000m² at each storey.

2b
Upper Risk 
Group

Hotels, flats, apartments and other residential buildings greater than 4 storeys but not exceeding 15 storeys.

Educational buildings greater than a single storey but not exceeding 15 storeys.

Retailing premises greater than 3 storeys but not exceeding 15 storeys.

Hospitals not exceeding 3 storeys.

Offices greater than 4 storeys but not exceeding 15 storeys.

All buildings to which the public are admitted and which contain floor areas exceeding 2,000m² but not exceeding 5,000m² at each 
storey.

Car parking not exceeding 6 storeys.

3

All buildings defined above as Class 2 Lower and Upper Consequence Class that exceed the limits on area and number of storeys.

All buildings to which members of the public are admitted in significant numbers.

Stadia accommodating more than 5,000 spectators.

Buildings containing hazardous substances and/or processes.





Notes: 

1. For buildings intended for more than one type of use the ‘Consequence Class’ should be that relating to the most onerous type.

2. In determining the number of storeys, basement storeys may be excluded provided such basement storeys fulfil the requirements of 
‘Consequences Class 2b Upper Risk Group’

3. UK Building Regulations Approved Document A contains a similar table to A.1 of EN 1991-1-7 which may also be used to determine the 
Consequence Class.



 

SCI Guide P391 provides guidance on classification of mixed-use buildings and buildings with basements. 
(Note: as classification classes are also used to determine the robustness strategy for a building, some of the guidance is 
dependent on the robustness strategy adopted, particularly where basements are present.)

2a, or 2b if 
retail premises 
> 1,000m²
FlatsShop
2 storeys of flats over one storey of retailing 
premises. This case should be considered as 3 storeys 
of retailing premises. Therefore, apply Class 2a to 
the whole building, or apply Class 2b to the whole 
building if floor area of retailing premises is 1000m² 
or more (per storey).

2bFlatsShop
2 storeys of flats over 2 storeys of retailing premises. 
This case should be taken as 4 storeys of retailing 
premises. Therefore, apply Class 2b to the whole 
building.

2bFlatsMovement joint2a2bOfficesOffices
4 storeys of flats adjacent to 5 storeys of offices. 
Class 2b should be applied to the 5 storey office area 
and extending to a suitable structural discontinuity in 
the 4 storey residential area and Class 2a should be 
applied to the remaining 4 storey residential area.

2bFlatsFlats2a2b4 storey over basement5 storey over basement
In determining the number of storeys for 
classification, basement storeys may be excluded if 
they fulfil the robustness requirements of Class 2b 
buildings. Otherwise, the basement storeys must 
be included in determining the number of storeys 
for building classification. The basement can be for 
habitable accommodation or parking. 



2. Define Service Category

Step 2

SC1 will be 
appropriate for 
the majority 
of buildings 
constructed in 

the UK

Service categories are the method used in BS EN 1090-2 to consider the risk from the actions 
to which the structure and its parts are likely to be exposed to during erection and use, 
such as fatigue and likelihood of seismic actions. They also consider the stress levels in the 
components in relation to their resistance.

Service categories are determined from Table B.1 of BS EN 1090-2 but for most buildings in 
the UK, SC1 will be appropriate.


Table B.1

Suggested Criteria for Service Categories

Categories

Criteria

SC1

• Buildings and components designed for quasi static actions only (Example: Buildings)

• Structures and components with their connections designed for seismic actions in regions with low seismic activity and in DCL*

• Structures and components designed for fatigue actions from cranes (class S0 )**

SC2

• Structures and components designed for fatigue actions according to EN 1993. (Examples: Road and railway bridges, 

 cranes (class S1 to S9 )**, structures susceptible to vibrations caused by wind, crowd or rotating machinery.)

• Structures and components with their connections designed for seismic actions in regions with medium or high seismic activity and in 
DCM* and DCH*.





Notes: 

* DCL, DCM, DCH: ductility classes according to EN 1998-1.

** For classification of fatigue actions from cranes, see EN 1991-3 and EN 13001-1.

3. Define Production Category

Production categories are the method used in BS EN 1090-2 to consider the risk from the 
complexity of the fabrication of the structure and its components, e.g. application of particular 
techniques, procedures or controls.

Production categories are determined from Table B.2 of BS EN 1090-2 and it should be 
noted that a structure or part of a structure may contain components or structural details 
that belong to different production categories. 

However, in all cases, the Execution Class is not sensitive to the Production Category selected.

Step 3

Execution 
Class is not 
sensitive to 
the Production 
Category


Table B.2

Suggested Criteria for Production Categories

Categories

Criteria

PC1

• Non welded components manufactured from any steel grade products

• Welded components manufactured from steel grade products below S355

PC2

• Welded components manufactured from steel grade products from S355 and above

• Components essential for structural integrity that are assembled by welding on construction site

• Components with hot forming manufacturing or receiving thermic treatment during manufacturing

• Components of CHS lattice girders requiring end profile cuts







4. Derive Execution Class

Having determined the Consequence Class, Service Category and Production Category for a 
building, the required Execution Class is derived simply from Table B.3 of BS EN 1090-2.

For the majority of buildings constructed in the UK, EXC2 will be the appropriate requirement. 
Where no Execution Class is specified, Clause 4.1.2 of BS EN 1090-2 states that EXC2 shall 
apply.

The engineer should always derive the Execution Class based on the design parameters 
appropriate to each project. The requirements to each Execution Class are listed in Table A3 of 
BS EN 1090-2 and can be reviewed by the engineer if desired. 

However, the engineer should avoid over-specification of the Execution Class wherever possible 
to avoid unnecessary costs being introduced. For example, EXC2 is the Execution Class derived 
for a project but the engineer requires full traceability (an EXC3 requirement) instead of the 
partial (or batch) traceability requirement of EXC2. Rather than specifying EXC3 on the basis of 
achieving this single Clause requirement, it is suggested that EXC2 is still specified but with the 
higher level of traceability added to the specification. 

Table B.3

Recommended Matrix for Determination of Execution Classes

Consequence classes

CC1

CC2

CC3

Service categories

SC1

SC2

SC1

SC2

SC1

SC2

Production 
categories

PC1

EXC1

EXC2

EXC2

EXC3

EXC3 a

EXC3 a

PC2

EXC2

EXC2

EXC2

EXC3

EXC3 a

EXC4

a EXC4 should be applied to special structures or structures with extreme consequences of a structural failure as required by national provisions





Note: 

Annex B of BS EN 1090-2 is classed as ‘informative’. Therefore the approach described is not mandatory and the 
engineer can base the selection of Execution Class on experience provided they can support their decision.

Step 4 

EXC2 will therefore 
be appropriate 
for the majority 
of buildings 
constructed in

 the UK



Steelwork contractor 
requirements for CE Marking

In order to be able to CE Mark the fabricated structural 
steelwork that they produce, steelwork contractors are 
required to declare performance to the System 2+ level 
of assessment (as described in Annex V of the CPR). This 
requires them to undertake:

• initial type-testing of the product

• Factory Production Control (FPC), which will include

· 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

They must also be assessed by a notified body that will 
carry out:

• initial inspection of the manufacturing plant 

• initial inspection of the FPC

• continuous surveillance, assessment and approval of 
the FPC, which will typically include:

· an annual audit to ensure continued competence 
to the declared Execution Class (Table B.3 of BS EN 
1090-1 sets out minimum levels for the routine surveillance 
intervals)

The notified body will then issue a FPC certificate and 
Welding Certificate identifying the Execution Class that 
the steelwork contractor has achieved.



Client and/or main contractor’s responsibility

For all fabricated structural steelwork delivered to site from 1 July 2014, there is a legal 
requirement under the CPR that it is CE Marked.

In order to achieve this, the client or main contractor should appoint a steelwork contractor 
with an Execution Class equal to that required for the project, as determined by 
BS EN 1090-1. It should be noted that steelwork contractors with EXC3 capability 
can be used for EXC1, 2, & 3; and a steelwork contractor with EXC2 capability can 
only be used for EXC1 & 2.

Compliance with the requirements of BS EN 1090-1 is no small task and places 
obligations on the steelwork contractor that are onerous and take significant 
time to put into place. To eliminate the risk of non-compliance with the CPR, 
it is recommended that clients and main contractors only award projects that 
will have fabricated structural steelwork delivered to site after 1 July 2014 
to steelwork contractors who have already achieved (or are close to achieving) 
CE Marking accreditation.

The BCSA has made CE Marking compliance a condition of membership of the Association 
from 1 July 2014, so selection of a BCSA Member company will guarantee that the steelwork 
contractor will have the necessary accreditation to comply with the CPR requirements. 

The directories for buildings and bridgeworks on BCSA’s 
website (www.steelconstruction.org) include details of 
accredited certification levels achieved by each member. 
Clients and main contractors can use this to find steelwork 
contractors with an Execution Class equal to that required for 
their project. It also states the level of accreditation achieved 
by those steelwork contractors who are moving towards 
achieving CE Marking.

Contract documentation should also be updated to incorporate CE Marked version of NSSS 
5th Edition, which incorporates the obligations of BS EN 1090-1 and BS EN 1090-2 on the 
steelwork contractor.

 

It should be noted that if a non-EU steelwork contractor is used on a project, the CPR puts 
liability on clients and/or main contractors. In that instance, the party engaging the steelwork 
contractor would be classed as an importer under the CPR and must comply with ‘Obligations 
of Importers’ given in Article 13 of the regulations.

Selecting a 
BCSA Member 
will ensure 
CE Marking 
compliance



How to check compliance 
with the CPR and CE Marking

In order for a steelwork contractor to demonstrate their right to CE Mark their products, 
they must provide the following three documents:

1. Factory Production Control (FPC) Certificate – issued by a notified body

2. Welding Certificate – issued by a notified body

3. Declaration of Performance (DoP) – issued by the steelwork contractor

The client or main contractor engaging the steelwork contractor should carry out 
due diligence before appointing any steelwork contractor who will be delivering 
fabricated structural steelwork to site on or after 1 July 14. Likewise, insurers should 
complete a similar due diligence process before giving Professional Indemnity 
insurance to a steelwork contractor who wants to CE Mark their products.

As the BCSA has made CE Marking compliance a condition of membership after this date, 
simply selecting a BCSA Member will ensure compliance with the regulations. The client, main 
contractor or insurer would not need to carry out due diligence of the steelwork contractor in 
this case since it has already been undertaken by the BCSA as part of their membership audit.

CE Marked fabricated 
steelwork must be 
supported by a Factory 
Production Control 
(FPC) Certificate, a 
Welding Certificate 
and a Declaration of 
Performance

SteelConstructionCertificationSchemeLimited4WhitehallCourt,Westminster,LondonSW1A2ESTel:+44(0)2078393980Fax:+44(0)2077478199Email:sccs@steelconstruction.orgwww.steelconstruction.orgF112SCCSCertGold:Layout 1 18/2/11 16:11 Page 1EC Certifi cateofFactory Production Control (FPC)
2273 – CPR - 001In compliance with the Construction Products Regulation or CPR, it has been stated that the 
construction product:
Structural Components for Steel StructuresHarmonisedType / Execution Class of the Construction ProductDeclaration MethodEN 1090-1: 2009+A1:2011Load bearing and welded structural steel components up to 
EXC 2 according to EN 1090-2:2008 +A1:20111, 2, 3a and 3b table A.1of EN 1090-1:2009 +A1:2011placed on the market byABC Engineering Ltdand produced in the factory(ies)
Thrimpson Plant, Thrimpson Road, Grillnik, Pondington, West Plumshire PM15 7TLGunburton McAvis Plant, Nyasa Way, Spent, East Plumshire BO42 9RFLydecker & Lydecker Plant, Grimwade Road, Hulke, Adamshire AD4 8BBis submitted by the manufacturer to the initial type-testing of the product, a factory production 
control and to the further testing of samples taken at the factory in accordance with a prescribed 
test plan and that the notifi ed body No. 2273 – Steel Construction Certifi cation Scheme Ltd - has 
performed the initial inspection of the factory and of the factory production control and performs the 
continuous surveillance, assessment and approval of the factory production control.
Attestation This certifi cate attests that all provisions concerning the attestation of 
factory production control described in Annex ZA of the standard: 
EN 1090-1: 2009 +A1:2011 were applied.
Date of next Surveillance by 31 March 2014Validity Period This certifi cate remains valid as long as the conditions laid down in the 
harmonised standard in reference or the manufacturing conditions in the 
factory or the FPC itself are not modifi ed signifi cantlyChairman: Scheme Manager:
SteelConstructionCertificationSchemeLimited4WhitehallCourt,Westminster,LondonSW1A2ESTel:+44(0)2078393980Fax:+44(0)2077478199Email:sccs@steelconstruction.orgwww.steelconstruction.orgF112SCCSCertGold:Layout 1 18/2/11 16:11 Page 1Welding Certifi cate9809 – CPR - 001In compliance with EN 1090-1:2009, table B.1, the following has been stated:
This Welding Certifi cate is an annex to 
the EC-Certifi cate of the Factory Production Control (FPC) 9809 – CPR - 001.
This Welding Certifi cate is only valid in conjunction with the aforementioned 
EC-Certifi cate in the scope of the Construction Products Regulation or CPR.
Manufacturer ABC Engineering LtdFacilities of the Thrimpson Plant, Thrimpson Road, Grillnik, Pondington, 
Manufacturer West Plumshire PM15 7TL 
Gunburton McAvis Plant, Nyasa Way, Spent, East Plumshire 
BO42 9RF 
Lydecker & Lydecker Plant, Grimwade.Road, Hulke, 
Adamshire AD4.8BBStandard EN 1090-2: 2008 +A1:2011Execution Class up to EXC 2 according EN 1090-2:2008 +A1:2011Welding Process(es) 111 – Manual metal arc 
121 – Submerged metal arcBase Material(s) S235, S275, S355 according to EN 10025-2Responsible Welding Mr L DroghedaCoordinatorSubstitute NoneAttestation This certifi cate attests that all procedures for the execution 
and surveillance of welding works are implemented.
Date of next 31 March 2014SurveillanceValidity Period This certifi cate remains valid as long as the conditions laid down 
in the technical specifi cation in reference (in connection with 
EN 1090-1:2009 +A1:2011) or the manufacturing conditions in 
the factory or the FPC itself are not modifi ed signifi cantly.
Chairman: Scheme Manager:
4

4

1

1

2

3

3



What to check – Factory Production Control 
and Welding Certificates

 1 Declared performance – ensure that the steelwork contractor meets or exceeds the 
Execution Class requirements for the project.

 2 Base materials – the steelwork contractor is covered for welding with material strength and 
subgrades up to and including those declared on the Welding Certificate. Ensure that these 
are consistent with the requirements of the project.

 3 Date of next surveillance – check that the certificate is still current and covers the period of 
the contract. 

 4 Notified body number – check on the EU’s Nando website to ensure that it is a valid and 
current number associated with the notified body named on each certificate.

What to check – Declaration of Performance

The scope of the DoP to be issued by the steelwork contractor for each project is set out in 
Article 6 of the CPR, with a standard form included as Annex III. The standard form in Annex III 
covers all aspects of the CPR, whereas the example below suggests what would be appropriate 
to include when CE Marking fabricated structural steelwork along with some comments that 
might be helpful in interpreting the intent of the DoP standard form.

 A Steelwork contractor’s unique DoP Certificate 
identification number.

 B Steelwork contractor defined (may be omitted if not 
relevant).

 C Brief description of use, which may include project name 
and location.

 D Check that notified body and level of assessment declared 
is consistent with the FPC and Welding Certificates where 
appropriate.

 E Steelwork Contractors are not required to declare 
performance against all of the performance characteristics 
in Table ZA.1 of BS EN 1090-1 +A1:2011, but only those 
that are appropriate and for which they are responsible.

Declaration of PerformanceNo. 1234 
Type ABCDIntended Use Structural steelwork construction components and/or 
kits for use in building and civil engineering worksManufacturer ABC Engineering Ltd, Thrimpson Road, Grillnik, 
Pondington, West Plumshire PM15 7TLVerifi cation of constancy System 2+
Notifi ed Body Steel Construction Certifi cation Scheme 
4, Whitehall Court, Westminster, London SW1A 2ESNotifi ed Body No 2773SCCS has performed (i) initial inspection of the manufacturing plant and factory product 
control and (ii) continuous surveillance, assessment and evaluation of factory production 
control and issued Factory Production Control Certifi cate 2273-CPR-001 and 
Welding Certifi cate 9809-CPR-001.
Essential characteristicsPerformanceHarmonised 
technical 
specifi cationTolerances on dimensions and shapeEN 1090-2, tolerance class 1EN 1090-1: 2009WeldabilityEN 10025-2, S275EN 1090: 2009Fracture toughness/impact resistanceS275JR (27J @ 20°C)EN 1090: 2009Load bearing capacityNPDEN 1090: 2009Fatigue strengthNPDEN 1090: 2009Resistance to fi reNPDEN 1090: 2009Reaction to fi reClass A1 (steel only)EN 1090: 2009Release of cadmium and its compoundsNPDEN 1090: 2009RadioactivityNPDEN 1090: 2009DurabilitySurface preparation according to 
BS EN 1090-2, Preparation grade P3. 
Surface painted according to 
BS EN ISO 12944.
EN 1090: 2009 
The performance of the product identifi ed above is in conformity with the declared 
performance identifi ed in the table. 
Signed for and on behalf of ABC Engineering Ltd by: 
John Smith, Director 
Pondington, Plumshire 
1 April 2013
A

B

C

E

D



Summary

Overview

It is now a legal requirement to use CE Marked construction products. This did not cause any 
disruption in the supply of materials for fabricated structural steelwork as manufacturers, such 
as Tata Steel, had been CE Marking their products for a number of years in anticipation of the 
CPR requirement.

 

From 1 July 2014, it will be a legal requirement for all fabricated structural steelwork delivered 
to site to be CE Marked. In order to comply with the regulations, only steelwork contractors 
with an Execution Class equal to that required for a project should be considered.

Contracts for fabricated structural steelwork to be delivered to site on or after this date 
should include the NSSS for Building Construction 5th Edition CE Marking Version or Model 
Specification for the Execution of Steelwork in Bridge Structures (revised January 2012). Both 
of these specifications incorporate the obligations of the CPR and CE Marking on the steelwork 
contractor.

Engineer’s responsibility

The engineer is responsible for specifying the Execution Class for the 
structure as a whole, the components and the details that they have 
designed. 

Procedure for specification of Execution Class for a project:

1. Determine Consequence Class – Table B1, BS EN 1990 

 or Table A.1, BS EN 1991-1-7 

 [Usually 2a or 2b]

2. Define Service Category – Table B.1, BS EN 1090-2 

 [Usually SC1]

3. Define Production Category – Table B.2, BS EN 1090-2 

 [either PC1 or PC2]

4. Derive Execution Class – Table B.3, BS EN 1090-2 

 [will typically result in EXC2]

Whilst each building needs to be considered on its own merits, EXC2 
will be appropriate for the majority of buildings constructed in the UK. 

If the Execution Class is not specified on a project, Clause 4.1.2 of 
BS EN 1090-2 states that EXC2 shall apply.

Consequence 
ClassTable B1BS EN 1990or 
Table A.1BS EN 1991-1-7Service 
CategoryTable B.1BS EN 1090-2Production 
CategoryTable B.2BS EN 1090-2ExecutionClassTable B.3BS EN 1090-2

Client and/or main contractor’s responsibility

For all fabricated structural steelwork delivered to site from 1 July 2014, there is a legal 
requirement under the CPR that it is CE Marked. In order to achieve this, the client or main 
contractor should appoint a steelwork contractor with an Execution Class equal to that required 
for the project, as determined by BS EN 1090-2. It should be noted that steelwork contractors 
with EXC3 capability can be used for EXC1, 2, & 3; and a steelwork contractor with EXC2 
capability can only be used for EXC1 & 2.

The BCSA has made CE Marking compliance a condition of membership of the Association 
from 1 July 2014, so selection of a BCSA Member company will guarantee that the steelwork 
contractor will have the necessary accreditation to comply with the CPR requirements. The 
directories for buildings and bridgeworks on BCSA’s website (www.steelconstruction.org) 
include details of accredited certification levels achieved by each member.

It should be noted that if a non-EU steelwork contractor is used on a project, the CPR puts 
liability on clients and/or main contractors. In that instance, the party engaging the steelwork 
contractor would be classed as an importer under the CPR and must comply with ‘Obligations 
of Importers’ given in Article 13 of the regulations.

Check compliance with the CPR and CE Marking

In order for a steelwork contractor to demonstrate their right to CE Mark their products, they 
must provide the following three documents:

1. Factory Production Control Certificate

2. Welding Certificate

3. Declaration of Performance

The client or main contractor engaging the steelwork contractor should carry out due diligence 
before appointing any steelwork contractor who will be delivering fabricated structural 
steelwork to site on or after 1 July 2014. Likewise, insurers should complete a similar due 
diligence process before giving Professional Indemnity insurance to a steelwork contractor who 
wants to CE Mark their products.

The BCSA has made CE Marking compliance a condition of membership of the Association after 
this date, simply selecting a BCSA Member will ensure compliance with the regulations. The 
client, main contractor or insurer would not need to carry out due diligence of the steelwork 
contractor in this case since it has already been undertaken by the BCSA as part of their 
membership audit.



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Produced for

The British Constructional Steelwork Association

www.steelconstruction.org

and

Tata Steel

www.tatasteelconstruction.com

by Barrett, Byrd Associates

www.barrett-byrd.com

Version 2, August 2013




 davido.extraxim@gmail.com