1. What is EN 10204?
EN 10204:2004 is the European standard governing the types of inspection documents that material manufacturers supply to purchasers. It was updated from the 1991 version (which used letter designations such as A and B) and is now referenced almost universally in offshore, pressure equipment, and structural procurement specifications across Europe and increasingly worldwide.
The standard defines four document types — 2.1, 2.2, 3.1, and 3.2 — distinguished by two axes:
- Who validates the test results? The manufacturer alone, or an independent/third-party inspector.
- Are the results specific to this deliverable? A declaration based on non-specific test results (like a batch average), or actual test results traceable to the product ordered.
2. The Four Certificate Types
Type 2.1 — Declaration of Compliance with the Order
A document in which the manufacturer declares that the products supplied comply with the requirements of the order. No test results are included — it is a statement of conformity only. The declaration is made by an authorised representative of the manufacturer's own quality system.
When is this used offshore? Rarely, and only for non-structural, non-safety-critical items: standard hardware (nuts, bolts, washers to DIN/ISO), cable trays, handrails, minor brackets. You would never accept 2.1 for anything load-bearing or pressure-containing.
Type 2.2 — Test Report
A document in which the manufacturer declares that the products supplied comply with the requirements of the order, and provides actual test results — but the results are based on non-specific inspection, meaning the tests were performed on material from the same batch or production lot, not necessarily on the precise pieces delivered.
The document is validated by the manufacturer's own authorised representative, not by an independent inspector. This is acceptable for medium-criticality structural items where traceability to the specific piece is not mandated.
Type 3.1 — Inspection Certificate
A document in which the manufacturer declares that the products supplied comply with the requirements of the order, and provides test results specific to the actual deliverable — i.e., test specimens taken from the same heat/cast number as the pieces shipped.
Crucially, the document is validated by a representative of the manufacturer who is independent of the manufacturing department. In practice this is normally a quality/inspection department signatory. The inspector does not need to be from an external organisation — that is the distinguishing characteristic of 3.2.
3.1 is the baseline requirement for most structural, lifting, and pressure-retaining components in offshore work.
Type 3.2 — Inspection Certificate (Third-Party Validation)
The same content as 3.1 (specific traceability, actual test results), but validated by both:
- The manufacturer's authorised inspector (as per 3.1), and
- A representative of the purchaser, or a purchaser-nominated independent inspection authority (e.g. DNV, Bureau Veritas, Lloyd's Register, TÜV).
The independent inspector witnesses or verifies the testing, reviews the results, and co-signs the certificate. This is the highest level of traceability and independence available under EN 10204.
3. Side-by-Side Comparison
| Type | Contains Test Results? | Results Specific to Delivery? | Validated By | Typical Offshore Use |
|---|---|---|---|---|
| 2.1 | No — declaration only | N/A | Manufacturer representative | Minor non-structural items |
| 2.2 | Yes — batch/production lot | No — non-specific | Manufacturer representative | Medium-criticality structural |
| 3.1 | Yes — specific heat/cast | Yes — traceable to delivery | Manufacturer independent QC dept | Lifting, structural, pressure |
| 3.2 | Yes — specific heat/cast | Yes — traceable to delivery | Manufacturer QC + independent inspector (DNV, BV, etc.) | Safety-critical, classed components |
4. DNV-ST-0378 Requirements
DNV-ST-0378 (Offshore and Marine Containers, 2023) specifies material certificate requirements primarily in §5 Materials. The requirements depend on component category and material grade.
Structural Steel (S235, S355, etc.)
For primary structural members — corner castings, lifting fittings, main frames, fork pockets — DNV-ST-0378 requires type 3.1 as a minimum. The heat/cast identification must be traceable from the certificate to the marked component.
Padeyes and Lifting Points
Lifting appliances (padeyes, trunnions, lashing rings) are specifically called out. The steel grade must be supported by a 3.1 certificate, and where the component is fabricated to a drawing that forms part of a classed deliverable (e.g. a DNV 2.7-1 container), DNV may require witness of testing — effectively 3.2 — depending on the survey scope agreed at order placement.
Weld Consumables
DNV-ST-0378 requires weld consumables to be certified to the applicable EN/AWS standard. A 2.2 test report is the minimum; for critical joints a 3.1 is expected. The consumable certificate must state the classification (e.g. E7018, S2Si) and the manufacturer's batch number.
5. EN 13445 and Pressure Equipment
EN 13445 (Unfired Pressure Vessels) references EN 10204 material certificates directly in its materials clause. The requirements are severity-tiered by PED (Pressure Equipment Directive) category:
- PED Category I: Type 2.2 is generally acceptable for low-pressure, low-hazard vessels.
- PED Category II–III: Type 3.1 is required for pressure-retaining parts (shells, heads, nozzles). This applies to the majority of process vessels on offshore platforms.
- PED Category IV / Article 4(3) special: Type 3.2 with an EU-recognised independent body as the co-signatory is required. This covers high-pressure, high-hazard applications such as high-pressure separators and wellhead equipment.
Note that offshore process equipment is subject to ATEX zoning and may need to comply with multiple overlapping schemes — PED, ATEX, and DNV classification — each of which can independently mandate a cert type. The most demanding requirement governs.
6. NORSOK M-650 and Supplementary Testing
NORSOK M-650 (Qualification of Manufacturers of Special Materials) is a Norwegian oil & gas sector supplement that imposes requirements beyond EN 10204 type 3.2. It applies specifically to special materials — duplex stainless steels, super duplex, titanium, nickel alloys, and 6Mo austenitic steels — commonly used in topside process piping and subsea applications.
Under M-650, manufacturers must be pre-qualified, and material deliveries require:
- Full chemical analysis (all elements specified in the material standard)
- Corrosion testing (ASTM G48 for duplex/super duplex)
- Ferrite content measurement (ASTM E562 / Fischer)
- Impact testing at specified temperatures
- EN 10204 type 3.2 certificate, with the NORSOK supplementary data attached
If a drawing or datasheet notes per NORSOK M-650, a standard 3.2 is not sufficient — the additional test data must accompany the certificate. This is a common source of procurement non-conformances when engineers specify M-650 materials without informing the purchasing team of the supplementary documentation requirements.
7. What Must Appear on a 3.1 / 3.2 Certificate
EN 10204:2004 §4.2 lists the mandatory content. For a 3.1 certificate this includes:
- Name and address of the manufacturer
- Description of the products (type, grade, dimensions, quantity)
- Reference to the order — order number and/or drawing number
- Heat/cast identification number traceable to the tested material
- Results of all tests required by the product standard (tensile, yield, elongation, impact, chemistry)
- Declaration of compliance with the specification
- Name, position, and signature of authorised representative (independent of manufacturing)
A 3.2 certificate requires all of the above, plus the co-signature and designation of the authorised purchaser or independent inspection body representative.
8. How to Call Out Cert Type on Drawings
Material certificate requirements should appear in at least two places: the drawing title block / general notes, and the material designation in the parts list (BOM).
Title Block / General Notes
The general note should read something like:
MATERIAL CERTIFICATES:
ALL STRUCTURAL STEEL: EN 10204 TYPE 3.1
PADEYES AND LIFTING FITTINGS: EN 10204 TYPE 3.1 (MIN)
PRESSURE-RETAINING PARTS: EN 10204 TYPE 3.2
WELD CONSUMABLES: EN 10204 TYPE 2.2 (MIN)
Parts List Column
Add a "CERT" column to the bill of materials and populate it with 2.2, 3.1, or 3.2 for each line item. This makes it unambiguous for purchasing and reduces the risk of the correct cert type being missed at order placement.
Weld Procedure Qualification (WPS / WPQR)
The welding procedure specification should reference the required certificate type for base metal and consumables, consistent with what is shown on the drawing. Discrepancies between the drawing and the WPS are a common audit finding.
9. Common Mistakes and NCR Triggers
Accepting a 2.2 Where 3.1 is Required
The most common procurement failure. If the purchase order does not explicitly state EN 10204 3.1, many steel stockholders will supply a 2.2 by default — it is cheaper to produce and they have less liability. Specify the required cert type on every line of the purchase order, and verify it on receipt.
Missing Heat Number on the Certificate
A certificate without a heat/cast number is not a valid 3.1. It may look complete — it has signatures, test results, and a declaration — but without heat traceability it cannot be verified against the physical material. Return it to the supplier for replacement documentation before accepting the material into stock.
Treating Foreign Equivalents as Automatic Substitutes
Some manufacturers supply Russian (GOST), Japanese (JIS), or Chinese (GB) test documents that are described as "equivalent to EN 10204 3.1". These are not equivalent without independent verification. Under EN 10204, the cert must explicitly state the EN 10204 type designation. Foreign format certs may be accepted by agreement, but this must be formally documented via a materials deviation request (MDR) or equivalence statement from the relevant authority.
Not Specifying Cert Type at Order Placement
A 3.1 certificate requires the manufacturer to plan witness/inspection steps before the material is shipped. If you request a 3.1 after the fact — or after the material has already been shipped — the supplier cannot retroactively issue it. They can only provide a 2.2 or a retrospective declaration, neither of which satisfies a 3.1 requirement. Specify cert type at order placement, always.
Accepting a Certificate Without Verifying Scope
A single certificate may cover multiple heats or line items. Verify that the item you received — by product form, dimension, heat number, and quantity — is explicitly listed on the certificate. A certificate for "S355J2 plate 20mm × 2000 × 6000, Heat 123456" does not cover S355J2 flat bar from the same heat unless that flat bar is also listed.
10. Incoming Material Certificate Acceptance Checklist
Before accepting material into stores or releasing it for fabrication, verify each of the following against the EN 10204 certificate:
- Certificate type matches what is required by the drawing and purchase order (2.1 / 2.2 / 3.1 / 3.2)
- Manufacturer name and address are present
- Order or purchase order reference matches the current order
- Product description matches the ordered item — grade, form, dimensions, surface condition
- Heat/cast number is stated on the certificate
- Heat/cast number matches the marking on the physical material
- All required mechanical properties are stated — Rp0.2, Rm, A%, KV at specified temperature
- Chemical composition (ladle analysis) is stated and within product standard limits
- Certificate is signed by authorised representative(s) with name, position, and date
- For 3.2: independent inspector signature and organisation are present
- For NORSOK M-650 materials: supplementary test data (corrosion, ferrite) is attached
- No erasures, corrections, or alterations without manufacturer countersignature
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