EN 1090-1 — CE Marking for Structural Steel: FPC, DoP, and Notified Body Requirements

EN 1090-1 is the conformity assessment standard that controls CE marking for structural steel and aluminium components placed on the EU/EEA market under the Construction Products Regulation (CPR). Where EN 1090-2 defines how structural steelwork is fabricated, EN 1090-1 defines how a fabricator demonstrates that their factory and products consistently meet the required performance level — through Factory Production Control, a Declaration of Performance, and, for welded components, third-party certification by a Notified Body. Since July 2014, CE marking under EN 1090-1 has been mandatory for any structural steel component sold into the EU market.

For offshore fabricators supplying EU-registered structures — topsides modules, lifting frames, structural supports, padeye assemblies — understanding the EN 1090-1 obligations is as critical as the fabrication requirements themselves. A supplier with impeccable welding quality but no valid FPC certificate cannot legally CE-mark and sell their product into the EU market.

1. What is EN 1090-1 and Why It Matters

The full title is EN 1090-1:2009+A1:2011 — Execution of steel structures and aluminium structures — Part 1: Requirements for conformity assessment of structural components. It is a harmonised European Standard (hEN) under the CPR (Regulation EU No 305/2011), which means CE marking based on it carries the presumption of conformity with the CPR's essential characteristics for structural steel components.

EN 1090-1 establishes two things for every CE-marked structural component:

1. The conformity assessment route — which AVCP system applies, what the manufacturer must do, and what a Notified Body must verify.
2. The Declaration of Performance (DoP) — the legal document that accompanies every CE-marked component, declaring its performance against the essential characteristics listed in the standard's Annex ZA.

The standard's scope covers prefabricated structural components — not complete structures. A fabricated beam, a welded node, a truss chord, a lifting lug assembly, a support frame — all of these are structural components subject to EN 1090-1 when sold as products in the EU market. In contrast, a structure built on-site under an engineering contract may fall outside CPR scope, depending on jurisdiction and the terms of the supply contract.

2. Scope: What Components Does EN 1090-1 Cover?

EN 1090-1 applies to structural components made from carbon steel, stainless steel, weathering steel, and aluminium alloys, fabricated by any combination of welding, bolting, cutting, forming, and surface treatment. The critical scoping question is whether the component is:

• Prefabricated — i.e., made in a factory (workshop) and supplied as a product, rather than assembled in situ
• Structural — i.e., contributing to load-bearing function
• Placed on the EU/EEA market — i.e., sold or supplied as a product under the CPR

Components that fall outside EN 1090-1 scope include: non-structural architectural steelwork with no load-bearing function, components designed and built entirely under a works contract on a specific construction site (not as a product), and components governed by other harmonised standards (e.g., EN 13001 for crane structures).

2.1 Welded vs Non-Welded Components

The most important distinction within EN 1090-1 scope is whether a component includes welded joints. This drives which AVCP system applies:

• Welded structural components (Class W): AVCP System 2+ — Notified Body certification of FPC required
• Non-welded structural components: AVCP System 3 — Notified Body performs initial type testing; manufacturer self-certifies ongoing production

In practice, virtually all structural steel components of consequence to offshore engineers are welded — meaning System 2+ is the default regime they will encounter.

3. AVCP Systems: 2+ vs 3 — Which Applies to You?

AVCP stands for Assessment and Verification of Constancy of Performance. It is the CPR's framework for deciding how much third-party involvement is needed to demonstrate that a product consistently performs as declared. For structural steel components, two AVCP systems are defined in EN 1090-1 Annex ZA:

Under System 2+, the Notified Body does not certify individual products — it certifies the system that produces them. This is an important distinction: the CE mark and DoP are the manufacturer's declaration, backed by the Notified Body's assurance that the FPC system is sound. The Notified Body number appears on the DoP and the CE marking label.

Under System 3, the Notified Body's role is limited to the Initial Type Test — a one-time test campaign that establishes the declared performance values. The manufacturer then self-declares ongoing conformity using those ITT results as the basis. No ongoing Notified Body surveillance is required under System 3.

3.1 Execution Class and AVCP System

The execution class assigned to the component by the designer (per EN 1090-2 Annex B) also influences AVCP system selection:

EXC3 and EXC4 structures are inherently welded and inherently high consequence — System 2+ is the only applicable route. For offshore primary structural members, this is the universal operating assumption.

4. Factory Production Control (FPC) Requirements

The Factory Production Control system is the manufacturer's documented, implemented quality management framework for consistently producing compliant structural components. EN 1090-1 §5 defines its minimum required elements. FPC is not the same as ISO 9001 certification (though ISO 9001 may satisfy some elements) — it is specifically focused on the product characteristics and processes defined in EN 1090-1 and EN 1090-2.

4.1 Core FPC Elements (EN 1090-1 §5)

The following elements must be documented, implemented, and maintained in the FPC system:

• Raw material receipt and traceability: Incoming steel must be verified against EN 10204 material certificates (3.1 minimum for EXC2+; 3.2 for critical applications). Heat number traceability must be maintained from receipt through to final product marking.
• Welder and welding operator qualification records: Valid qualification certificates (EN ISO 9606-1 for welders, EN ISO 14732 for operators) must be on file and referenced in the FPC. Requalification dates must be tracked. The FPC certificate scope must cover all welding processes, positions, and material groups used in production.
• Welding procedure specifications (WPS) and procedure qualification records (WPQR): All production WPS must be backed by qualified WPQRs (EN ISO 15614-1). The FPC must index which WPS applies to which product type and joint configuration.
• Equipment calibration and maintenance records: Welding machines, NDT equipment, measurement tools, and gauges must be calibrated on a defined schedule with records retained in the FPC system.
• NDT personnel qualification records: Personnel performing NDT must hold valid EN ISO 9712 certifications at the required level for each method. The FPC must list qualified NDT personnel and their scope.
• Inspection and test plans (ITP): Production ITPs defining hold points, witness points, and acceptance criteria must be documented and implemented for each product type or project.
• Non-conformance and corrective action records: The FPC must include a documented NCR process. Open NCRs that have not been resolved and closed out before CE marking is applied are a direct non-conformance with EN 1090-1.
• Product marking and traceability: Finished components must be marked to allow traceability to the production records and the applicable DoP. Marking must include the CE symbol, Notified Body number, year of affixing, product type reference, and execution class.

4.2 FPC Scope and Limitations

The FPC certificate issued by the Notified Body has a defined scope — it lists the product families, execution classes, welding processes, steel grades, and component configurations that the certificate covers. Producing a component outside this scope without updating the certificate and notifying the Notified Body is a non-conformance.

Common scope limitations to check:

• Maximum steel grade covered (e.g., certificate may cover S355 but not S420 or S460)
• Welding processes listed (e.g., SMAW, FCAW, SAW — if GTAW is added to production, the certificate scope must be updated)
• Maximum plate thickness covered by qualified WPS in the FPC
• NDT methods in scope — if phased-array UT is used but the certificate only lists conventional UT, the scope is exceeded

5. The Declaration of Performance (DoP)

The Declaration of Performance is the legal document that the manufacturer must draw up and make available (in paper or electronic form) whenever a CE-marked structural component is placed on the market. It is the manufacturer's declaration that the product's performance has been assessed in accordance with EN 1090-1 and conforms to the declared values.

5.1 Mandatory DoP Content (CPR Article 6)

The DoP must contain the following information:

A DoP that is missing the Notified Body number, or that references an expired FPC certificate number, is non-compliant and the CE marking applied on that basis is invalid. Market surveillance authorities (national building product regulators) treat this as placing a non-compliant product on the market.

5.2 Essential Characteristics in Annex ZA

EN 1090-1 Annex ZA lists the essential characteristics that must be declared in the DoP. For structural steel components these include:

• Execution class (EXC1–EXC4)
• Weld quality class (ISO 5817 level corresponding to execution class)
• Reaction to fire (for components where this is relevant)
• Resistance to fatigue (for fatigue-loaded components — reference DNV-RP-C203 or EN 1993-1-9)
• Dimensional tolerances (reference EN 1090-2 tolerance class)
• Fracture toughness / impact energy (from material certificates — links to EN 10025-2 sub-grade)

Where a characteristic is "not relevant" for a given component type, the DoP must state "NPD" (No Performance Determined) for that characteristic — leaving it blank is not acceptable.

6. Notified Body Role and Surveillance Audits

Under AVCP System 2+, the Notified Body (NB) has two distinct functions: initial certification of the FPC system, and ongoing surveillance to maintain that certification.

6.1 Initial Certification

Before a manufacturer can CE-mark welded structural components, the NB must:

1. Review the manufacturer's FPC documentation against EN 1090-1 §5 requirements
2. Conduct an initial factory audit — inspecting the physical facility, equipment, records, and interviewing personnel
3. Verify that the WPS/WPQR system, welder qualifications, NDT personnel, and calibration records are in order
4. Assess the adequacy of production inspection and testing procedures
5. Issue the FPC certificate, defining its scope, validity period, and any conditions

The initial audit typically takes one to two days on-site, depending on the complexity and range of products in scope. The NB issues a certificate with a unique number that must appear on every DoP and CE marking label issued under that certificate.

6.2 Surveillance Audits

FPC certificates under System 2+ require annual surveillance audits by the NB. These audits verify that:

• The FPC system continues to be implemented as documented
• Welder and NDT qualifications are current — all certificates have been renewed before expiry
• Equipment calibration is up to date
• NCR system is functioning — non-conformances are being raised, investigated, and closed out
• Any scope changes (new processes, new product types, new steel grades) have been notified and approved
• The DoPs being issued correctly reference the current certificate number and declared characteristics

6.3 Certificate Suspension and Withdrawal

A Notified Body may suspend an FPC certificate immediately if it identifies a systematic failure in the FPC system — for example, welders being deployed outside their qualified scope, or NDT results being accepted without the required qualified personnel sign-off. Suspension means no new CE-marked products can be shipped under that certificate until the NB lifts the suspension following a corrective action review.

Withdrawal is a more serious step taken when suspension conditions are not corrected. All products CE-marked under a withdrawn certificate retain their marking (withdrawal is not retrospective unless a specific safety issue is identified), but no further products can be placed on the market under that certificate.

7. CE Marking on Offshore Projects — Practical Implications

Offshore structural fabrication for EU-registered installations (Norwegian continental shelf, Dutch sector, UK sector post-Brexit rules, Danish sector) frequently intersects with EN 1090-1 requirements in ways that differ from onshore construction. Key practical points for offshore engineers and procurement teams:

7.1 CE Marking vs DNVGL Certification

CE marking under EN 1090-1 and DNV certification (Type Approval or product certificate under DNV-ST-0378, DNV-OS-C101, etc.) are parallel, independent requirements — neither substitutes for the other. A component may need both: CE marking to be legally placed on the EU market, and DNV certification to satisfy the flag state or classification requirements of the installation.

The FPC system required by EN 1090-1 has substantial overlap with the Quality Management System requirements in DNV-ST-0378 and NORSOK M-101, but the NB audit and the DNV TPI audit are separate processes with separate scope.

7.2 Procurement and Supplier Qualification

When qualifying a fabricator for offshore structural steel supply, the CE marking audit trail should include verification of:

• Valid FPC certificate — check the NB register (NANDO database) to confirm the certificate is current and the NB is notified for the correct scope
• Certificate scope covers the specific product types, execution classes, and welding processes in your purchase order
• Most recent surveillance audit completed — request the surveillance audit report, not just the certificate
• DoP template review — verify it correctly identifies the Notified Body number, certificate number, AVCP system, and all required Annex ZA characteristics

7.3 Non-EU Fabricators Supplying the EU Market

Fabricators based outside the EU (e.g., South Korea, China, UAE) can CE-mark structural components under EN 1090-1, but must appoint an EU-based Authorised Representative whose details appear in the DoP. The FPC certificate is still issued by an EU-recognised Notified Body following the same audit process. The NANDO database confirms which NBs are recognised and for which product scopes.

8. Common Non-Conformances and Pitfalls

• DoP missing the Notified Body number or FPC certificate number — a DoP that references only the NB name without the four-digit NB identification number is non-compliant under CPR Article 6
• FPC certificate expired or surveillance audit overdue — fabricator continues issuing CE-marked products under a certificate whose surveillance is lapsed; all DoPs issued during the gap period are potentially invalid
• Welder certificates not listed in the FPC records — individual welder qualifications are in a separate folder but are not cross-referenced in the FPC document index; the NB cannot verify scope compliance
• FPC certificate scope does not cover the actual production scope — new steel grades (S420, S460) or new welding processes (FCAW-G) added to production without updating the certificate scope through the NB
• Non-conformance records open at time of CE marking — NCRs raised during fabrication that were not formally closed out before the DoP was issued; the product's conformity to declared performance is unverified
• DoP declares "NPD" for execution class rather than the actual EXC — some fabricators leave execution class as NPD to avoid commitment; this is technically permissible but creates uncertainty for the downstream designer who cannot confirm the component meets their structural specification
• CE marking label on component does not match the DoP product type code — the physical marking references a different DoP than what is supplied with the delivery, creating a traceability gap
• FPC document version control inadequate — the FPC manual distributed to production is an older version than the one submitted to the NB for certification; the implemented system differs from the certified system
• FPC system integrated with ISO 3834 quality system for fusion welding — when the EN 1090-1 FPC and the EN ISO 3834 welding quality system are maintained as a single integrated management system, surveillance audits are more efficient and the welder/WPS traceability requirements of both standards are satisfied simultaneously
• NANDO database check performed at supplier qualification stage — verifying the fabricator's NB number against the EU NANDO (New Approach Notified and Designated Organisations) database confirms the NB is properly notified for the correct CPR product scope

9. Related Standards

10. Ask Leide Navigator about EN 1090-1