CE marking, EN 1090 and EN 10204 certificates are not the same thing

Steel buyers often see CE marking, EN 1090 and EN 10204 3.1/3.2 in the same project and assume they are three versions of the same quality certificate. They are not.

They answer different questions.

CE marking is a regulatory conformity mark

For construction products, the EU Construction Products Regulation (CPR) establishes harmonised rules for marketing construction products and the framework for declarations of performance/conformity and CE marking.

CE marking is therefore not an MTC and does not, by itself, tell a buyer the heat chemistry, yield strength or Charpy result of a particular piece of steel.

Whether a specific product requires or may carry CE marking depends on its intended use, the applicable EU legal route and the relevant harmonised technical specification. Because the CPR framework is in transition following Regulation (EU) 2024/3110, current legal/harmonised-standard status should be checked rather than inferred from an old project document.

EN 1090-1 is about structural components and kits

EN 1090-1 covers conformity assessment of structural steel and aluminium components and kits placed on the market as construction products within its scope. It works alongside the execution requirements of the wider EN 1090 series.

This is different from saying that every steel mill producing plate, beam or tube must hold “EN 1090 certification” simply to manufacture raw material.

A mill supplying a constituent steel product and a fabricator manufacturing a load-bearing structural component occupy different positions in the supply chain. The applicable product standard, CPR route, intended use and fabrication scope determine what conformity documentation is required.

EN 10204 is an inspection-document standard

EN 10204 defines inspection-document types such as 2.1, 2.2, 3.1 and 3.2 for metallic products.

A 3.1 MTC may include heat-specific chemistry and mechanical test results, but it does not establish that a fabricated structural component has been conformity-assessed under EN 1090-1. Conversely, an EN 1090/CE conformity document does not replace the material MTC when the purchase order requires specific material test evidence.

See EN 10204 certificate types 2.1, 2.2, 3.1 and 3.2.

A useful way to think about the three layers

Consider a fabricated structural member made from certified steel plate:

1. Material level: the plate may arrive with an EN 10204 3.1 certificate showing its specified material properties.
2. Fabrication/component level: the fabricator may need to operate under the applicable EN 1090 conformity/execution framework for the structural component.
3. Regulatory market level: where the CPR/harmonised route applies, the required declaration and CE marking address placing the construction product on the EU market.

Those layers can coexist. None should automatically be substituted for another.

What about pressure equipment and PED?

The EU Pressure Equipment Directive (PED) is a different regulatory framework for pressure equipment. A pipe or material certificate associated with a PED project does not thereby establish CPR/EN 1090 conformity, and EN 1090 conformity does not by itself establish PED compliance.

When a material can serve structural, pressure or other applications, the intended use and governing legislation must be identified before deciding which conformity route applies.

Common procurement mistakes

“The mill has a 3.1 certificate, so the material is CE marked.”
Not necessarily. EN 10204 and CE marking address different things.

“The mill is EN 1090 certified, therefore every steel product it sells is EN 1090 material.”
EN 1090 is not a steel grade or generic raw-material product standard.

“CE marked means 3.2 inspected.”
No. Independent inspection-document validation and EU conformity marking are separate concepts.

“A CE certificate replaces the MTC.”
Not where the order requires material-specific inspection results.

Procurement takeaway

Before asking for “CE + EN 1090 + 3.1”, identify what each requirement is intended to prove. Specify separately:

• the material product standard and grade;
• EN 10204 inspection-document type;
• fabrication/execution requirements;
• applicable conformity/CE-marking route;
• any purchaser, class or third-party inspection requirement.

This prevents suppliers from treating unrelated documents as interchangeable evidence.

References and verification sources

• European Commission — Construction Products Regulation
• DIN EN 1090-1 — Requirements for conformity assessment of structural components
• DIN EN 10204 — Metallic products: types of inspection documents