Solution: Initial Inspection EN 1090

The Legal Background – Construction Products Regulation, LE, CE Marking

What does the Construction Products Regulation (CPR) cover?

The Construction Products Regulation (EU) No. 305/2011 governs the free movement of harmonized construction products in Europe. These are construction products for which either harmonized European standards (e.g., EN 1090-1) or European Technical Approvals (ETA, e.g., for anchor bolts) exist. These construction products may only be placed on the market with the CE marking.

What is a construction product?

“The term ‘construction product’ refers to any product or kit that is manufactured and placed on the market to be permanently incorporated into construction works or parts thereof, and whose performance affects the performance of the construction work with regard to the basic requirements for construction works” (BPV Art. 2, para. 1).

What are the basic requirements for construction works?

The BPV specifies seven basic requirements in Annex 1. For EN 1090 components, the first basic requirement, “Mechanical strength and stability,” applies.

What is a construction kit?

“The term ‘construction kit’ refers to a construction product placed on the market by a single manufacturer as a set of at least two separate components that must be assembled in order to be incorporated into the structure” (BPV Art. 2, para. 2).

This is the norm in steel construction. Numerous load-bearing components such as columns, beams, braces, purlins, trusses, bolts, etc., are assembled on the construction site to form a structure—that is, a steel building, carport, railing, etc.

EN 1090 construction products can therefore be either individual components (columns, beams, etc.), kits (consisting of numerous load-bearing components), or pre-assembled subassemblies (e.g., welded subassemblies) that are manufactured at the manufacturer’s plant and then placed on the market with CE marking.

What is the purpose of the Declaration of Performance (DoP)?

The LE is a requirement of the Construction Products Regulation and serves to disclose the performance characteristics declared and thus guaranteed by the manufacturer (component properties such as execution class EXC, tolerances, materials, load-bearing capacity, corrosion protection, etc.) with regard to the essential characteristics.

For which essential characteristics must performance be declared?

The essential characteristics for which performance levels (NPD, if applicable) must be declared are specified in EN 1090-1 Table ZA.1: Tolerances for dimensions and shape, weldability/fracture toughness, load-bearing capacity, fatigue strength, fire resistance, fire behavior, release of cadmium/radioactive radiation, and durability (corrosion protection).

What responsibilities are associated with the Declaration of Performance?

By issuing the Declaration of Performance, the manufacturer assumes responsibility for the conformity of the load-bearing components with the declared performance characteristics. To ensure compliance with the declared performance characteristics, the manufacturer must implement factory production control.

How long must the Declaration of Performance be retained?

10 years from the date of placing on the market.

What is the purpose of the CE mark?

With the CE mark, the manufacturer confirms to clients, distributors, authorities, market surveillance agencies, etc., that the components conform to the declared performance. The CE marking also serves as a “passport” for the free movement of goods to all EU and EEA countries (Norway, Iceland, Liechtenstein) as well as to Switzerland.

Can an LE and a CE marking be issued for a steel building?

No, LE and CE markings can only be issued for individual components (e.g., columns, beams) or for kits (sets of load-bearing components assembled on-site) or for pre-assembled subassemblies that are produced at a manufacturer’s facility and placed on the market with the CE marking.

Where is the CE marking affixed?

The CE marking is applied to the component itself, to a label attached to it, on the packaging, or on accompanying documentation.

When is the CE marking applied?

CE marking must be applied before the product is placed on the market, i.e., no later than upon delivery of the first components.

Who is responsible for issuing the LE and for CE marking?

The manufacturer is responsible for both (BPV Art. 11).

What regulations apply to the installation of components on the construction site?

National building codes apply to the installation of CE-marked components; in Austria, this means the respective state building codes, the OIB Guideline 1, the Eurocode, and consequently EN 1090-2/3. The execution standards EN 1090-2/3 represent the state of the art and necessarily result from the application of the Eurocode. The Construction Products Regulation and EN 1090-1 are irrelevant on the construction site because the components have already been placed on the market.
In the special case where load-bearing components are fabricated directly on the construction site rather than in a workshop, they are exempt from CE marking pursuant to Article 5(b) of the Construction Products Regulation. However, they are subject to national building codes and thus, once again, to the execution standards EN 1090-2/3.

The EN 1090 family of standards

ÖNORM EN 1090-1:2012 (Procedures for demonstrating conformity for load-bearing components; harmonized standard, governing initial testing, the production control system, CE marking, etc.).
ÖNORM EN 1090-2:2012 (Technical rules for the execution of steel structures)
ÖNORM EN 1090-3:2008 (Technical rules for the execution of aluminum structures)
ÖNORM EN 1090-4:2015_Draft (Technical requirements for cold-formed steel structural elements and load-bearing components for roof, floor, ceiling, and wall applications)
ÖNORM EN 1090-5: 2014_Draft (Technical requirements for load-bearing, thin-walled, cold-formed structural elements and components made of aluminum for roof, floor, ceiling, and wall applications).
Which components fall under EN 1090-1

Which structural components fall under EN 1090-1?

Steel or aluminum components fall under EN 1090-1—and are therefore subject to CE marking—if all of the following conditions are met:

they have a load-bearing function in relation to the structure,
they are permanently installed in building or civil engineering structures,
they are not covered by their own harmonized product standards or ETAs,
they are placed on the market.

Execution Classes EXC1 – EXC4

Structural systems and components are classified into four execution classes (EXC = Execution Class) based on the potential risk in the event of failure, the type of loading (static or dynamic), and the complexity of manufacturing. The rules for classification have been adopted from the Annex to Eurocode 3 (EN 1993-1-1), because classification is closely related to design.

The execution classes EXC1 (simple) through EXC4 (complex) define the scope of design, construction, testing, and documentation requirements and thus significantly influence construction costs. Different execution classes may be applied within a single structure; for example, the main structural framework or critical welds may be classified as EXC3, while other components may be classified as EXC2.

A general classification of execution classes

EXC1: Structures primarily in the private sector, with little pedestrian traffic
EXC2: Standard steel construction, building construction up to 15 stories!
EXC3: Bridge construction, high-rise buildings, stadiums
EXC4: Large-scale structures with extreme consequences in the event of failure

Is there any guidance available for determining the execution classes?

To ensure uniform specifications, the ONR 21090:2013 standard was established in Austria. It provides guidance on determining the EXC in Austria.

Who determines the design class?

The execution class is determined by the structural engineer and, if applicable, by regulatory requirements.

An overview of the requirements of EN 1090-1

Manufacturer certification and monitoring by the notified body TÜV AUSTRIA

Manufacturer certification and ongoing monitoring

During manufacturer certification, a notified body conducts an initial assessment (initial inspection) of the operational and personnel requirements and, above all, of the manufacturer’s self-monitoring and factory production control. Continuous monitoring for the assessment and approval of the factory production control (FPC) takes place at annual intervals of 1-2-3-3… for EXC1/2 and 1-1-2-3-3… for EXC3/4.

Are suppliers also subject to EN 1090-1?

Suppliers of semi-finished products do not require certification. However, they must meet the quality requirements specified in the purchase orders regarding construction materials. It is important that all semi-finished products be delivered with proper identification (label, tag, marking) and that the material certificates comply with the harmonized standards for semi-finished products (EN 10025, EN 10210, EN 10219, EN 10088-4, EN 10088-5, etc.) bear the CE mark.

Are subcontractors also subject to EN 1090-1?

All subcontractors performing processing steps (thermal cutting, forming, welding, galvanizing, coating) must be qualified to do so. Subcontractors must comply with the requirements of the execution standards EN 1090-2/3 and are subject to the manufacturer’s quality assurance system. EN 1090 certification is not required because subcontractors do not place the components on the market themselves. However, when subcontracting welding work, it is advantageous for the quality assurance system if subcontractors are also EN 1090-1 certified.

What should be considered when subcontracting?

The manufacturer/distributor (the party affixing the CE marking) must initially assess the suitability of its subcontractors and monitor compliance with the EN 1090 requirements as part of its quality assurance system (e.g., incoming inspection, documentation review). The manufacturer must clearly specify the subcontract and communicate all requirements (e.g., complete details of the coating specification). Overall responsibility for the quality of subcontracted work always remains with the contracting company.

What must the purchasing department and the incoming goods inspection team consider regarding structural materials?

Semi-finished products must bear the CE mark if harmonized European standards exist for them. This applies, for example, to EN 10025 (sheets and sections made of unalloyed structural steels), EN 10210 (hot-formed hollow sections), EN 10219 (cold-formed, welded hollow sections), EN 10088-4 (sheet and strip of corrosion-resistant steels for construction), EN 10088-5 (bars and sections made of corrosion-resistant steels for construction), EN 15048-1 (non-preloaded fastener sets, self-tapping screws), EN 14399 (high-strength bolts), EN 13479 (welding consumables), and anchor bolts/adhesive anchors (CE marking based on an ETA approval).

Which material standards are primarily used at EXC1?

As a rule, these are semi-finished products made of unalloyed structural steel S235JR in accordance with the following harmonized standards (with CE marking on the certificate): Sections, plates, and flat steel in accordance with EN 10025-2, and cold-formed/welded shaped tubes in accordance with EN 10219 or hot-formed in accordance with EN 10210.

Three Key Roles for the WPK to Function Effectively

The person responsible for the WPK is accountable for its proper implementation. They must be familiar with the standard requirements, assign tasks within the WPK, and ensure that employees are properly qualified. He or she personally conducts inspections and tests or oversees their execution and is involved in decisions regarding defective parts. As a rule, the WPK manager also signs the declarations of performance on behalf of management.

The welding supervisor monitors the welding production process, prepares the welding procedures, and is responsible for the procedure tests. His specific duties are defined in EN ISO 14731. If companies use an external welding supervisor, a contractual agreement is required, and the external welding supervisor must maintain work records.

Welders:Only certified welders/operators may be employed within their scope of certification. Welders must have access to complete drawings containing all welding-related details and welding procedures. If welders perform visual inspections of welds as part of in-house inspection, they must have received at least internal training for this purpose (visual inspection per EN ISO 17637, evaluation of weld irregularities per EN ISO 5817) and must undergo regular continuing education.

All positions—FPC manager, SAP, and welder—may also be held by the same person, e.g., in a one-person operation.

The Initial Inspection and the Factory Production Control (FPC)

What is the purpose of the initial inspection?

For each product type, the manufacturer must first demonstrate, using a prototype, that it has suitable manufacturing facilities and processes to comply with the standard requirements and achieve the declared component properties. The initial inspection is required when introducing a new product type (new construction materials or modified manufacturing processes that affect the essential characteristics) or when switching production to a higher EXC level.

What is factory production control (FPC)?

FPC is the manufacturer’s self-monitoring of load-bearing components. FPC must cover the processes of welding, bolted connections, and corrosion protection. If the manufacturer is also jointly responsible for the structural analysis, the design process is also subject to FPC.

FPC must be implemented using a written monitoring and testing plan, and the results of the tests must be recorded in a traceable manner. The basic principles of FPC are specified in EN 1090-1, Chapter 6.3. EN 1090-1, Table 2, “Frequency of Product Inspections within the Factory Production Control,” specifies how and how often inspections are to be conducted.

What is the purpose of the factory production control (FPC)?

FPC must ensure that the components placed on the market actually possess the declared performance characteristics (component properties).

The checklist “EN 1090 – Factory Production Control (FPC)” contains important inspection points for this purpose. However, the checklist does not claim to be complete or up-to-date.

What else does FPC require in addition to ongoing production controls?

Definition of the responsibilities of personnel performing quality-related activities.
Personnel must be sufficiently qualified and receive regular training.
Quality-related manufacturing and testing equipment must be regularly inspected and maintained.
The procedure to be followed in the event of nonconforming products (defects, deviations) must be defined.

Download: TÜV AUSTRIA Certification Program “Manufacturer Approval”