The standard that makes CE marking mandatory for structural steel and aluminium: factory production control under system 2+ and welding qualified to ISO 3834.
EN 1090 is the set of technical standards that makes CE marking mandatory for structural steel and aluminium components used in construction: metal staircases, walkways, industrial buildings, canopies or any component that contributes to the stability of a structure. The legal basis is the Construction Products Regulation: until 8 January 2026 it was Regulation (EU) No 305/2011; from that date Regulation (EU) 2024/3110 applies, repealing it except for a group of articles (definitions, declaration of performance and CE marking, obligations of economic operators and harmonised standards, among others) and Annexes III and V, which remain in force until 8 January 2040 and only for products covered by harmonised standards still in effect (Article 95.8). Until the Commission replaces the corresponding harmonised technical specification, the reference standard remains EN 1090-1:2009+A1:2011, which sets the conformity assessment requirements for structural components.
CE marking under EN 1090-1 is obtained through assessment and verification of constancy of performance (AVCP) system 2+. Under this system, the manufacturer runs and documents factory production control (FPC), tests the samples taken in the factory according to the test plan and prepares the technical documentation; a notified body carries out an initial inspection of the factory and the FPC, then maintains continued surveillance through periodic assessments. The notified body certifies the FPC, not each part manufactured, which is why it must be well documented and run consistently, not just on audit day. Summum Calidad supports the implementation of the FPC and the preparation for the audit; the certificate is issued by the notified body the manufacturer chooses.
Only EN 1090-1 is harmonised under the Construction Products Regulation. EN 1090-2 (steel structures) and EN 1090-3 (aluminium structures) are not harmonised standards in themselves, but EN 1090-1 refers to them to set the technical execution requirements, and the notified body's certificate must state expressly which part applies and which execution class (EXC1 to EXC4) it covers. The execution class determines, among other things, the level of welding quality required under ISO 3834, which is why a large part of implementing EN 1090 is, in practice, putting the welding quality system in order.
ISO 3834 sets out three levels of requirement, comprehensive (part 2), standard (part 3) and elementary (part 4), depending on the complexity and the structural responsibility of what is manufactured. The system rests on three elements that must be resolved before the audit: welders qualified under ISO 9606-1, welding procedures (WPS) qualified under ISO 15614-1, and a welding coordinator qualified under ISO 14731 with genuine authority over the process, not just on paper. Factory production control can be built on the basis of an existing ISO 3834 or ISO 9001 system, but in either case it must be specifically adapted to the requirements of EN 1090-1.
In Spain, anyone who manufactures structural steel components and places them on the market without CE marking breaches the Construction Products Regulation, regardless of company size. It is common for metalwork and boilermaking workshops that have worked well technically for years not to have sorted out CE marking because no client ever required it; the problem appears when they enter a public tender or the supply chain of a large contractor, where the EN 1090 certificate is a condition of entry. It should be distinguished from the general CE marking regime (machinery, low voltage, pressure equipment), which Summum Consultoría manages: EN 1090 has its own regulation and its own harmonised standard, and it is Summum Calidad that supports it from start to finish.
The execution class (EXC) is the variable that sets how much control a specific project requires. It is assigned by the structure's design engineer, normally following Eurocode 3 and its National Annex, and it determines the level of welding quality, the qualification required of personnel and the scope of inspections. It is not a manufacturer's choice: it follows from the use, the consequences of failure and the complexity of execution of the structure.
| Class | Typical structure type | Welding quality level (ISO 3834) |
|---|---|---|
| EXC1 | Low-responsibility static structures: light supports, secondary elements with no significant risk in the event of failure | ISO 3834-4 (elementary) |
| EXC2 | Typical industrial and commercial building structures: warehouses, mezzanines, staircases and walkways for general use | ISO 3834-3 (standard) |
| EXC3 | Structures with greater consequences of failure or subject to fatigue: bridges, long-span structures, dynamic elements | ISO 3834-2 (comprehensive) |
| EXC4 | Structures with very severe consequences in the event of failure, outside typical conventional construction use | ISO 3834-2 (comprehensive), with additional execution requirements |
Most structural steel workshops working for industrial and commercial buildings in Spain sit within EXC2. Moving up to EXC3 is not just a paperwork change: it requires welding procedures qualified by testing (ISO 15614-1) instead of pre-qualified procedures, and often additional non-destructive testing inspection.
The notified body does not certify a single part: it certifies that the factory production control system runs consistently. That means that before the initial audit there is a block of documentation that must exist, be up to date and actually be used, not just filed away for visit day.
| Document | What it does |
|---|---|
| FPC manual or procedure | Describes how the manufacturing process is controlled end to end and who is responsible for each check |
| Welding procedure specifications (WPS) and their qualification records (WPQR) | Show that each welding procedure used has been tested under ISO 15614-1 |
| Welder qualification certificates | Confirm that each welder is qualified under ISO 9606-1 for the process, position and material they work with |
| Welding coordinator record | Identifies the person qualified under ISO 14731 with genuine authority over welding |
| Raw material control and traceability | Material certificates (type 3.1 under EN 10204) and traceability of each batch through to the finished structure |
| Inspection and test plan, and its records | Sets out what is inspected, by which method and to what acceptance criteria, and records each check carried out |
The notified body's initial audit reviews this documentation and, from there, carries out periodic surveillance inspections to check the system stays alive. An FPC that exists only on paper for audit day is the most common cause of non-conformity in workshops that arrive unprepared.
Meeting ISO 3834 is not a single standalone certificate: it means having three elements resolved at the same time, each audited independently. The first is the welder: each one must be qualified under ISO 9606-1 for the process, material, thickness, position and joint type they actually carry out, not in general terms. The second is the procedure: each welding procedure specification (WPS) must be backed by a qualification record (WPQR) obtained through testing under ISO 15614-1, unless the execution class allows pre-qualified procedures. The third is coordination: the company needs a person qualified under ISO 14731, with genuine authority to stop a welding process that does not comply.
In practice, it is common for a workshop to have good welders and procedures that have 'always worked' but without the documentary backing the standard requires. The implementation work consists of putting in writing and testing what the workshop already knows how to do, and closing the gaps (new processes, new materials, positions not covered) before the notified body finds them. The obligation applies to any manufacturer placing structural steel on the European market, regardless of size: metalwork shops, boilermaking workshops and structural workshops for industrial buildings fall within scope just like a large manufacturer.
We review the workshop's current position against EN 1090-1 and determine, together with the design engineer or the client, which execution class (EXC1-EXC4) applies to each type of structure you manufacture. The result is an implementation plan with gaps prioritised by risk.
We build the factory production control system and the level of ISO 3834 that matches the execution class: procedures, material control, traceability and the inspection and test plan. We coordinate the qualification of welding procedures (WPS/WPQR) under ISO 15614-1.
We organise and verify each welder's qualification under ISO 9606-1 for the processes, materials and positions they actually work in, and formalise the welding coordinator role under ISO 14731 with genuine authority over the process.
We prepare the documentation and the workshop for the notified body's initial audit (inspection of the factory and the FPC), and set up the periodic surveillance programme that keeps the certificate valid after the first audit.
The operational detail: what we deliver as part of the work and what we keep alive afterwards.
Assessment and execution class
Gap analysis against EN 1090-1 and determination of the execution class (EXC1-EXC4) applicable to each type of structure.
Factory production control (FPC) system
Manual, procedures, material control and traceability, and inspection and test plan adapted to the requirements of EN 1090-1.
ISO 3834 implementation
Welding quality system at the level required by the execution class (comprehensive, standard or elementary), with its records.
Welding procedure qualification (WPS/WPQR)
Coordination of the qualification tests under ISO 15614-1 for each welding procedure used in production.
Welder and coordinator qualification
Verification of welder qualification under ISO 9606-1 and formalisation of the welding coordinator under ISO 14731.
Support through the notified body's audit
Preparation for the initial audit and the periodic surveillance programme with the notified body the manufacturer chooses.
Normas y reglamentos verificados que aplican a este servicio: Regulation (EU) 2024/3110, Regulation (EU) No 305/2011, EN 1090-1:2009+A1:2011….
CE marking of structural steel relies on the general CE marking regime managed by Summum Consultoría and, when the workshop needs to bring order to material and order traceability, on Summum Sistemas' construction ERP.
The general CE marking regime (machinery, low voltage, pressure equipment) is managed by Summum Consultoría; EN 1090 has its own regulation and its own assessment system, specific to construction.
View service → sistemasThe traceability of materials, orders and production control required by the FPC is supported by a construction ERP once the workshop outgrows spreadsheets.
View service → calidadAssembling and welding structural steel on site or in the workshop carries its own risks, which a certifiable occupational health and safety management system covers in a coordinated way.
View service →It is mandatory for structural steel or aluminium components intended for construction that are placed on the market in the European Economic Area, regardless of the manufacturer's size. It does not cover non-structural elements or products already covered by another specific CE marking. If the part contributes to the stability of a structure, it falls within scope.
Only EN 1090-1 is harmonised under the Construction Products Regulation and it is the one that enables CE marking. EN 1090-2 sets the technical execution requirements for steel structures and EN 1090-3 for aluminium structures, including execution classes EXC1 to EXC4; EN 1090-1 refers to them to complete the technical content.
No. EN 1090 certification is issued by a notified body appointed by the European Commission. Summum Calidad supports the implementation of factory production control, the qualification of welders and procedures, and the preparation for the audit; the notified body the manufacturer chooses is the one that certifies.
The execution class is set by the structure's design engineer, normally under Eurocode 3, based on the consequences of failure and the complexity of execution. It is not chosen by the manufacturer or the consultant: it is fixed in the project or the client's technical specification, and it directly determines the required welding quality level.
It breaches the Construction Products Regulation, which can prevent the product from being placed on the market and create liability towards clients and authorities. In practice, the problem tends to surface when a public tender or a contractor requires the certificate as a condition of entry and the workshop cannot produce it.
No. EN 1090 has its own regulation, its own harmonised standard and its own assessment system, applicable only to structural construction components. CE marking for machinery, low voltage or pressure equipment is governed by different directives; Summum Consultoría supports that general regime.