CE Marking Of Steel Elements According To EN 1090 1 V1 CE109001

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CE marking of steel elements according to EN 1090-1
CE marking of steel elements according to EN 1090-1
Summary
1 EN 1090, CPR, CPR vs. CPD, CE marking
1.1
EN 1090
1.2
CPR
1.3
CPR vs. CPD
1.4
CE marking
1.4.1 Question:
1.4.2 Answer:
2 Position of the European Commission regarding EN 1090 standards
3 Execution classes and traceability
3.1
EN 1090
3.2
CPR
3.3
CPR vs EN 1090 regarding traceability and execution classes
3.4
A source of conflict between CPR and EN 1090
3.5
Arguments related to inspection documents
3.6
Traceability
3.7
Weldability and welding
4 Inspection documents are not quoted in Annex ZA of EN 1090-1:
5 The main issue
6 Scope of EN 1090-1
7 Scope of EN 1090-1 for steel elements
8 Companies concerned by EN 1090-1
9 Article 15 of CPR
10
Delegated acts regarding DoPs under the CPR
11
Some sensitive questions that the CE marking should clearly address
11.1 Weldability
11.2 The right references to the steel grade
11.3 Welding consumables
11.4 Aptitude to galvanizing
11.5 Aptitude to hot forming
11.6 Practical situations
12
Conclusions
13
Appendix 1, Execution classes and traceability
13.1 EN 1090
13.2 CPR
13.3 CPR vs EN 1090 regarding traceability and execution classes
14
Appendix 2 - A source of conflict between CPR and EN 1090
14.1.1
CPR, Articles 8 and 28
14.1.2
EN 1090-2, Articles 6.2, 12.2.1 and 5
15
Appendix 3 - The question of inspection documents
16
Appendix 4 - The possible use of inspection documents
16.1 Inspection documents in the frame of FPC
16.2 Inspection documents in the frame of certification
17
Appendix 5 - About the technical use of inspection documents regarding welding
17.1 Technical content
17.2 Influence on welding procedure
17.3 Improvable practices
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18
Appendix 6 - About inspection, testing and correction
19
Appendix 7 - Clause 5 of EN 1090-2
20
Appendix 8 - Weldability and welding
21
Appendix 9, Table 1 of CEN ISO/TR 15608
22
Appendix 10, Clauses of EN 1090 not in phase with CPR
22.1 Clauses of EN 1090-1 not in phase with CPR
22.2 Clauses of EN 1090-2 not in phase with CPR
22.3 What to write in EN 1090 standards?
22.4 What to do now?
22.5 Principle lack of information found in DoPs from basic steel products
23
Appendix 11 - Other important topics for constructional steels
24
Appendix 12, How to weld steels of the grades S235 and S275?
24.1 Definition of weldability
24.2 Reference technical basis for the definition of safe welding conditions
24.2.1
“Welding Steels without hydrogen cracking”
24.2.2
Approach adopted
24.2.3
Some Tables and Figures
24.3 How to weld a steel with a maximum CEV of 0,41 %?
24.4 Synthesis
25
Appendix 13 - Excerpts from “Welding Steels without hydrogen cracking”

Summary
CE marking is quite essential. It is a consequence of the declaration of performances (DoP).
The DoP may cover different variants of a reference product. Since it can be placed on an internet
site, it does not need to accompany the delivered product.
CE marking is directly linked to each delivery.
CE marking and DoP are thus linked and complementary to each other.
DoP's and CE marking are a must for eligible products and are obviously to be offered free of charge.
According to CPR, if a harmonized standard exists, the only relevant documents to check
whether a product is conforming are the DoP and the CE marking.
Inspection documents according to EN 10204 offer not only many options but also quite different sorts
of information, among others based on non-specific results (2.2), meaning that the customer receives
information that may be not strictly bound to the product he uses...
Inspection documents based on specific control (like 3.1 or 3.2) have a sound technical background;
depending on the products or the kind of production, they may be interesting, useful or necessary
(especially for large projects involving high execution classes and specific welding procedures).
According to Annex ZA of some harmonized standards that quote them (EN 10025-1), inspection
documents are considered as "commercial documents", thus documents binding only the purchaser
and the customer on contractual voluntary matters.
Therefore, in no cases, inspection documents should be imposed by a third party for CE
marking certification purposes.
The present non-harmonized EN 1090-2 does not deal with inspection documents in a manner that is
compatible with CPR. The same may be said as regards other materials standards (like EN 10025).
This is a source of confusion. This kind of situation is tackled by the European Commission in a quite
clear way (see FAQ 9 on CPR on the web):
 "What shall a manufacturer do if certain clauses in the harmonised standard are not in line with the
provisions of the Construction Products Regulation (CPR)?
 The Construction Products Regulation (CPR) is the directly applicable legislation in every EU
Member State. Therefore in such cases, of course, it is this legislation which prevails. The
consequence is that such conflicting clauses of standards cannot be applied. The CEN
Technical Committees have undertaken the work to iron out the soonest possible any such
inconsistencies in the harmonised standards but it cannot be excluded that some inconsistencies
may remain after 01/07/2013, presumably for a short time only."

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That means that these questions are to be approached and tackled in a comprehensive and flexible
way, avoiding dogmatic positions in one or the other directions but according to the basic principles of
wisdom and safety, a priority being anyway given without any compromise to the essential question of
traceability, this in a chain routing process involving cascading actors.
As regards steel elements, not only the major constructors but also any company dealing with steel
products purchased from steel producers and placing afterwards such steel elements on the market
are concerned by EN 1090-1.
Such any company who wishes to be in line with CPR and to carry out professionally should be able to
build up a “factory production control” (“FPC”) ensuring at least traceability, to be certified according to
Annex ZA of EN 1090-1:2009+A1:2011, to emit a free of charge “Declaration of performance” or “DoP”
according to that standard and to CE mark at no cost for the customer, this with the possibility to
rightly use the “NPD” option (“no performance determined, a term used if the actual characteristic has
not been tested”).
European standards ruling the qualification of welding procedures or welders are based on a rather
simple grouping of steel qualities involving for each subgroup a wide range of properties. None of
these standards refers to inspection documents according to EN 10204. This simply means that
qualified welding processes must cover a range of properties, among other the chemical contents,
whose acceptable upper values are ruled by an official generic document, namely the value listed in
the relevant product standard and not in another document of specific nature. Exceptions to that
obvious evidence could only apply when formal contractual robust documents build for given projects
an anticipated clear scope differing from that one defined by the standard. Such special situations
disclose an objective need for inspection documents of types 3.1 or 3.2.
Now for usual cases of current execution works on steel structures, the situation is as follows.
Provided the declaration of performance and the CE marking contain the necessary legal requested
information, a manufacturer operating under EN 1090 and related CE does not need further
information when he purchases steel elements either directly from the producer or from a certified
distributor.
According to Article 15 of CPR, a distributor who places his products on the market under his own
name must draw up an own declaration of performance and affix his own CE marking.

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1 EN 1090, CPR, CPR vs. CPD, CE marking
1.1

EN 1090

Annex ZA of the harmonized standard EN 1090-1:2009+A1:2011 is the text of reference for the CE
marking regarding the “Execution of steel structures and aluminium structures - Part 1: Requirements
for conformity assessment of structural components”. Since July 01, 2014, CE marking according to
EN 1090-1:2009+A1:2011 is a legal and mandatory obligation1.
Contrary to EN 1090-1, EN 1090-2:2008+A1:2011 is a non-harmonized standard. EN 1090-2 lists
technical rules. Only the technical rules of EN 1090-2 underlying the CE marking to EN 10901:2009+A1:2011 are eligible.
The other rules are simply not applicable to CE marking2.
As a typical example of that legal fact, EN 1090-2 deals with more than two kinds of tolerances:
1. “3.16.1 essential tolerance, basic limits for a geometrical tolerance necessary to satisfy the
design assumptions for structures in terms of mechanical resistance and stability”
2. “3.16.2 functional tolerance, geometrical tolerance which might be required to meet a function
other than mechanical resistance and stability, e.g. appearance or fit up”
3. “3.16.3 special tolerance, geometrical tolerance which is not covered by the tabulated types or
values of tolerances given in this European Standard, and which needs to be specified in a
particular case”
4. “3.16.4 manufacturing tolerance, permitted range in the size of a dimension of a component
resulting from component manufacture”
According to Annex ZA of EN 1090-1, only the essential tolerances are covered by CE marking:

1

See:

2

but possibly in the frame of a voluntary certification.

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Thus clearly, functional tolerances are not relevant to CE marking and have to be ignored when
CE marking is dealt with. Regarding “special” and “manufacturing” tolerances, they should be dealt
with only they are related to essential tolerances3.

1.2

CPR

Since July 01, 2013, a regulation (CPR) has repealed the directive (CPD) for the CE marking of
construction products.

1.3

CPR vs. CPD

A main difference regarding the CE marking accompanying the placing on the market is that the
“Declaration of conformity” referred to in CPD and still mentioned in section ZA.2.3 of Annex ZA of EN
1090-1:2009+A1:2011 has to be replaced by the “Declaration of performance” referred to in CPR.

1.4

CE marking

A general question that arises regarding CE marking is the following one:
 "What shall a manufacturer do if certain clauses in the harmonised standard are not in line
with the provisions of the Construction Products Regulation (CPR)?”
The position of the European Commission in this regard is approached in a document entitled:
“Frequently Asked Questions on the Construction Products Regulation (CPR)”. This document is
available on the Commission website4:

It is also reproduced in an OCAB-OCBS file5.

3

This does not mean that EN 1090-2 cannot be applied for certification purposes on a voluntary
basis, but that certainly not in the frame of legal CE marking. An auditor acting on behalf of CE
marking would thus be quite wrong in requesting the application of EN 1090-2 specifications which
rely on pure voluntary aspects.
4

https://www.google.com/url?q=http://ec.europa.eu/enterprise/sectors/construction/faq/index_en.htm&s
a=U&ei=uJUcVP69FsHlaN2YgvgL&ved=0CAYQFjAA&client=internal-udscse&usg=AFQjCNFEOegwKTamJCIR0Y3_ozKwi6pQng

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Coming back to the question mentioned here-above, the answer is quite clear:

Clearly:
1.4.1 Question:
What shall a manufacturer do if certain clauses in the harmonised standard are not in line with the
provisions of the Construction Products Regulation (CPR)?
1.4.2 Answer:
The Construction Products Regulation (CPR) is the directly applicable legislation in every EU Member
State. Therefore in such cases, of course, it is this legislation which prevails. The consequence
is that such conflicting clauses of standards cannot be applied. The CEN Technical Committees
have undertaken the work to iron out the soonest possible any such inconsistencies in the harmonised
standards but it cannot be excluded that some inconsistencies may remain after 01/07/2013,
presumably for a short time only."

2 Position of the European Commission regarding EN 1090
standards
A presentation about European Standards in terms of CPR was recently given by the
European commission6:

In one of the slides, the European Commission expresses concern about the scope of the EN 1090-1
standard which is considered not enough clear and self-supporting, this mainly because too much
reference is given to the non-harmonized EN 1090-2 in order to issue the DoP for the product:

5

OCAB-OCBS file: “From European Commission - Enterprises and Industry: Frequently Asked
Questions on the Construction Products Regulation (CPR)”
6
Presentation of Mr KATSARAKIS about European Standards in terms of CPR

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Consequently, there is a priority for the concerned Technical Committee to rapidly update EN 1090-1
together with EN 1090-2 so as to avoid once and for all these discrepancies between both these
standards and the CPR.

3 Execution classes and traceability
3.1

EN 1090

Two major concepts sustain and govern the set of EN 1090 European standards and are indeed
closely interacting together, these are the concepts of so-called “execution class” and of traceability.
According to Article 4.1.2 of EN 1090-2, four execution classes 1 to 4, denoted EXC1 to EXC4, are
given, for which requirement strictness increases from EXC1 to EXC4.
According to Article 6.3.5 of EN 1090-1, the requirements for traceability are dependent on
execution class.

3.2

CPR

CPR never quotes the topic of execution class. This does not mean that this concept is absent from
CPR principles. Indeed CPR deals among others with the concepts of “performance”, “level” and
“class”. CPR quotes three times the term “traceability”. The details are listed in Appendix 1

3.3

CPR vs EN 1090 regarding traceability and execution classes

There is not per se any conflict between CPR and EN 1090 regarding both concepts of traceability
and execution classes.
On the contrary, CPR and EN 1090 could not be in phase regarding the modalities to appraise the
questions linked to traceability and execution classes. Should a conflict exist in this regard, the legal
rule is clear: conflicting clauses of EN 1090-1 or EN 1090-2 cannot be applied.

3.4

A source of conflict between CPR and EN 1090

A source of conflict between CPR and EN 1090 could emerge from the following situation.
On the one hand, CPR states in its article 8.3 that for any construction product covered by a
harmonised standard7 the CE marking shall be the only marking which attests conformity of the
construction product with the declared performance in relation to the essential characteristics,
covered by that harmonised standard. CPR also states that the CE marking shall be made according
to one of the five systems for assessment and verification of constancy of performance of construction
products in relation to their essential characteristics set out in its Annex V (systems 1+, 1, 2+, 3 and
4).
On the other hand, EN 1090-2 makes several references to inspection documents according to EN
10204 that could attest for the conformity of the products. The details are listed in Appendix 2.

7

or by a European Technical Assessment

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Indeed, inspection documents according to EN 10204 can neither be considered as part of CE
marking nor can be systematically requested as a must by auditors who carry out the
certification of manufacturers according to Annex ZA of EN 1090-1.
The reasons for that are obvious:
 Certification against EN 1090-1 is made according to the 2+ system (certification of conformity
of the factory production control by the notified body);
 For constituents products covered by a harmonized standard, CE marking is the only way to
attest their conformity;
 Imposing inspection documents together with CE marking would simply result in a CE-certification
scheme combining the applicable 2+ system to
o Either the non-eligible 4 system (self-certification by the sole manufacturer without the
intervention of any notified body) (with inspection certificates of types 2.1, 2.2 or 3.1);
o Or a part of the non-eligible 1+ system (certification of constancy of performance of the
construction product on the basis among others of audit-testing of samples taken by the
notified product certification body at the manufacturing plant) (with inspection certificates
of type 3.2).

3.5

Arguments related to inspection documents

It may be still heard that inspection documents according to EN 10204 are a mandatory need to apply
CE marking according to EN 1090-1. The arguments underlying this standpoint are based on
traceability and weldability. These arguments are not supported by the legal facts regarding CE
marked products. This question is dealt with in details in appendixes 3 to 78 of the present document
but it is obvious that neither traceability nor weldability request inspection documents.

3.6

Traceability

Since the existence of CE marking, traceability is ensured by CE marking as far as a product falls
under a harmonized European standard. This was a fact for construction products under the CPD; this
simply remains under the CPR. The CE marking must contain all information regarding the traceability
of a product.
Should it not be the case, a complaint against that infringement has to be addressed to the competent
authority of the Member State according to the rules of CPR (see among others articles 13, 14 or 56).

3.7

Weldability and welding

As explained in details in Appendix 8, weldability and welding are ruled as far as EN 1090 is
concerned by a set of specific European standards dealing with guidance for welding (EN 1011-1,2,…), qualification of welding procedures (EN ISO 15609-1, EN ISO 15614-1, …), qualification of
welders, (EN ISO 9606-1,…) and grouping of metallic material (CEN ISO TR 15608).
On the one hand, none of these standards quotes inspection documents according to EN 10204.
On the other hand, all carbon steels with a level of yield stress up to 355 MPa are integrated in two
subgroups 1.1 and 1.2 (see Appendix 9):

EN 1011-2 defines safe and economic welding conditions without preheating levels for the prevention
of hydrogen cracking from the carbon equivalent (CE) as follows: “The most effective assurance of
avoiding hydrogen cracking is to reduce the hydrogen input to the weld metal from the welding
consumables. The benefits resulting from a growing number of possibilities where no preheat
temperature > 20 °C is required, can - as shown by examples in table C.1 - be increased by
using filler materials with lower hydrogen content.”
8

See chapters 15 to 19

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Without entering into detailed technical considerations, it is clear that it is quite feasible to weld thick
plates without preheat at carbon equivalent up to 0,43 % provided low hydrogen consumables are
used.

4 Inspection documents are not quoted in Annex ZA of EN 1090-1:

As a confirmation of this, EN 1090-1 gives an example of CE marking of a steel element, a welded
beam which may be quite comparable to a hot rolled section that would have been delivered
according to EN 10025-2 and CE marked according to EN 10025-1.
No mention at all of any inspection document appears here, although for instance weldability is
declared.
Appendix 10 lists the clauses of EN 1090-1 or EN 1090-2 that are obviously not yet in phase with CPR
(article 8.3) as far as CE marking is available for the construction products referred to.
The consequence is that such conflicting clauses of standards cannot be applied.
EN 1090 standards are thus to be corrected.
Fortunately, corrections are already found in the draft of future EN 1090-1, but the task is not yet
ended.

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5 The main issue
The main point with CE marking in line with CPR is therefore not to vainly dispute about the question
of inspection documents but
 On the one hand, to adopt robust basis for the editing of valid declarations of performances and
CE marking;
 On the other hand, to carefully define the status and the possible usefulness of inspection
documents.
Both these questions will be tackled at the end of this document. Meanwhile, it is essential to review
the scope covered by EN 1090 as regards steel components and the role to be exerted by any
company dealing with steel components even for very simple operations. This is approached in the
following chapters.

6 Scope of EN 1090-1
The scope covered by EN 1090-1:2009+A1:2011 is quite broad in so far as “This European Standard
specifies requirements for conformity assessment of performance characteristics for structural steel
and aluminium components as well as for kits placed on the market as construction products. The

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conformity assessment covers the manufacturing characteristics, and where appropriate the structural
design characteristics.”9

7 Scope of EN 1090-1 for steel elements
As far as steel is concerned, the technical rules underlying the CE marking to EN 10901:2009+A1:2011 are defined in EN 1090-2:2008+A1:2011 whose scope is also broad although clear10.
As a consequence, any operation - even as simple as cutting11 - made on a steel constituent
responding to a product standard like EN 10025-2 for instance implies that this operation be under
control. If that element is placed on the market, it must thus be CE marked according to EN 1090-1
9

The scope of EN 1090-1 is often criticised because it interferes with other product standards or with
European technical agreements. This delicate question is not concerned with the themes developed in
the present document; therefore, no specific concern about the scope is here relevant.

10

“This European Standard specifies requirements for execution of structural steelwork as structures
or as manufactured components, produced from:
 hot rolled, structural steel products up to and including grade S690;
 cold formed components and sheeting up to and including grades S700;
 hot finished and cold formed austenitic, austenitic-ferritic and ferritic stainless steel products;
 hot finished and cold formed structural hollow sections, including standard range and custommade rolled products and hollow sections manufactured by welding.
This European Standard may also be used for structural steel grades up to and including S960,
provided that conditions for execution are verified against reliability criteria and any necessary
additional requirements are specified.
This European Standard specifies requirements independent of the type and shape of the steel
structure (e.g. buildings, bridges, plated or latticed components) including structures subjected to
fatigue or seismic actions.
The requirements are expressed in terms of execution classes.
This European Standard applies to structures designed according to the relevant part of EN 1993.
This European Standard applies to structural components and sheeting as defined in EN 1993-1-3.
This European Standard applies to steel components in composite steel and concrete structures
designed according to the relevant part of EN 1994.
This European Standard may be used for structures designed according to other design rules
provided that conditions for execution comply with them and any necessary additional requirements
are specified.
This European Standard does not cover requirements for watertightness or air permeability resistance
of sheeting.”
11

According to that standard, “execution” implies “all activities performed for the physical completion of
the works, i.e. procurement, fabrication, welding, mechanical fastening, transportation, erection,
surface treatment and the inspection and documentation thereof” while “preparation” implies “all
activities performed on the constituent steel products to produce the parts ready for assembly and
inclusion in components. As relevant, this comprises e.g. identification, handling and storage,
cutting, shaping and holing”. It is said for instance that “Cutting shall be carried out in such a way
that the requirements for geometrical tolerances, maximum hardness and smoothness of free
edges as specified in this European Standard are met. NOTE Known and recognised cutting
methods are sawing, shearing, disc cutting, water jet techniques and thermal cutting… Hand thermal
cutting should be used only if it is not practical to use machine thermal cutting. Some cutting methods
can be unsuitable for components subject to fatigue. If a process does not conform, it shall not be
used until corrected and checked again. It may be used on a restricted range of constituent products
that do produce conforming results. If coated materials are to be cut, the method of cutting shall be
selected to minimize the damage on the coating. Burrs that could cause injury or prevent the proper
alignment or bedding of sections or sheeting shall be removed.”

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and no more according to EN 10025-1, this because all relevant essential characteristics are to be
certified and this with regards to the eligible topics.

8 Companies concerned by EN 1090-1
That means that not only the major constructors are concerned by EN 1090-1 but also any company
dealing with steel products purchased from steel producers and placing afterwards such steel
elements on the market.
Such any company who wishes to be in line with CPR and to carry out professionally should be able to
build up a “factory production control” (“FPC”) ensuring at least traceability, to be certified according
to Annex ZA of EN 1090-1:2009+A1:2011 and to emit a “Declaration of performance” or “DoP”
according to that standard, with possibilities to rightly use the “NPD” option (“no performance
determined, a term used if the actual characteristic has not been tested”12) when for instance not all
activities are performed on the constituent steel products to produce the parts ready for assembly and
inclusion in components. Obviously, the “NPD” option is, in the present case, in no way eligible
as regards traceability. As a consequence, such a company that ensures traceability under the cover
of a CE marking certified by a Notified Body must be able to emit any legal or commercial document in
a way that is in phase with the so consequently certified FPC according to EN 1090-1 Annex ZA.
This is understood as evident and unavoidable according to the rules presently edited and written
down in official documents by the Authorities in force (European Commission and CEN).
Therefore, distributors of steel elements are concerned by EN 1090 in so far as they install an FPC
that at least covers traceability.
The same applies to batch galvanizers who would be in a similar situation. Obviously, both distributors
and galvanizers could state that they are not concerned by EN 1090, especially the latter because
claiming they are just subcontractors never placing a product on the market. Nevertheless, any
company liable to place a product on the market and to edit DoPs concerned by EN 1090 can request
a CE certification and nobody is allowed to dispute that right.
As CE marking is scheduled to be workable in a cascading way, any company should neither
be discouraged nor be refused to play the game as far as it fits the rules.

9 Article 15 of CPR
According to Article 15 of CPR “Cases in which obligations of manufacturers apply to importers and
distributors”:
 “An importer or distributor shall be considered a manufacturer for the purposes of this Regulation
and shall be subject to the obligations of a manufacturer pursuant to Article 11, where he places a
product on the market under his name or trademark or modifies a construction product already
placed on the market in such a way that conformity with the declaration of performance may be
affected.”
A distributor that places his products on the market under his own name must respond to Article 11
and thus “shall draw up a declaration of performance in accordance with Articles 4 and 6, and affix the
CE marking in accordance with Articles 8 and 9.”

10 Delegated acts regarding DoPs under the CPR
For the purposes of achieving the objectives of the regulation, in particular removing and avoiding
restrictions on making construction products available on the market, Articles 60 to 62 of the CPR
delegate to the Commission the possibility to amend or update different matters, this till to April 24,
12

Cf. §3.2 Abbreviations in EN 1090-1:2009+A1:2011 (E) and CPR Article 6 “Content of the
declaration of performance” (f) “for the listed essential characteristics for which no performance is
declared, the letters ‘NPD’ (No Performance Determined);”

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2016. This regards among others the declaration of performance. Presently, two delegated acts have
been published in this regard:

Both these documents shall be carefully read but it is worth shortly stressing those key points:
 The model of DoP should be adapted, in order to respond to technological progress, to allow the
flexibility required by different kinds of construction products and manufacturers as well as to
simplify the declaration of performance.
 Manufacturers need further instructions for drawing up declarations of performance on
construction products in line with applicable legislation.
 The manufacturers should be allowed some flexibility for drawing up declarations of performance
as long as they provide, in a clear and coherent manner, the essential information required by
Article 6 of CPR.
 The purpose of Article 11(4) of CPR is to enable the identification and the traceability of any single
construction product by the indication, by the manufacturers, of a type, batch or serial number.
This purpose is not served by a declaration of performance, which should be subsequently used
for all products corresponding to the product-type defined in it. Therefore, the information required
13
by Article 11(4) should not be required to be contained in the declaration of performance.
 In order to enhance the efficiency and competitiveness of the European construction sector as a
whole, manufacturers providing declarations of performance wishing to benefit from the
simplification and instructions for the purposes of facilitating the provision of such declarations
should be able to do so as soon as possible,
Under given conditions, delegated act N° 574 offers a manufacturer the possibility to issue a single
declaration of performance covering different variations of a product-type.

11 Some sensitive questions that the CE marking should clearly
address
As already said above, article 8.3 of CPR states that the CE marking shall be the only marking which
attests conformity of the construction product with the declared performance in relation to the essential
characteristics. Consequently, the declaration of performance must be clear and must bring the
necessary information.
Some essential characteristics may raise sensitive questions that are approached hereunder.

13

Article 11.4: “Manufacturers shall ensure that their construction products bear a type, batch or serial
number or any other element allowing their identification, or, where the size or nature of the product
does not allow it, that the required information is provided on the packaging or in a document
accompanying the construction product.”

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11.1 Weldability
Weldability is first governed by the chemical composition of the steel but also by its manufacturing
process. That is why the materials standards distinguish between:
 steel just hot rolled (J grades);
 fine grain steel subjected to a normalizing treatment (after or during rolling) (N grades);
 steel thermomechanically treated during rolling (M grades);
 steel quenched and tempered (after or during rolling) (Q grades).
Simply speaking, welding conditions must first avoid embrittlement. This is done on basis of the
carbon equivalent (CEV) whose maximum allowable value is limited by the materials standards and
has to be declared (see for instance EN 10025 standards). On that basis, the manufacturer can
choose a safe minimum heat input for welding.
Welding conditions must also avoid excessive grain coarsening in the heat affected zone so that
maximum heat inputs should not be exceeded. Information in this regard is available in the literature
for many years. It is well-known that thermomechanical steels are more sensitive to high heat input
than just rolled steels and may suffer from softening. However, thermomechanical steels offer indeed
a lower carbon equivalent and enable to save costs in welding by reducing the necessary preheating.
This is clearly shown hereunder when comparing the maximum allowable CEV on ladle analysis for
the following grades (thickness of 25 mm):
 S355J2,
CEV ≤ 0,45 % (according to EN 10025-1 + EN 10025-2);
 S355N,
CEV ≤ 0,43 % (according to EN 10025-1 + EN 10025-3);
 S355M,
CEV ≤ 0,39 % (according to EN 10025-1 + EN 10025-4).
To provide the necessary information to the welder, the DoP should thus clearly indicate both the
maximum CEV and the rolling process applicable to the delivered steel element.

11.2 The right references to the steel grade
Many constructions are made from hot rolled non-alloy structural steels according to EN 10025-214
and this in the grades showing a level of guaranteed yield stress of either 235 or 275 MPa and no
severe requirement for impact energy, these are the grades S235JR and S275JR.
It is important also to recall that the EN 10025-2 standard includes in its definitions three ways for
producing such steel grades or three kinds of delivery conditions15, namely:
14

EN 10025-2: “Hot rolled products of structural steels - Part 2: Technical delivery conditions for nonalloy structural steels”

15

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




as-rolled delivery condition without any special rolling and/or heat treatment condition with the
abbreviated form “+AR”;
normalizing rolling, rolling process in which the final deformation is carried out in a certain
temperature range leading to a material condition equivalent to that obtained after normalizing so
that the specified values of the mechanical properties are retained even after normalizing, with the
abbreviated form “+N”;
thermomechanical rolling, rolling process in which the final deformation is carried out in a certain
temperature range leading to a material condition with certain properties which cannot be
achieved or repeated by heat treatment alone16, with the abbreviated form “+M”.

The classification and designation of steel grades is defined in chapter 4 of that standard. Key points
are as follows:
 Steel grades shall be classified as non-alloy quality steels according to EN 10020;
 Eight steel grades are specified of whom four with a required impact energy17 (Charpy V): S235,
S275, S355, S450;
 Steel grades S235 and S275 may be supplied in qualities JR, J0 and J2;
 Steel grade S355 may be supplied in qualities JR, J0, J2 and K2
 Steel grade S450 is supplied in quality J0;
 The qualities differ in specified impact energy requirements.
 The designation shall be in accordance with EN 10025-1:
o EN 10025-2
o symbol S (for structural steel)
o indication of the minimum specified yield strength (235, 275, 355, 450)
o quality designation in respect of specified impact energy values (JR, J0, J2, K2)
o if applicable, the additional symbol C for the suitability for cold flanging, cold roll forming or
cold drawing
o +AR, +N, +M according to the delivery condition.
It is thus considered that the above-mentioned should be available in the DoP.

11.3 Welding consumables
EN 13749 is a harmonized standard and CE marking of filler metals and fluxes for fusion welding of
metallic metals is mandatory since October 01, 2006:

Annex ZA of EN 13479:2004 defines:
 the attestation of conformity system: 2+;
 the essential characteristics covered by CE marking, among which elongation, tensile strength,
yield strength, impact strength and chemical composition of deposited metal.
In its introduction, EN 13479 illustrates the family of standards that it covers.

16

As written in the standard, subsequent heating above 580 °C may lower the strength

17

S185, E295, E335 and E360 without requirements for impact energy

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EN 13479 does not apply to auxiliaries like shielding gases. During the last meeting of the group of
notified bodies in Hamburg (SG17, meeting of 20140923), it was mentioned by the Chairman that
many welding consumables are not yet CE marked. It is not known why and supposed that this is not
caused by the question of the shielding gas. Manufacturers of welding consumables should be
encouraged to CE mark their eligible products.

11.4 Aptitude to galvanizing
If galvanizing is planned, suitability of the steel for hot-dip zinc-coating is important18. EN 10025
standards refer in this regard to EN ISO 1461 and EN ISO 14713 norms:
 ISO 1461, Third edition 2009-05-15 Hot dip galvanized coatings on fabricated iron and steel
articles – Specifications and test methods;
 ISO 14713-1, First edition 2009-12-15 Zinc coatings - Guidelines and recommendations for the
protection against corrosion of iron and steel in structures - Part 1: General principles of design
and corrosion resistance;
 ISO 14713-2, First edition 2009-12-15 Zinc coatings - Guidelines and recommendations for the
protection against corrosion of iron and steel in structures - Part 2: Hot dip galvanizing.
The hereunder tables are respectively extracted from ISO 14713-2 and from EN 10025-2:

18

Appendix 11 deals with the basic principles of that question.

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It comes that CATEGORY B of ISO 14713-2 fits exactly with CLASS 3 of EN 10025-2.
EN 10025-2 defines the chemical composition of a steel grade S275JR as follows:

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According to Table 6 of that standard, the maximum CEV up to 30 mm is 0,40 %. This value should be
increased 0,01 % if class 3 is adopted for suitability to galvanizing, thus CEV ≤ 0,41 %.

11.5 Aptitude to hot forming
Hot forming may be necessary to bend or to straighten. If steel has undergone some
thermomechanical rolling, it might be sensitive to softening after hot forming at temperatures
exceeding 580 °C.
The manufacturer applying EN 1090 should be aware of that.
This information is automatically available for a steel quality like S355M according to EN 10025-4 or
as S275JR+M according to EN 10025-219.

11.6 Practical situations
A practical example may be given by a steel 275 with requested impact energy of 27 J at +20 °C while
that steel should be suitable to batch galvanizing. A sound economical solution is a heat treatment
during rolling of a steel grade type S275JR with a Si content between 0,14 and 0,25 % whose
maximum allowable CEV would be 0,41 %.
As such, the information necessary to the manufacturer who applies EN 1090 must include the
suitability to batch galvanizing and the application of a heat treatment during rolling, this to avoid
problems when hot forming. Such information may easily be brought in a declaration of performance
including
 “S275 JR+M”;
 “Steel suited to hot dip galvanizing, Si content between 0,14 and 0,25 %”;
 “Weldability ensured by CEV not greater than 0,41%”.
As discussed in details in Appendix 12, safe welding conditions avoiding the risk of cold cracking may
be easily be applied with that level of carbon equivalent without preheating provided low hydrogen
consumables are used. This is illustrated in the Table hereunder:

19

It is to be noted that steel grades standardized under EN 10025-4 must show high impact energies
(CHARPY V value) at different temperatures from +20 to -20 °C (55 to 40 J for M) and not only 27 J at
a given temperature for JR, J0 and J2.

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HI (kJ/cm)
6
8
10
12
14
16
18
20
22
24
26
28
30

H2> 15
16
23
30
34
40
46
52
58
63
70
75
80
85

Weld temperature = 0 °C
Combined thickness (mm)
10 20 °C is
required, can - as shown by examples in table C.1 - be increased by using filler materials with
lower hydrogen content.”

Without entering into detailed technical considerations, it is clear that it is quite feasible to weld thick
plates without preheat at carbon equivalent up to 0,43 % provided low hydrogen consumables are
used.
Not any mention of inspection documents according to EN 10204 is referred to in EN ISO 15609-1
listing the “Specification and qualification of welding procedures for metallic materials - Welding
procedure specification - Part 1: Arc welding”.

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Not any mention of inspection documents according to EN 10204 is referred to in EN ISO 15614-1
listing the “Specification and qualification of welding procedures for metallic materials - Welding
procedure test - Part 1: Arc and gas welding of steels and arc welding of nickel and nickel alloys”.
Not any mention of inspection documents according to EN 10204 is referred to in EN ISO 9606-1
listing the rules for the “Qualification testing of welders - Fusion welding - Part 1: Steels”.
Not any mention of inspection documents according to EN 10204 is referred to in CEN ISO TR 15608
listing the “Guidelines for a metallic materials grouping system”. In this document, all steels are
organised through 11 groups altogether (see Table 1 of that technical report in Appendix 9). The
carbon steel grades covered by EN 1090 are found indeed in groups 1, 2 and partly 3 under 7
subgroups:

The main point with CE marking in line with CPR is therefore not to vainly dispute about the question
of inspection documents but
 On the one hand, to adopt robust basis for the editing of valid declarations of performances and
CE marking;
 On the other hand, to carefully define the status and the possible usefulness of inspection
documents.

21 Appendix 9, Table 1 of CEN ISO/TR 15608

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22 Appendix 10, Clauses of EN 1090 not in phase with CPR
Any clause of EN 1090-1 or EN 1090-2 quoting inspection documents as a request are obviously not
in phase with CPR (article 8.3) as far as CE marking is available for the construction products referred
to.
The consequence is that such conflicting clauses of standards cannot be applied.
Such conflicting clauses are listed hereunder.

22.1 Clauses of EN 1090-1 not in phase with CPR

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22.2 Clauses of EN 1090-2 not in phase with CPR

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22.3 What to write in EN 1090 standards?
EN 1090 standards are to be corrected. Obviously several items are addressed.
The present chapter focuses on the question of inspection documents.
First of all, a clear distinction must be made in EN 1090 standards between constituent basic
construction products covered by a harmonized standard and those not covered by a harmonized
standard.
The reason is clear.
Structural elements (steel or aluminium) made according to EN 1090 must be CE marked whatever
the kind of constituent basic construction products (CE marked or not CE marked).
For construction products covered by a harmonized standard, any reference to inspection document
must be replaced by a reference to “declaration of performance”.
For construction products not covered by a harmonized standard, any reference to inspection
document must be suppressed and replaced by a guideline stating that:

“The constituent products shall be evaluated by checking any eligible declaration of conformity
regarding these products. Such a declaration of conformity may emerge from a third party
voluntary certification or from inspection documents according to EN 10204.”

22.4 What to do now?
The conflicting clauses of EN 1090 standards quoting inspection documents as a request cannot be
applied.
These clauses of the standards must thus be understood from now on as follows:
1.

For construction products covered by a harmonized standard, the constituent products shall be
evaluated by checking their declaration of performance together with the content of the
accompanying CE marking.

2.

For construction products not covered by a harmonized standard, the constituent products shall
be evaluated by checking any eligible declaration of conformity regarding these products, like a
declaration of conformity from a third party voluntary certification or an inspection document
according to EN 10204.

3.

Construction products covered by a harmonized standard whose declaration of performance does
not yet contain all the necessary technical content should be treated as construction products not
covered by a harmonized standard.

22.5 Principle lack of information found in DoPs from basic steel products
Mainly, the following information is missing:
 Type of processing route (as hot rolling [AR], hot rolling with normalizing [N] or hot rolling with
thermomechanical treatment [M]);
 Suitability to batch galvanizing.

23 Appendix 11 - Other important topics for constructional steels
Durability is a major topic for constructional steel. The ability of a given steel grade to be batch
galvanized may be of major significance in many occasions. To our opinion, an improvement of some
declarations of performance so as to better document the risk of SANDELIN’s peak32 is necessary.
This matter is now covered by standardization and can easily be integrated in the declaration of
performances.
32

The SANDELIN’s peak is mainly linked to silicon content with possible interference with
phosphorous.

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24 Appendix 12, How to weld steels of the grades S235 and S275?
24.1 Definition of weldability
According to EN 10025-2, weldability of such grades is ruled by the chemical composition of the
products and by limitations on several elements, among others the carbon equivalent CEV.
As a result, CEV has to be limited to a maximum value of 0,41 % for S 275 steel suitable to hot
galvanizing (Si-content not greater than 0,25 %).
The welding conditions ensuring safe welds can be readily defined on such a basis.

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24.2 Reference technical basis for the definition of safe welding conditions
24.2.1 “Welding Steels without hydrogen cracking”
This is illustrated by applying the recommendations from the well-known book “Welding Steels without
hydrogen cracking”. This book is a recognized worldwide accepted reference for safe welding against
hydrogen cracking. It was published in 1973, confirmed and enlarged in 1993 and is now available in
an electronic format:

This book is shortly presented in Appendix 13. The reader who is interested in details should obviously
consult it. Some Figures and Tables are illustrated below (chapter 24.2.3)
24.2.2 Approach adopted
The approach which is adopted is summarized hereunder:
 The applicable welding conditions are defined by the heat input and the preheat temperature;
 The heat input is expressed as gross heat input for manual metal arc welding (welding process
efficiency of 80 %);
 The geometry of the weld joint is defined in terms of butt or fillet welds through the concept of
combined thickness;
 The weldability of the steel is defined by the CEV formula.
 The accuracy of the value affixed to CEV is quantified at ±0.02 %, this tolerance is included in the
welding recommendations as a margin of safety;
 Different levels for the diffusible hydrogen of the deposited metal are considered;
 The welding conditions are defined from a set of charts including heat input, combined thickness,
CEV, hydrogen level, preheat temperature;
 The minimum heat input considered by the charts is 6 kJ/cm (or 0,6 kJ/mm).
24.2.3 Some Tables and Figures

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24.3 How to weld a steel with a maximum CEV of 0,41 %?
The safe welding conditions for such a steel are summarized in the Table hereunder.
These welding conditions are given for different levels of diffusible hydrogen and for a welding
temperature of 0 °C.

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This Table lists the maximum combined thickness acceptable as a function of the heat input
depending on the hydrogen level.

HI (kJ/cm)
6
8
10
12
14
16
18
20
22
24
26
28
30

H2> 15
16
23
30
34
40
46
52
58
63
70
75
80
85

Weld temperature = 0 °C
Combined thickness (mm)
10
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