EN 10204 inspection documents - when a 3.1 certificate is required
An inspection certificate 3.1 to EN 10204 is required where the obligation follows from a regulation covering the product: from the execution standard EN 1090-2 for CE marked steel structures, from the requirements for pressure equipment in categories II, III and IV, or from the European assessment document for load bearing components of storage racking. In other applications, including enclosures and control cabinets, metal furniture, transport packaging and ventilation ducting, no legal provision imposes the obligation and the type of inspection document remains a matter of contract between the parties.
A request for a certificate to be supplied with the material is one of the most frequently repeated purchasing conditions in steel processing. In a large share of cases it follows neither from legislation nor from the product standard, but from an internal purchasing procedure shaped historically. Distinguishing the two situations has measurable cost and logistics consequences.
Types of inspection documents
Inspection documents for metallic products are defined in EN 10204:20041. The standard distinguishes four document types, differing in who validates the results and what those results refer to.
| Document | Name | Validated by | Scope of test results |
|---|---|---|---|
| 2.1 | declaration of compliance with the order | manufacturer | no test results |
| 2.2 | test report | manufacturer | results of general internal inspection, not necessarily from the batch supplied |
| 3.1 | inspection certificate | inspection representative independent of the manufacturing department | tests on samples from the batch shipped to the customer |
| 3.2 | inspection certificate | additionally the purchaser representative or an inspector designated by regulation | as above, with dual validation |
The dividing line runs between non specific inspection, covering documents 2.1 and 2.2, and specific inspection assigned to a particular batch, covering documents 3.1 and 3.21. The standard governs only the way inspection is documented, not the requirements for the product itself2.
3.1
inspection certificate based on tests of samples from the batch shipped to the customer, validated independently of production1
2-4 weeks
typical extension of the order cycle where a 3.2 inspection certificate is required3
cat. II-IV
pressure equipment categories for which the Polish technical inspection authority indicates documentation 3.1 or 3.25
A higher grade document also has scheduling consequences. Delivery with a 3.2 inspection certificate extends the order cycle, in project practice by two to four weeks3, because testing requires the presence of the purchaser representative or an inspector designated by regulation.
Applications covered by a documentation obligation
CE marked steel structures. The execution standard EN 1090-2 requires constituent products to be supplied with inspection documents to EN 10204 and their properties to be documented in a way that allows comparison with the properties required in the specification4.
Pressure equipment. According to the guidance of the Polish Office of Technical Inspection, materials for the main pressure bearing parts of categories II, III and IV require documentation of type 3.1 or 3.2, while other parts require documentation 2.25. The pressure equipment directive also sets a threshold below which equipment is designed and manufactured in accordance with the sound engineering practice of a member state, without CE marking6.
Load bearing components of storage racking in the European assessment route. The European assessment document for steel components of pallet racking provides for incoming material inspection with documents to EN 1090-2 within factory production control7.
What these regulations have in common is the load bearing or pressure retaining function of the product, and therefore a direct link between material properties and safety in use.
Scope in which no obligation applies
The construction products regulation governs the placing on the market of a finished product covered by a harmonised standard and its declared performance, and does not address the documentation of input materials in the supply chain8.
The conclusion is relevant for purchasing planning. Where a product is not covered by a harmonised standard, by the pressure equipment directive or by another regulation addressing the input material, no legal provision requires an inspection certificate. This typically applies to enclosures and control cabinets, metal furniture, transport packaging, fit out components, metal fittings and ventilation ducting, for which the Polish technical and building regulation refers to the non combustibility of the material9. Analyses published by certification bodies indicate that a requirement for a higher grade document appears mainly where material properties are imposed by regulation, and in the remaining cases it stays a matter of contract between the parties2.
Reviewing requirements within the organisation
Assessing whether a documentation requirement is justified covers three areas.
1
Source of the requirement
Establishing whether it follows from customer requirements, from product certification, or solely from an internal procedure.
2
Scope of the requirement
In many structures the documentation applies to load bearing members, not to cladding, guards and enclosures.
3
Content of the purchasing archive
In place of the expected inspection certificates, 2.2 test reports are often kept, referring to the internal inspection of the producer rather than to the batch delivered1.
Available steel grades, coating types and formats of coils, slit strip and sheets are presented in the HEN-STOL steel sheet offer. The status of material originating from mill surplus production is discussed in the article on excess prime steel and mill overruns, and the assessment criteria for downgraded material in the article on non-prime steel sheet.
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Frequently asked questions
What is the difference between a 2.2 test report and a 3.1 inspection certificate?
A 2.2 test report is validated by the manufacturer on the basis of general internal inspection results, which need not come from the batch supplied. A 3.1 inspection certificate is issued by an inspection representative independent of the manufacturing department, and the results relate to samples taken from the specific batch delivered.
When is a 3.1 inspection certificate required by regulation?
Where a regulation addresses the input material. This covers CE marked steel structures, for which the execution standard EN 1090-2 requires inspection documents for constituent products, materials for the main pressure bearing parts of categories II, III and IV under the guidance of the Polish technical inspection authority, and load bearing components of pallet racking in the European assessment route.
Is an inspection document required for enclosures, metal furniture and packaging?
For products without a load bearing or pressure retaining function no legal provision imposes the obligation. The type of inspection document then remains a matter of contract between the parties and is often written into the purchaser internal procedure rather than into a product standard. Verifying the source of the requirement limits the cost of documentation that is not needed.
What does a 3.2 document add and how does it affect delivery time?
A 3.2 inspection certificate requires dual validation: by an inspection representative independent of production and by the purchaser representative or an inspector designated by regulation. Arranging the presence of both parties at testing extends the order cycle, in project practice by two to four weeks.
Does CE marking of a finished product require inspection certificates for the input material?
Not in every case. The construction products regulation covers the placing on the market of a finished product under a harmonised standard and its declared performance, and does not govern the documentation of input materials. The requirement for an inspection document follows from the execution standard applicable to the product, for example EN 1090-2.
Which inspection document is needed for sheet used in ventilation ducting?
The Polish technical and building regulation refers here to the non combustibility of the material, not to the type of inspection document. No legal provision therefore requires an inspection certificate, and the documentation level is set by the contract or the purchaser specification. The material standard remains galvanised sheet in grade DX51D with a Z275 coating.
Sources
- Polish Committee for Standardization, interpretation of PN-EN 10204:2006 Metallic products. Types of inspection documents
- LRQA, Understanding EN 10204 type 3.2 certification
- Projectmaterials, Mill test certificate EN 10204 3.1 vs 3.2, F. Sutera, July 2026
- ECCS, FAQ on EN 1090-2 and inspection documents for constituent products
- Office of Technical Inspection UDT, guidance on materials for pressure equipment under Directive 2014/68/EU
- Directive 2014/68/EU of the European Parliament and of the Council, Article 4(3)
- EOTA, European Assessment Document EAD 200059-00-0302
- European Commission, FAQ on Regulation 305/2011 on construction products
- Regulation of the Minister of Infrastructure on the technical conditions to be met by buildings and their location, § 267(1)