
Is EN 1090 required? Decide from the supplied product and market
Check structural purpose, the supplied component or kit and the applicable cited specification. Welding alone, a tender clause or an execution class does not decide the product’s legal CE route.
Identify the product before deciding an obligation
Identify what is placed on the market, by whom and for which intended use. EN 1090-1 covers conformity assessment of structural steel and aluminium components and kits within its scope; it is not a rule that every fabricated or welded metal item needs the same certificate. Examine load-bearing function and product boundaries rather than relying on the material name alone.
For an EU-market case, check the applicable cited product specification and current construction-product framework. Product families transition between the old and new CPR regimes separately; publication of a newer execution standard does not by itself change the harmonised assessment reference. Document which route actually applies before assigning declaration, CE and assessment tasks.
A decorative panel and a structural component are different cases
Conditional example: a laser-cut metal panel was described as decorative, but a revised order requires it to carry a balcony load. The earlier description and invoice cannot settle the new scope. Review the actual function, connections, drawings and supplied assembly with the responsible design and conformity specialists before treating the old evidence as applicable.
Do not simply rename the decorative panel a structural product or conclude that it has no obligations because the original order used that label. Conversely, do not apply EN 1090 to every decorative metal product without scope analysis. An item outside this scope may have other product or project requirements that must be assessed separately.
Separate legal route, contract and construction design
A contract may specify execution requirements or an execution class, but that alone does not establish the legal CE obligation. Distinguish EN 1090-1 product assessment from the steel and aluminium execution parts and from the design requirements of the particular construction work. CE does not prove suitability for every building or connection.
The manufacturer must establish its applicable product responsibilities and actual performance evidence. A body performs the assigned third-party tasks where the route requires them; Kayra can help organise the scope investigation and evidence map. Where the market, intended use or specification remains unresolved, give a reasoned open decision rather than an automatic mandatory or exempt answer.
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Share intended use, drawings, supplied scope and target market to investigate the applicable product route.