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EN 10204 Type 3.2 Certification Confusion Article LR

David Thompson, Lloyd's Register Energy Senior Surveyor, Coventry, UK
Increasingly there is a need for manufacturers to prove the
materials they use in safety critical pressure equipment
applications meet the required chemical and mechanical
properties. As such, the use of the EN 10204:2004 standard
for inspection documents for metallic products has become
more widespread, beyond even the European Union. As an
independent third party, Lloyds Register is working to
educate the manufacturing community about the myths
surrounding - and inspection methods involved in - EN
10204 type 3.2 certification.
There are two types of inspection certificates listed in the EN standard:
3.1: A document issued by the manufacturer which declares that the products supplied are in compliance
with the requirements of the order and is supported by evidence of the manufacturers test results. The
document is validated by the manufacturers authorised inspection representative, independent of the
manufacturing department.
3.2: A document prepared by both the manufacturer and an independent third-party in which they declare
that the products supplied are in compliance with the requirements of the order and in which test results
are supplied.
The goal of type 3.2 certification is to independently verify material conformity across the supply chain, all the
way back to the steelmaker.

First, a bit of history

EN 10204 was first published in 1991, based on the German standard DIN 50049, Inspection documents for the
delivery of metallic products. At that time, it was aimed at steelmakers. In the years since, the supply chain for
steel has become more complex. Smaller manufacturers are using steel stockholders or stockists, as they are
the more cost-effective solution for relatively smaller orders of material certified to EN 10204.

Stockists have also become heavily involved in the supply of metal for subsea oil and gas equipment, where the
traceability and properties of metals has become a key safety concern.

Frustration in the industry

This past spring, Lloyds Register experts invited pressure equipment manufacturers and steel stockists in the
UK to a briefing about type 3.2 certification. Clients such as Alstom Power Thermal Services and Sulzer Pumps
presented their perspective of EN 10204 requirements.

One presenter expressed frustration with overseas

suppliers whose pipes and fittings fit specifications on
paper, but fail those specifications when sent to the lab.
This is due to several issues, including certifications that
were changed and some that were showing certifying
authority markings without permission. There was also
industry concern that EN 10204 is no longer applicable in
its current form, due to the need to certify complex supply
chain processing routes and complex multi-component

The goal: traceability

True type 3.2 certification involves visits to the manufacturer by the third-party surveyor for a visual examination,
sample dimensional checks, and confirmation that the material is traceable back to the ladle chemical analysis
and its properties meet specification requirements. The surveyor would also visit the test house to witness
appropriate mechanical tests.

Stockist vs. manufacturer?

Traceability and inspection requirement issues can occur at stockists. For example, if the stockist carries out
property-changing operations on either 3.1 or 3.2 certified material, the stockist is then considered a
manufacturer. That means the material can be certified/re-certified to type 3.2 .

Intent vs. in accordance

But what if the stockist is merely re-shaping the material, for example sawing down 3.1 certified stock from a
manufacturer? The standard is less clear in these instances.

Lloyds Register would not consider the stockist to be a manufacturer in this case, but could inspect the material
in the same or a similar manner and certification would use the phrase intent of 3.2. This differentiates between
true 3.2 inspection at a property-changing manufacturer and re-selling unmodified material and also complies
with EN 10204, which only specifies manufacturers.

The acceptability of meeting the intent of type 3.2 should be confirmed with the purchaser before work starts. We
have seen cases in which the end user did not accept to the intent of 3.2.

Type 3.2 myths

One of the myths that persists is that an independent thirdparty can carry out a paperwork review for type 3.2
certification at the stockist and then certify to 3.2. Lloyds
Register does not recognise this practice as it does not
verify traceability of the material, nor does it verify the

In other cases, clients have asked the test house to add

EN 10204 3.2 to its test report. This does not fit with the
standard, since the test house is not a manufacturer or an
independent third-party capable of issuing a 3.2 certificate. It also creates confusion, since clients then assume
the test house test report is all that is required for 3.2 certification.

Lloyds Register aims to guide and educate our clients regarding 3.2 certification so that industry has a
consistent approach and interpretation of the standard. This should enhance the value of EN 10204 3.2
certification as proof of effective, independent verification of material.

For more information about the briefing in the UK and to download a copy of the presentation, click here.

About the author:

David Thompson is a senior surveyor for Lloyds Register Energys Inspection Services office in Coventry. He
has been with Lloyds Register since 2008, and is a Graduate Materials Engineer and Chartered Engineer. Prior
to working for Lloyds Register, he worked at GKN for 23 years and was involved in quality control, certification,
research and development of automotive castings. You can contact him at