EN 1090 & CPR 2024/3110

EN 1090 COMPLIANCE IN 2026

IMPACT ON STRCTURAL STEEL

How Does EU Construction Products Regulation 2024/3110 Affect EN 1090 for Indian and Global Structural Steel Manufacturers in 2026?

By First Welding Certification Technical Editorial Team

08 Min Read

17 Sep 2026

Table Of Contents

What Steps Should Manufacturers Follow for EN 1090 Compliance Under CPR 2024/3110?

01

IDENTIFY

02

CONTROL

03

VERIFY

04

PREPARE

en 1090 certification

A structural steel manufacturer can make high-quality parts keep welders and follow the right production processes. But when the company plans to sell in the market in 2026 one question becomes more important:”Does our current EN 1090 system match the new rules from the EU Construction Products Regulation? The answer starts with knowing what EN 1090 is. Companies then need to link their production controls, welding methods, material tracking and technical records with the European rules.

This article explains how EN 1090 and Regulation (EU) 2024/3110 connect for global structural steel companies.

EN 1090 deals with how to make and check the quality of structural steel and aluminum parts.

For companies that make steel EN 1090 can involve many important steps. These include Factory Production Control (FPC) welding planning, Execution Classes, WPS, WPQR, welder testing, material tracking, checking and technical records.

Companies should know these rules before looking at the CPR updates.

If you are not familiar with EN 1090 certification first read our EN 1090 Standard: Which Companies Need It in India & International Markets in 2026 to understand the standard, its purpose and why it matters to steel companies.

The EN 1090 series has parts for different uses.

EN 1090-1 covers checking the quality of parts. EN 1090-2 sets the rules for making steel structures. EN 1090-3 is about aluminum structures.

For steel companies EN 1090-2 can affect how they build, weld, check and control their work.

Companies also need to decide on the Execution Class, like EXC1, EXC2, EXC3 or EXC4 based on the project and the rules.

Our article EN 1090 Execution Classes: Complete Guide to EXC1, EXC2, EXC3 & EXC4 explains how these classes affect the way structures are made and how quality is managed.

What Is EU Construction Products Regulation 2024/3110?

The European Union passed Regulation (EU) 2024/3110 as the updated Construction Products Regulation. This rule creates rules for selling building products in the EU and adds changes about product details, checking, eco-friendliness and digital tools. The regulation started on 7 January 2025. The full use of it began on 8 January 2026.

Companies should not think this change replaces all the old rules at once. The European Commission says that CPR 2011 and CPR 2024 will be together during the change period. Products will move into the system as the right rules become active. So companies should find out exactly which product they are making and what rules apply before changing their certification or record system.

What Changed for EN 1090 Compliance Under CPR 2024/3110 in 2026?

In the year 2026 manufacturers must review EN 1090 compliance under the Construction Products Regulation. Indian and global structural steel manufacturers must look at how their Factory Production Control, product performance information, conformity assessment, technical documentation, material traceability and CE marking fit into the changing EU rules.

Manufacturers should focus on:

  • Technical specifications
  • EN 1090 conformity assessment requirements
  • Factory Production Control (FPC)
  • Product performance information
  • Execution Class requirements
  • Conformity assessment procedures
  • Technical documentation
  • Material traceability
  • CE marking requirements
  • Environmental and sustainability information
  • Digital product information
  • Responsibilities across the supply chain

 The new regulation also sets up a framework for Digital Product Passports, for construction products. Manufacturers should organise product, production and traceability records in a format that can hold future digital information.

The European Commission keeps working on the measures needed to put CPR 2024 into practice. Manufacturers should check the EU regulatory papers and applicable technical specifications instead of only using old CPR 2011 information.

CPR 2024/3110 does not just change one EN 1090 certificate into another.

Instead companies need to look at how their product type, production steps, checking and records fit into the European rules.

1. Companies Need Good Factory Production Control

A company needs to manage production not just depend on final checks. An effective Factory Production Control (FPC) system can cover production steps checking materials welding work, checking, tools, problems and records. Companies should compare their work with the FPC rules they have written down. Read our EN 1090 Factory Production Control (FPC) article for an explanation of FPC rules and how to get ready for an audit.

2. Companies Must Choose the Right Execution Class

The Execution Class can change how much control is needed for welding, building and checking. Companies should not choose an Execution Class just because customers often ask for it. They should decide based on the project rules the structure. The standards that apply.

3. Companies Must Control Welding Procedures

Welding is another area where control is needed in building steel parts. Companies should connect their Welding Procedure Specifications (WPS) with the right Welding Procedure Qualification Records (WPQR) and trained welders. The company should also make sure that the welding during production stays within the range allowed by the procedure. Read EN 1090 WPS & WPQR Requirements: Ensuring Welding Quality and Compliance for details on this process.

What Problems Do Manufacturers Face?

Problem 1: Companies Mix Up EN 1090 With CE Marking

EN 1090 checking and CE marking are linked, but they are not the thing. Companies should first find out what product they are making and what rules apply. Then they can decide what documents and checks are needed for their product.

Problem 2: Companies Lose Track of Materials

A material certificate alone is not enough for a tracking system. Companies should connect material ID with production records checking papers and the final part whenever the rules require this. Read our EN 1090 Material Traceability & Inspection article to understand how companies can manage material ID and checking during production.

Problem 3: Companies Keep WPS Papers Without Using Them Right

A company may have WPS papers but still have a problem if workers use the wrong or outdated method. Companies should check the WPS WPQR, material range, welding method and production conditions before starting work.

Problem 4: Companies Get Documents Done Too Late

Many companies start getting papers after a European customer asks for them. Indian structural steel companies can avoid this by setting up their production controls and records before they get an export order.

What Should Indian and Global Manufacturers Check?

Companies can follow a way.

Step 1: Figure Out the Product -> Know what part is being made what it is used for the materials and the market it goes to.
Step 2: Check the Right EN 1090 Rules -> Find out if EN 1090-1 EN 1090-2 or another rule covers the product.
Step 3: Decide on the Execution Class -> Figure out the EXC level from the project and rules.
Step 4: Look at Factory Production Control ->  Check if the FPC system matches what the company actually does.
Step 5: Check Welding Controls -> Check WPS, WPQR, welding planning and welder skills. First Welding Certification Pvt Ltd provides  WPS & WPQR Certification for companies that need welding method checking.
Step 6: Check Material Papers -> Check material ID checking papers and tracking. For projects that need checks of material papers companies can also use EN 10204 Type 3.2 Certification.
Step 7: Check Welding Quality Rules -> Companies should also look at the welding quality rules that apply.

ISO 3834 can give a way to manage welding quality, including methods, trained workers, welding planning, checking and records. See EN ISO 3834 Certification if your work needs this welding quality rule.

Step 8: Check Checking and NDT Rules ->Companies should find out what checking and testing rules apply to their product and project. If the rules need trained NDT workers companies can check ISO 9712 NDT Personnel Certification.
Step 9: Check CE and Technical Papers Companies should check if their declaration, technical papers and CE marking plans match the product and the rules.

Practical EN 1090 2026 Checklist

Companies should check the following before starting a project in Europe:

  • product type
  • right EN 1090 part
  • execution class
  • factory production control
  • welding planning
  • wps
  • wpqr
  • welder qualifications
  • material ID
  • material track
  • checking and testing
  • ndt needs
  • equipment calibration
  • technical records
  • right checking path
  • right ce marking needs
  • cpr 2024/3110 change status
  • digital product needs

This list helps companies start on the right path but the rules they need depend on the product the project and the rules that apply.

Advantages and Challenges

Advantages

The new CPR system can help companies manage product details better.

Companies can use records to:

  • improve how they track products
  • organize technical info
  • make communication across the supply chain better
  • get ready for digital product details
  • show product performance more clearly
  • find missing documents earlier

Challenges

Companies also face some real challenges. They must keep up with rule changes find the path for their product update their records and understand the shift, from old rules to new ones. Indian companies also need to think about EU rules before they finish their production and export papers.

Frequently Asked Questions

Does CPR 2024/3110 replace EN 1090?

No. CPR 2024/3110 sets a regulatory framework for construction products. Manufacturers should review the specification and transition steps that apply to their specific product instead of assuming that CPR 2024 automatically replaces each EN 1090 rule.

No. Manufacturers need to check if their products are covered by the EN 1090 scope and if the market they target or the rules in that market call for a conformity assessment under the framework.

Manufacturers must set up the documents that fit their product and the chosen conformity route. These could be FPC records, welding procedures, WPQR, welder qualifications, material records, inspection reports, technical documentation and the required declaration and CE‑marking details.

CPR 2024/3110 shifts the overall regulatory framework for construction products. Manufacturers should find the product‑specific specification and the conformity route that apply before they decide on the precise CE‑marking and declaration requirements.

The updated CPR sets up a product passport system for construction products. Manufacturers should begin arranging product, performance, technical and traceability data in a digital format. The specific rules and deadlines will depend on the measures, in place and the scope of the product.

Conclusion

The 2026 EN 1090 situation makes it necessary for manufacturers to think more than about a certificate or a CE mark.

Indian and global structural steel manufacturers need to link their product scope, EN 1090 requirements, Execution Class, Factory Production Control, welding procedures, material traceability, inspection records and technical documentation with the European rules.

Regulation (EU) 2024/3110 has brought in a Construction Products Regulation and the EU is moving from the old system to the new one. Manufacturers should therefore look at the rules for their specific product instead of using old CPR details.

A real way to start is with one step by step process:

Define the product → find the right requirements → set the Execution Class → manage production → handle welding → keep track of materials → check inspections → keep technical documentation → make sure the right way to prove conformity is used.

Manufacturers that put this process into their work can build a base, for EU market rules and future digital product information.

Related Resources

EN 1090 Certification for Structural Steel Manufacturers

Does your company manufacture structural steel components for the European or international market?

Explore the First Welding Certification Pvt Ltd (PRVÁ ZVÁRAČSKÁ, a.s.) EN 1090 Certification scope and review the applicable requirements for your product and manufacturing process.

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