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EN 1090 certification
CE marking
Outsourcing
24 Oct 2026
EN 1090 for Outsourced Steel Fabrication: Who Is Responsible for Quality, Traceability and CE Marking?
By Editorial Team
Table Of Contents
- Why Outsourcing Matters Under EN 1090
- Can Steel Fabrication Be Outsourced?
- Manufacturer vs Subcontractor: Understanding the Responsibilities
- Which Activities May Require External Suppliers?
- How to Maintain Quality and Traceability Across Companies
- What Should Be Checked Before Selecting a Subcontractor?
- Documents to Review Before Accepting Outsourced Components
- Common Outsourcing Mistakes
- FAQ
- Related Searchs
- Conclusion
Outsourcing steel fabrication can help manufacturers increase production capacity, reduce investment in machinery and manage large structural steel projects. Many companies rely on subcontractors for cutting, drilling, welding, surface preparation, painting or the fabrication of complete structural components.
For companies supplying structural steel components to the European market, understanding the relationship between outsourced production, Factory Production Control (FPC), technical documentation and CE marking is particularly important.
A manufacturer may receive completed steel components from a subcontractor, but important questions remain. Who controls the manufacturing requirements? How are materials identified? Which welding and inspection records must be retained? How should outsourced processes be evaluated?
This article explains the key considerations for companies using subcontracted steel fabrication within an EN 1090-related manufacturing and conformity assessment arrangement.
Why Outsourcing Matters Under EN 1090
Outsourcing is common in structural steel manufacturing. A company may design a structure, purchase the raw materials and manage the customer relationship while using another factory for fabrication. The arrangement can become complicated when production activities are divided between several organisations.
For example, one supplier may cut the steel, another may perform welding, and a third may apply a protective coating. If the companies use different drawing revisions, identification methods or inspection procedures, maintaining consistent product conformity becomes more difficult.
EN 1090-1 addresses conformity assessment and Factory Production Control for structural components within its applicable scope. EN 1090-2 specifies technical execution requirements for steel structures. Manufacturers must determine which requirements apply to their products and how external production activities are controlled within their particular arrangement.
Can Steel Fabrication Be Outsourced?
Steel fabrication activities can be outsourced where the applicable regulatory, contractual and technical requirements permit the arrangement. However, the consequences depend on the role each organisation performs.
A company that supplies a complete structural component under its own name may have different responsibilities from a subcontractor that performs one manufacturing operation for another manufacturer.
The assessment should consider:
-Who is legally identified as the manufacturer of the finished component?
-Who determines and approves the applicable technical requirements?
-Which organisation controls the manufacturing process?
-How is the subcontracted activity covered by the relevant production-control arrangements?
-Which organisation retains the required technical and production records?
-What does the applicable conformity assessment and certification scope permit?
There is no universal rule that every subcontractor must hold the same certificate as the main manufacturer. Equally, there is no universal rule that a subcontractor’s existing certificate automatically makes the finished product compliant.
The applicable standard, product scope, contractual arrangement and conformity assessment requirements must be reviewed together.
Manufacturer vs Subcontractor: Understanding the Responsibilities
Consider a company supplying fabricated steel frames for an industrial building.
The company purchases the steel, manages the engineering documents and appoints another factory to weld the frames. The subcontractor completes the welding and returns the components for final inspection and delivery.
Both organisations have responsibilities within their agreed roles, but these roles should not be confused.
The main manufacturer or supplier:
Depending on the actual arrangement, its responsibilities may include:
-Defining the required product and execution specifications.
-Selecting and controlling external suppliers.
-Communicating approved drawings and technical requirements.
-Establishing suitable acceptance and verification arrangements.
-Reviewing relevant manufacturing and inspection evidence.
-Maintaining required product documentation.
-Fulfilling applicable manufacturer and conformity assessment obligations.
The subcontractor
Depending on the contract and applicable requirements, the subcontractor may need to:
-Perform the agreed manufacturing activities to the correct specifications.
-Use suitable equipment, personnel and applicable welding procedures.
-Maintain relevant production and inspection records.
-Identify and report nonconforming work.
-Preserve material and component identification where required.
-Cooperate with agreed verification, inspection and assessment activities.
These responsibilities should be established in the contract, purchase order, technical specification or other controlled documentation.
Important: A commercial agreement cannot, by itself, transfer or eliminate statutory obligations assigned to the manufacturer under applicable legislation.
Which Activities May Require External Suppliers?
Structural steel manufacturers may outsource individual processes or complete manufacturing packages.
| Outsourced activity | Key control consideration |
|---|---|
| Cutting and drilling | Approved dimensions, drawing revision and component identification |
| Welding | Applicable welding procedures, qualified personnel and execution requirements |
| Non-destructive testing | Appropriate personnel, methods, acceptance criteria and reports |
| Surface preparation | Specified preparation requirements and verification |
| Protective coating | Agreed coating specification, application controls and inspection |
| Bolting and assembly | Correct components, installation requirements and inspection |
| Material supply | Required material specifications and supporting documentation |
How to Maintain Quality and Traceability Across Companies
Traceability can become difficult when materials and components move between different factories. A steel plate may be cut at one location, welded at another and coated at a third. If identification is lost during any transfer, connecting the finished component to the relevant records may become difficult.
A practical control system should establish how information is maintained throughout the supply chain.
Before production
-Issue the applicable approved drawings and specifications.
-Define the required component identification system.
-Establish material documentation requirements.
-Agree on production checks and inspection responsibilities.
-Identify records that must be returned with the finished work.
During production
-Monitor the progress and status of outsourced work.
-Ensure relevant changes are communicated.
-Maintain identification according to applicable requirements.
-Record inspections and any nonconformities.
-Confirm that deviations are reviewed and authorised where necessary.
Before acceptance
-Verify the delivered components against the purchase order and applicable specifications.
-Review required inspection and test reports.
-Check that relevant material and production records are complete.
-Resolve discrepancies before releasing components for subsequent operations or delivery.
The extent of verification should reflect the applicable requirements and the risks associated with the outsourced activity.
What Should Be Checked Before Selecting a Subcontractor?
Choosing a subcontractor based only on price or production capacity can create significant quality risks.
Before awarding work, the purchasing or quality team should evaluate the supplier against the actual manufacturing requirements.
Technical capability
Confirm that the subcontractor has suitable machinery, production capacity, technical competence and personnel for the activities being assigned.
Welding capability
Where welding is involved, determine whether the applicable welding procedures, personnel qualifications and welding coordination arrangements are suitable for the work.
Quality control
Understand how the subcontractor controls production, inspects completed work and identifies nonconformities.
Documentation
Establish which drawings, material records, production documents and inspection reports must accompany the completed components.
Traceability
Agree on how components will be identified and how their manufacturing history will be linked to the relevant records.
Scope and certification status
Where certification or approval is required, verify its validity, scope and relevance to the proposed work. A certificate should not be assumed to cover every process, product or manufacturing location.
Documents to Review Before Accepting Outsourced Components
The required documentation will vary by project and product. Depending on the arrangement, the receiving manufacturer may need to review:
- Approved drawings and the applicable revisions.
- Purchase orders and technical specifications.
- Material inspection documents where required.
- Component identification and traceability records.
- Relevant welding procedures and qualification evidence.
- Welder or welding operator qualification records, where applicable.
- Inspection and non-destructive testing reports, where specified.
- Surface preparation and coating inspection records, where applicable.
- Records of nonconformities, repairs and approved deviations.
- Final verification records and other required delivery documentation.
A document checklist should be prepared for the actual product scope. Not every item on this list is mandatory for every component.
The manufacturer should also establish how missing, incomplete or inconsistent records will be investigated and resolved.
Common Outsourcing Mistakes
Mistake 1: Assuming the subcontractor’s certificate covers the entire product
A subcontractor’s certificate may cover a different scope, product or activity.
Better approach: Verify the exact scope and determine how the subcontracted work fits into the applicable conformity assessment arrangement.
Mistake 2: Giving the subcontractor incomplete drawings
Missing details or outdated revisions can lead to nonconforming production.
Better approach: Use controlled technical documents and communicate relevant changes promptly.
Mistake 3: Accepting components without the agreed records
A completed component may arrive without the evidence required to verify its manufacturing history.
Better approach: Define documentation and acceptance requirements before production begins.
Mistake 4: Assuming outsourcing removes manufacturer obligations
The contractual allocation of work does not automatically remove obligations that applicable legislation assigns to the manufacturer.
Better approach: Identify the legal manufacturer, the product scope and the applicable conformity assessment responsibilities before finalising the arrangement.
Frequently Asked Questions
Can an EN 1090 manufacturer outsource welding?
Outsourcing may be possible where the applicable requirements and conformity assessment arrangement permit it. The manufacturer should establish appropriate controls for the outsourced welding activity, including relevant technical requirements, personnel competence, inspection and records.v
Does every subcontractor need EN 1090 certification?
Not necessarily in every arrangement. The answer depends on the applicable requirements, the subcontracted activity, the manufacturer’s conformity assessment arrangements and any contractual or project-specific conditions. The required scope should be verified rather than assumed.
Who is responsible for CE marking when fabrication is outsourced?
The answer depends on who qualifies as the manufacturer under the applicable product legislation and conformity assessment arrangement. Outsourcing an operation does not automatically transfer the manufacturer’s legal obligations to the subcontractor.
Can a company use multiple subcontractors for one structural component?
Multiple subcontractors may be used where the arrangement is permitted and suitably controlled. The manufacturer should coordinate technical requirements, production interfaces, traceability, inspection and documentation across the relevant suppliers.
What should be done if a subcontractor cannot provide required records?
The manufacturer should identify which evidence is missing, determine whether conformity can be demonstrated through acceptable means and resolve the issue before making unsupported conformity claims or releasing the product where required evidence is outstanding.
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Conclusion
Outsourcing can help structural steel manufacturers expand capacity and access specialist production services. However, the arrangement needs clear responsibilities and suitable controls to maintain conformity.
The most effective approach is to define the manufacturer’s role, evaluate subcontractors against the actual work, communicate approved technical requirements and establish how production and inspection evidence will be retained.
Need guidance on EN 1090 certification?
First Welding Certification Pvt Ltd (PRVÁ ZVÁRAČSKÁ, a.s.) can assist you to understand the applicable welding quality requirements and prepare for the certification process.
Contact our team to discuss your manufacturing activities, welding documentation, personnel qualification records, and applicable certification requirements.