EN 1090
CE MARKING
PREPARATION GUIDE
EN 1090 CE Marking Audit: Complete Checklist, Common Non-Conformities & Preparation Guide
By PZVAR Technical Editorial Team
10 Min Read
14 Aug 2026
Table Of Contents
- Introduction
- What Is an EN 1090 CE Marking Audit?
- When Does EN 1090 Apply?
- What Does an EN 1090 Audit Examine?
- EN 1090 CE Marking Audit Whole Checklist
- Common EN 1090 Audit Non-Conformities
- EN 1090 Audit Preparation: What to Do Before the Auditor Arrives
- EN 1090 CE Marking Audit Checklist
- FAQ
- Conclusion
Key Takeaways
Documentations
Process Flow
Tips
Checklist
Introduction
For manufacturers of structural steel and aluminium components, EN 1090 CE marking requires more than simply applying the CE logo to a product.
Manufacturers need an appropriate system for controlling production and demonstrating that the declared product performance is maintained.
For products within the scope of EN 1090-1 and the applicable Construction Products Regulation (CPR) route, the certification process can involve assessment of Factory Production Control (FPC) and other relevant conformity-assessment activities.
The European Commission explains that AVCP defines how construction-product performance is assessed and how constancy of the assessment results is controlled.
An EN 1090 CE marking audit therefore examines whether the manufacturer’s documented procedures and actual production activities provide adequate control over the product.
This guide explains:
- What an EN 1090 CE marking audit involves
- What auditors typically examine
- Common EN 1090 non-conformities
- FPC audit requirements
- Welding documentation checks
- Material traceability requirements
- How to prepare for an EN 1090 audit
- A practical EN 1090 audit checklist
Important: EN 1090 applicability depends on the product, its intended use, structural function and the applicable technical/regulatory framework. The European Commission states that CE marking under EN 1090-1:2009+A1:2011 applies when the product falls within the standard’s scope, is a structural construction product within the CPR meaning, and is not covered by a more specific European product specification.
What Is an EN 1090 CE Marking Audit?
An EN 1090 CE marking audit is an assessment of whether a manufacturer has the necessary production controls and technical processes to consistently manufacture structural components in accordance with the applicable requirements.
A key part of this process is Factory Production Control (FPC).
The audit does not simply ask:
“Do you have the required documents?“
It also asks:
“Are your documented procedures actually implemented in production?”
This distinction is important.
A manufacturer may have:
- An FPC manual
- Welding procedures
- Inspection procedures
- Material certificates
- Calibration records
but still receive non-conformities if these documents are not properly implemented or controlled.
When Does EN 1090 Apply?
EN 1090-1 is relevant to the execution of structural steel and aluminium components within its scope.
The European Commission’s CPR guidance states that CE marking based on EN 1090-1:2009+A1:2011 requires, among other conditions, that the product falls within the scope of the standard and is a structural construction product intended to be permanently incorporated into construction works with a structural function.
This means manufacturers should determine applicability before beginning the certification process.
Key questions include:
- What product is being manufactured?
- Is it a structural component?
- Is it permanently incorporated into construction works?
- Is it within the scope of EN 1090-1?
- Is another specific harmonised product standard applicable?
If another specific harmonised European standard applies to the product, that standard may provide the relevant CE-marking basis instead.
What Does an EN 1090 Audit Examine?
An EN 1090 audit typically examines the manufacturer’s complete production-control system.
Important areas include:
- Factory Production Control
- Management responsibility
- Product specifications
- Material purchasing
- Material identification
- Material traceability
- Welding coordination
- Welder qualifications
- WPS and WPQR
- Welding consumables
- Manufacturing processes
- Inspection and testing
- Measuring and test equipment
- Non-conforming products
- Corrective actions
- Technical documentation
- CE marking and declaration documentation
The exact audit scope depends on the applicable requirements and certification route.
EN 1090 CE Marking Audit Checklist
1 Factory Production Control
Factory Production Control (FPC) is one of the most important areas of EN 1090 compliance.
The manufacturer should have documented production-control procedures covering relevant manufacturing activities.
Auditors may review:
- FPC manual
- Quality procedures
- Production procedures
- Inspection procedures
- Responsibility and authority
- Document control
- Records
- Non-conformity procedures
- Corrective actions
Audit question
Can the manufacturer demonstrate that its production-control system is implemented consistently? An FPC system should not exist only as a set of documents. It should be visible in actual production.
2 Management Responsibility
The auditor may examine whether responsibilities are clearly assigned.
The manufacturer should define who is responsible for:
- Quality control
- Production
- Welding coordination
- Inspection
- Material control
- Documentation
- Non-conforming products
- Corrective actions
Responsibilities should be understood by the personnel performing the work.
Common problem
A procedure may state that one person is responsible for a task, while production records show that another person performs it without documented authority or competence.
3 Material Purchasing and Control
Structural components depend heavily on the materials used.
An EN 1090 audit can therefore examine how the manufacturer controls incoming materials.
Relevant records may include:
- Purchase specifications
- Material grades
- Supplier information
- Inspection documents
- Material certificates
- Incoming inspection records
- Material identification
- Traceability records
The manufacturer should be able to demonstrate that purchased material meets the specified requirements.
4 Material Traceability
Material traceability is a major audit area. The manufacturer should have a controlled method for linking materials to the finished component where the applicable requirements call for such traceability.
For example:
Material Certificate
↓
Heat / Batch Identification
↓
Incoming Material
↓
Cutting / Processing
↓
Component
↓
Final Documentation
If traceability is lost during production, it can become difficult to demonstrate which material was used in a particular structural component.
Common non-conformities
- Missing material identification
- Illegible markings
- Uncontrolled material transfers
- Missing certificates
- Traceability broken after cutting
- Finished components cannot be linked to material records
5 Welding Coordination
Welding is one of the most important technical areas in structural steel and aluminium fabrication.
The manufacturer should have appropriate arrangements for welding coordination and supervision.
The auditor may examine:
- Welding coordinator responsibilities
- Competence records
- Welding procedures
- Welder qualifications
- Welding consumables
- Welding parameters
- Inspection records
- Welding equipment
- Welding documentation
The exact requirements depend on the applicable execution and welding quality requirements.
6 WPS and WPQR
A major area of EN 1090 audit preparation is the control of:
- WPS — Welding Procedure Specification
- WPQR — Welding Procedure Qualification Record
The manufacturer should be able to demonstrate that applicable welding procedures are qualified and controlled.
Auditors may check:
- WPS identification
- Applicable materials
- Welding process
- Joint configuration
- Welding parameters
- Thickness ranges
- Position
- Consumables
- Preheat requirements
- Interpass temperature
- Supporting WPQR
Common problem
A manufacturer may have a WPS available but cannot demonstrate that the WPS is supported by an appropriate qualification. That creates a technical documentation gap.
7 Welder Qualification
The welding personnel performing production work must have the appropriate qualification for the welding activities they undertake.
An audit may verify:
- Welder identification
- Qualification certificate
- Welding process
- Material group
- Thickness range
- Welding position
- Validity/status
- Production assignments
Practical audit check
Select several welders from current production records and trace them back to their qualification documents.
This is a useful internal audit technique because it tests whether the system actually works.
8 Welding Consumables
The manufacturer should control welding consumables appropriately.
Depending on the welding process and applicable requirements, records may include:
- Consumable specification
- Batch/lot identification
- Storage conditions
- Drying requirements
- Issue records
- Expiry information where applicable
Common issue
Consumables may be technically suitable but poorly controlled.
For example:
- Unidentified consumables
- Incorrect storage
- Missing batch information
- No controlled issue procedure
These issues can become audit findings.
9 Manufacturing Process Control
The audit should cover the actual manufacturing process.
Depending on the component, this may include:
- Cutting
- Drilling
- Forming
- Machining
- Assembly
- Welding
- Surface preparation
- Coating
Final inspection
The manufacturer should have appropriate controls to ensure that the finished product corresponds to the specified requirements.
10 Inspection and Testing
Inspection and testing should be planned and documented.
The auditor may examine:
- Inspection plans
- Inspection criteria
- Dimensional checks
- Visual inspection
- Weld inspection
- NDT records where applicable
- Final inspection
- Acceptance criteria
- Inspection reports
Records should identify:
- What was inspected
- Who performed the inspection
- When it was performed
- Applicable acceptance criteria
- Result
- Product/component identification
11 Measuring and Test Equipment
Measurement equipment used for quality-control activities should be appropriately controlled.
Examples include:
- Measuring tapes
- Vernier calipers
- Micrometers
- Welding gauges
- Temperature measuring devices
- Pressure gauges
- Electrical measuring equipment
- Other inspection equipment
Where calibration or verification is required, the manufacturer should maintain appropriate records.
Auditor may ask:
- What equipment is used?
- How is it identified?
- When was it last calibrated or verified?
- What is the acceptance criterion?
- What happens if equipment is found out of calibration?
12 Non-Conforming Products
An effective FPC system should define what happens when a product does not meet requirements.
The manufacturer should have a process for:
Identify → Segregate/Control → Evaluate → Correct → Reinspect → Release
Records may include:
- Non-conformity reports
- Rework records
- Repair records
- Reinspection results
- Final disposition
- Common weakness
Some manufacturers correct defective components but do not document the non-conformity or the corrective action.
An auditor may therefore find that the physical problem was corrected but the quality system did not demonstrate adequate control.
13 Corrective Action
If a non-conformity occurs repeatedly, the manufacturer should investigate its root cause.
A good corrective-action process should identify:
- Problem
- Root cause
- Immediate correction
- Corrective action
- Responsible person
- Completion date
- Effectiveness verification
Simply writing “operator mistake” is usually not enough for a meaningful root-cause analysis.
14 Document Control
EN 1090 certification depends on controlled technical documentation.
The manufacturer should control:
- FPC procedures
- WPS
- WPQR
- Drawings
- Inspection plans
- Material specifications
- Forms
- Records
- Certificates
- Previous document versions
- Common audit problem
An outdated WPS is still available on the production floor while a newer revision has already been approved.
This creates a document-control risk.
15 CE Marking and Declaration Documentation
The final stage is ensuring that the CE marking documentation is consistent with the actual product and certification route.
The European Commission states that CE marking for construction products indicates conformity with the product’s declared performance and that the product has been assessed according to the applicable harmonised European standard or European Technical Assessment.
Therefore, manufacturers should verify:
- Product identification
- Applicable technical specification
- Declared performance
- Assessment route
- Certificate information where applicable
- Declaration documentation
CE marking information
Common EN 1090 Audit Non-Conformities
Some recurring problem areas include:
| Audit Area | Common Non-Conformity |
|---|---|
| FPC | Procedures not implemented |
| Material Control | Missing material identification |
| Traceability | Material cannot be traced to component |
| Welding | Inadequate welding documentation |
| WPS | WPS not properly controlled |
| WPQR | Qualification does not support production |
| Welders | Qualification records incomplete |
| Consumables | Poor storage or identification |
| Inspection | Missing inspection records |
| Calibration | Equipment status not controlled |
| NCR | Non-conforming products not properly controlled |
| Corrective Action | No effective root-cause analysis |
| Documents | Obsolete procedures in use |
| CE Documentation | Inconsistencies between product and documentation |
EN 1090 Audit Preparation: What to Do Before the Auditor Arrives
A manufacturer should perform an internal pre-audit before the certification audit.
Step 1: Review the FPC System
Check whether:
- Procedures are current
- Responsibilities are defined
- Records are maintained
- Production controls are implemented
Step 2: Perform a Traceability Test
Select one finished component and ask:
- Can we trace this component back to the relevant material, production and inspection records?
If the answer is no, investigate the gap before the audit.
Step 3: Review Welding Documentation
Select current production welds and verify:
Weld → Welder → WPS → WPQR → Material → Inspection Record
This is one of the most useful practical checks.
Step 4: Check Calibration
Verify that all relevant measuring and test equipment has current calibration or verification status.
Step 5: Review Non-Conformities
Check previous NCRs and confirm:
- Corrective action completed
- Root cause identified
- Effectiveness verified
- Step 6: Check Document Revisions
Remove obsolete documents from production areas.
Step 7: Review CE Documentation
Confirm that the declaration and CE marking information correspond to the applicable certification and product.
EN 1090 CE Marking Audit Checklist
Use this checklist as a final pre-audit review.
FPC
- FPC manual is current
- Responsibilities are defined
- Production procedures are controlled
- Inspection procedures are available
- Quality records are maintained
Materials
- Approved suppliers are controlled
- Material specifications are defined
- Material certificates are available
- Incoming materials are identified
- Traceability is maintained
Welding
- Welding coordinator responsibilities are defined
- Welding personnel are qualified
- WPS documents are current
- WPQR supports applicable welding procedures
- Welding consumables are controlled
- Welding records are maintained
Production
- Drawings are controlled
- Production processes are defined
- Identification is maintained
- Inspection points are defined
- Final inspection is documented
Equipment
- Measuring equipment is identified
- Calibration/verification status is controlled
- Records are available
- Out-of-calibration equipment is addressed
Non-Conformities
- NCR procedure exists
- Non-conforming products are identified
- Rework is controlled
- Reinspection is documented
- Corrective actions are recorded
Documentation
- Documents have revision control
- Obsolete documents are removed
- Records are retained
- Technical documentation is traceable
CE Marking
- Applicable standard has been verified
- Assessment route is correct
- Certification information is current
- Declaration documentation is correct
- CE marking information is consistent
What Happens During an EN 1090 Audit?
While the exact process varies by certification body and scope, an audit commonly involves several stages.
1 Opening Meeting
The auditor discusses:
- Audit scope
- Objectives
- Production activities
- Applicable requirements
- Audit plan
2 Documentation Review
The auditor examines relevant procedures and records.
3 Production Inspection
The auditor may visit production areas and observe actual manufacturing activities.
4 Personnel Interviews
Employees may be asked questions about their responsibilities and procedures.
For example:
- “How do you identify incoming material?”
- “How do you know which WPS applies to this weld?”
- “What do you do when a component fails inspection?”
5 Record Sampling
The auditor may select samples and trace them through the production-control system.
6 Findings
Any identified non-conformities or observations are documented according to the certification body’s procedures.
7 Corrective Action
Where required, the manufacturer must address the findings within the applicable timeframe.
How to Pass an EN 1090 CE Marking Audit
The objective should not be to prepare documents only for the day of the audit.
Instead, build a system that works every day.
The strongest approach is:
Documented Procedure
↓
Employee Competence
↓
Production Implementation
↓
Inspection
↓
Records
↓
Corrective Action
↓
Continual Improvement
If the documented system and actual production process match, audit preparation becomes significantly easier.
7 Mistakes Manufacturers Should Avoid Before an EN 1090 Audit
1 Creating Documents at the Last Minute
Auditors can identify systems that exist only on paper.
2 Ignoring Material Traceability
If you cannot trace a finished component back to its material records, investigate the problem before the audit.
3 Using Outdated WPS Documents
Make sure production personnel have access only to current approved procedures.
4 Ignoring Welder Qualification Status
Review qualification records against actual production activities.
5 Missing Inspection Records
If an inspection is required, make sure the result is recorded and traceable.
6 Treating NCRs as Paperwork
A corrective action should address the underlying cause, not just the immediate defect.
7 Focusing Only on Documentation
An auditor will generally want evidence that procedures are actually implemented.
EN 1090 Audit: Documentation vs Implementation
One of the most important principles of audit preparation is:
Having a procedure is not the same as implementing the procedure.
For example:
Document says:
“All incoming materials shall be identified and checked.”
Auditor may ask:
“Show me the records for the last three material deliveries.”
Similarly:
Document says:
“Only qualified welders shall perform production welding.”
Auditor may ask:
“Show me the qualification record for the person who made this weld.”
This is why objective evidence is so important during an EN 1090 audit.
Frequently Asked Questions
What is an EN 1090 CE marking audit?
It is an assessment of whether a manufacturer has the required production-control and technical systems to consistently manufacture structural steel or aluminium components within the applicable EN 1090/CPR framework.
What is checked during an EN 1090 audit?
Typical areas include FPC, material control, traceability, welding, WPS, WPQR, welder qualifications, inspection, calibration, non-conformity control and CE-marking documentation.
Is Factory Production Control important for EN 1090?
Yes. FPC is a central part of the conformity-assessment framework for construction products. The applicable AVCP system determines how performance and constancy are assessed.
Are WPS and WPQR checked during an EN 1090 audit?
Where applicable to the manufacturing and welding scope, auditors can review welding procedures and qualification records to verify that production welding is appropriately controlled.
Is material traceability checked?
Material identification and traceability are important parts of controlling structural-component production. The exact traceability requirements depend on the applicable product and execution requirements.
What happens if an auditor finds a non-conformity?
The certification body’s process will determine how the finding is classified and what corrective action or follow-up is required. The manufacturer should identify the cause, implement appropriate corrective action and provide objective evidence where required.
How can I prepare for an EN 1090 audit?
Perform an internal pre-audit covering:
FPC → Materials → Traceability → Welding → WPS/WPQR → Inspection → Calibration → NCR → Documentation → CE Marking
Do not review documents alone. Verify that the procedures are actually being followed on the shop floor.
Conclusion
An EN 1090 CE marking audit is fundamentally about demonstrating control.
A manufacturer should be able to show a clear connection between:
Material
→ Production
→ Welding
→ Inspection
→ Traceability
→ Factory Production Control
→ Declared Performance
→ CE Marking
The most common audit weaknesses are not necessarily complicated technical failures. They are often gaps in traceability, document control, welding records, inspection evidence, calibration, FPC implementation and corrective-action management.
The best preparation is therefore a practical internal audit that tests both documentation and implementation.
If your procedures say something should happen, make sure you can demonstrate objective evidence that it actually happens.