EN 1090

COMPLIANCE

ELEMENTS

Mastering EN 1090 Factory Production Control (FPC): Comprehensive Audit Checklist & Compliance Guide

By PZVAR Technical Editorial Team

8 Min Read

10 Aug 2026

Key Takeaways

FPC Elements

Checklist

Roadmap

Documents

Introduction

Under the EU Construction Products Regulation (CPR), manufacturers of structural steel and aluminum components must implement an effective Factory Production Control (FPC) system to ensure products meet declared performance and CE-marking requirements. EN 1090-1 (the harmonised standard for structural steel/aluminium) mandates that fabricators establish documented procedures covering production control, welding and bolting operations, personnel qualifications, inspection/testing, traceability, nonconformity management, and record-keeping. This guide distills those FPC requirements into practical terms: we map each element to the relevant EN 1090 clause, provide a detailed audit checklist (with sample document names), list typical audit findings (nonconformities) and fixes, and outline a step-by-step path to achieving EN 1090 certification. A comparison table highlights the user-provided PZVAR checklist versus the official standard clauses, ensuring fabricators understand both industry best practice and the precise regulatory language. Sample flowcharts and record-retention tables are included for clarity.

FPC Scope & Legal Context under CPR

What is FPC? The Construction Products Regulation (EU) 305/2011 (CPR) defines factory production control as the “documented, permanent and internal control of production in a factory, in accordance with the relevant harmonised technical specifications”. In practice, FPC means manufacturers must continuously monitor and control their production processes to guarantee that every structural component consistently meets the declared performance values.

Why EN 1090 and CE Marking? EN 1090-1 is the harmonised standard for structural steel and aluminium components. Compliance with EN 1090-1 is mandatory to affix the CE mark to such components. Under the CPR, placing CE-marked structural steelwork on the EU market requires:

Performing the conformity assessment under system 2+ (for EXC1/2) or system 4 (for EXC3/4), which involves factory production control and a Notified Body assessment.
Issuing a Declaration of Performance (DoP) and affixing the CE mark, based on EN 1090-1 and any EN 1090-2/3 specifications for fabrication.
Implementing FPC such that materials, production, and inspections adhere to EN 1090 requirements.

Certification requirement: A Notified Body must audit and certify the manufacturer’s FPC system. This involves an initial inspection of the factory and FPC procedures, followed by ongoing surveillance (system 2+). RINA, a notified certification body, explicitly notes that EN 1090-1 requires a producer to establish and maintain FPC and to perform all welding to ISO 3834 standards. In practice, obtaining the EN 1090 certificate means your FPC manual, records, and processes have been deemed sufficient to guarantee consistent product quality and CE marking compliance.

Mandatory FPC Elements (EN 1090 Clauses)

EN 1090-1 Clause 6.3 specifies the FPC requirements. In summary, a compliant FPC system must include all of the following elements:

Documented FPC system (Clause 6.3.1): A written FPC manual and procedures to control production. The manufacturer must “establish, document and maintain a factory production control (FPC) system to ensure that products placed on the market conform to the declared performance characteristics”. This includes written production and inspection procedures, and records of all inspections/tests. In effect, this is a mini quality manual specific to EN 1090 (it need not be full ISO 9001, but it often mirrors many requirements).
Organizational roles and responsibilities (Clause 6.3.2): The FPC system must define the responsibility and authority of personnel managing or performing tasks affecting product conformity. Key roles include a qualified Welding Coordinator (for EXC2-4) and responsible individuals for material control, inspection, and NCR management. The manufacturer must ensure all such personnel have adequate training and competence for the work and Execution Classes (EXCs) they handle.
Equipment control (Clause 6.3.3): All measuring, testing, and production equipment that affects conformity must be controlled. EN 1090-1 requires calibration and inspection of any equipment influencing product quality. Manufacturing machinery must be maintained/inspected so that wear does not cause defects. All calibration and maintenance activities must be documented, and those records retained per the FPC procedures.
Design (if applicable, Clause 6.3.4): If the manufacturer is also responsible for structural design, the FPC system must control the design process. This includes ensuring compliance with the design brief, specifying who checks calculations, and recording design responsibilities. (Many fabricators use Eurocodes and do not perform design, in which case 6.3.4 is not used.)
Constituent products (Clause 6.3.5): Controls must ensure all raw materials and welding consumables meet EN 1090-2 (steel) or EN 1090-3 (aluminium) requirements. The FPC requires written procedures to verify incoming material and consumable certificates against specifications. Identification (heat numbers, part markings) and traceability of each batch of material and consumable must be maintained through fabrication. The EN 1090-2 standard (Technical requirements for steel structures) also adds specifics like bolting and thermal cutting controls. For example, steel filler metals must comply with EN 13479, and cut-edge quality must meet hardness/tolerance limits (clause 5.5–6.x in EN 1090-2). In practice, this means your FPC should include procedures to check and record that all steel plates, profiles, bolts, and welding rods meet the correct specs, and that each is traceable to a CoC.
Component specification & production control (Clause 6.3.6–6.3.7): For each structural component, a “Component Specification” must exist including design data, material spec, execution class, welding process, and inspection plan. EN 1090-1 requires an inspection and test plan for manufacturing. Manufacturers must verify each component against its specification – dimension checks, weld inspections, etc – and record the results. Sampling must follow EN 1090-1’s Table of performance characteristics (Annex ZA) for each execution class.
Welding and bolting operations: EN 1090-2/3 impose detailed controls on welding and mechanical fastening. Your FPC should explicitly incorporate these: approved Welding Procedure Specifications (WPS) that have been qualified (WPQR), welder/operator qualification certificates (per ISO 9606-1/14732), and clearly defined Welding Coordinator roles. Bolted connections (for specified Execution Classes) must use certified high-strength bolts, proper tensioning tools, and documentation (e.g. torque certificates). Controls for welding consumables (procurement, ID, storage, and FIFO usage) are also required. Notably, RINA’s guidance emphasizes that all welding operations must conform to ISO 3834 depending on EXC. (In practice, this often means EN ISO 3834-2 certification or equivalent comprehensive welding QA for EXC3/4 work.)
Inspections & Testing: The FPC must cover all required inspections – visual weld checks, dimensional checks, NDT (if required by design or contract), etc. Inspection results must be recorded. EN 1090-1’s Annex B (for NB use) implies the audit will verify that all inspection/test plans have been followed and documented.
Nonconformity handling (Clause 6.3.8): Written procedures must exist to identify, document, and address any nonconforming product. As soon as a defect is found, it must be recorded (Non-Conformance Report), assessed, and appropriate corrective action taken. Records of NCRs are mandatory, including any rework or concessions. The standard says “events shall be recorded as they occur and these records shall be kept for the period defined in the manufacturer’s written procedures”.
Records & Retention: All records from the above processes must be maintained. EN 1090-1 requires that inspection/test results “shall be recorded” and that actions for deviations “shall be recorded and retained for the period specified in the manufacturer’s FPC procedures”. In other words, the standard itself does not fix a specific retention period – your company must decide and document it. (By contrast, CPR mandates keeping the Declaration of Performance and technical documentation for 10 years after market placement, and EN 1090-1 requires retaining initial type test/calculation records for at least 5 years.) In practice, many fabricators keep material and FPC records for 5–10 years or longer, as appropriate for warranty and regulatory reasons.
Internal audits & management review: Although EN 1090-1 does not explicitly mandate ISO 9001-style internal audits or management reviews, a robust FPC system (often integrated into an ISO 9001 QMS) will include them. Regular internal audits help verify that FPC procedures are followed and effective, and management reviews ensure the FPC system is evaluated by top management. PZVAR’s audit guidance highlights “lack of internal audits and corrective actions” as a common finding. Best practice: schedule annual internal FPC audits and periodic management reviews to catch issues early and demonstrate control.

Practical Audit Checklist & Sample Documents

To prepare for an EN 1090 audit, use this checklist of key items (with example documents) covering all FPC aspects:

FPC Manual & Procedures: Review your FPC manual and all procedures. These should explicitly cover material control, welding operations, inspections, calibration, nonconformities, and record-keeping. (Documents: FPC Manual, Quality Plan, Control Procedures.)
Material Control Records: Verify that every incoming steel or aluminum delivery has a material certificate (EN 10204 3.1/3.2) matching the spec. Check batch/heat numbers on parts, and that they trace to certs. (Documents: Mill Test Reports, Material Inspection Records, Receiving Logs.)
Traceability: Confirm all fabricated parts are uniquely identified (e.g. with tags or paint marks). Check that tags link back to material certs and the component specification. (Documents: Traceability Sheets, Tag Registers.)
Welding Procedures: Ensure approved WPSs exist for every welding process and execution class. The WPS must reference the correct joint types, materials, thickness ranges, and preheat/interpass temps. (Documents: Welding Procedure Specifications (WPS), Welding Coordination Record.)
Welding Procedure Qualifications: Verify that each WPS has a valid WPQR (Procedure Qualification) showing successful tests (bend, tensile, etc) covering the actual material and joint. Ensure WPQR ranges match production. (Documents: WPQR Reports, PQR Test Certificates.)
Welder/Operator Qualifications: Check that welders and welding operators each have current qualification certificates for the processes and positions they use. The certificate scope (material group, position, thickness) must cover the work. (Documents: Welder Qualification Certificates, Welder List.)
Welding Coordination: Confirm that a qualified welding coordinator is assigned for EXC2 or higher. There should be documented assignment of this role and evidence of their activities (monitoring WPS compliance, reviewing records). (Documents: Welding Coordinator Credentials, Assignment Letter.)
Consumables & Bolting: Review procurement/inspection records for welding consumables (electrodes, filler) – they should comply with EN 13479 (steel) and be stored/used per FIFO. Check that high-strength bolt batches match EN 1090 spec (tensile test certs), and that torque calibration records exist if torqueing bolted joints. (Documents: Consumables Inspection Log, Bolt Certificate, Torque Wrench Calibration Log.)
Equipment Calibration Logs: Ensure calibration stickers or documents for measuring equipment (gauges, ultrasonic testers, etc). Verify maintenance logs for welding machines (if considered quality-critical). (Documents: Calibration Certificates, Maintenance Schedules.)
Inspection & Testing Records: Check that each produced component was inspected per its inspection plan. Look for completed Inspection and Test Plans (ITPs) showing dimensional checks, visual weld inspections, NDT (UT/MT/PT/RT) results, etc. (Documents: ITPs, Inspection Checklists, NDT Reports.)
Non-Conforming Product (NCR) Records: If any defects occurred, there should be Non-Conformance Reports detailing the issue, evaluation, and corrective action. Verify that these are recorded and closed. (Documents: NCR Log, Corrective Action Forms.)
Training & Competence Records: Confirm records of FPC training, welding safety, and any special training (e.g. for welding coordination) for relevant personnel. (Documents: Training Matrix, Certificates, Attendance Records.)
Internal Audits & Management Review: If implemented, review the latest internal audit reports of the FPC system and minutes of any management review meetings. (Documents: Internal Audit Reports, Audit Checklists, Meeting Minutes.)
Declaration of Performance & FPC Certificate: Check that the CE marking label and DoP template are ready. Ensure you have a copy of any existing CoC of FPC (certificate of conformity for FPC). (Documents: Draft DoP, CE mark label proof, Notified Body Certificate of FPC.)

Each item above should be supported by a document or record. For example, typical document titles might be “FPC_Manual_v2.3.pdf”, “WPS-123-EXC3.pdf”, “WPQR-EC-34.pdf”, “Welder-Cert-JohnDoe.pdf”, “ITP-ComponentX.pdf”, “NCR-0023.pdf”, “CalibrationLog_FT4.pdf”, “InternalAudit_Aug2025.pdf”, and so on. Using clear file names with dates, version numbers, and responsible person initials helps auditors easily locate and verify information.

Common Nonconformities & Corrective Actions

Auditors frequently find issues in FPC implementation. Key examples (and fixes) include:

Incomplete or outdated FPC documentation: Missing procedures, uncontrolled documents, or outdated revisions cause NCRs. Corrective Action: Review and update your FPC manual and procedures; ensure version control and approvals. Conduct a document review to fill any gaps in welding, material, inspection, or NCR procedures.
Missing welding documentation: Audits often find absent or expired WPS, WPQR, or welder certs. Corrective Action: Prepare or update all WPSs, ensure each has a valid WPQR covering actual thickness/material, and verify every welder is qualified. Keep printed certificates readily available.
Poor material traceability: Common failures include lost mill certificates, missing heat numbers, or mismarked parts. Corrective Action: Label each raw material with a unique ID as soon as it is received. Maintain a material log linking IDs to certificates. If any material lacks a certificate, request a replacement or obtain one from your supplier. Ensure tags remain attached through cutting/fabrication.
Incomplete inspection or NDT records: Simply performing inspections is not enough; auditors expect documented evidence. Missing weld inspection logs, visual/NDT reports, or calibration stickers are major findings. Corrective Action: Ensure every inspection step (e.g. weld visual check, ultrasonic test) is signed off on an ITP or checklist. Keep original NDT reports (UT/MT/PT/RT) filed. Verify calibration dates of all inspection tools and include certificates.
Non-conformity management lapses: If no NCR process or log is in place, auditors will mark this major. Corrective Action: Implement a formal NCR procedure: use NCR forms to document any defects, root causes, and fixes. Train staff to raise NCRs promptly. During audits, present closed NCRs as evidence of corrective action.
Lack of internal audits / corrective action system: Not having scheduled internal audits or a corrective action process is a recurring finding. Corrective Action: Conduct periodic self-audits of the FPC system. Record findings and corrective actions in audit reports. This shows the auditor you proactively maintain compliance.
Expired certificates: Whether it’s welder certificates, calibration tags, or the FPC certificate itself, expired documents are nonconformities. Corrective Action: Establish a master list of all certificate expiry dates and assign reminders to renew before expiration.

By addressing the above issues with clear documented fixes, manufacturers avoid delays in certification.

Step-by-Step Certification Roadmap

Use this roadmap to guide your factory from start to CE marking compliance:

Determine applicability: Confirm whether your product requires EN 1090-1 certification (based on its intended use in construction, load-bearing role, etc.). Identify the required Execution Class (EXC) (EXC1–EXC4) by consulting EN 1090-2/3 Annexes or an authority.

Gap Analysis: Compare your current FPC practices with EN 1090-1:2011 FPC requirements (Clause 6.3) and EN 1090-2 fabrication rules. Use the checklist above to identify missing elements.

Establish FPC Manual: Develop your FPC manual and written procedures. Cover all areas: material control, welding control, production processes, inspections, calibration, NCR, records, etc. Clearly define roles (e.g. assign a Welding Coordinator with EXC-appropriate qualifications).

Compile Key Documents: Create or collect all essential records: WPS/WPQR, welder quals, material certificates, inspection plans, calibration logs, NCR forms, etc. Ensure they are formatted consistently and easily retrievable.

Implement and Train: Put procedures into practice on the shop floor. Train staff on new procedures (e.g. how to fill an NCR or perform an incoming material check). Run a few production batches, executing the FPC as written.

Internal Audit/GAP Check: Before the Notified Body visit, conduct an internal audit or management review. Walk through a fabricated part from raw material to final product (as PZVAR suggests): verify traceability, WPS use, inspections, and documents for that part. Fix any issues found and document the corrective actions.

Select Notified Body: Research and contact a notified certification body (e.g. DNV, RINA, TÜV). They will register your company and schedule Stage 1 (document review) and Stage 2 (onsite audit).

Stage 1 Audit: The auditor reviews your quality documentation (FPC manual, procedures, records). Address any nonconformities from this review (often minor). Be ready to clarify responsibilities, scope, and any ambiguities in docs.

Stage 2 Audit: The auditor inspects your factory. They will tour the shop floor, interview personnel, and examine live processes against your documents. They will randomly select finished components and trace back their records (material certs, WPS used, inspection done). Nonconformities found here must be corrected before certification.

Certification: If all major issues are closed, the Notified Body issues a Certificate of Conformity of FPC (system 2+). You may then issue Declarations of Performance (DoPs) for your products and affix CE marks.

Ongoing Maintenance: After certification, maintain the FPC as implemented. Expect annual surveillance audits. Update procedures as needed for new products or EXC changes. Keep training up-to-date. Use internal audits and management reviews to continually improve the FPC system.

Following these steps ensures you build a culture of quality control that not only meets EN 1090 but also streamlines your audit experience.

PZVAR Checklist vs Official EN 1090 Clauses

Checklist Topic	PZVAR Guidance (Audit Prep)	EN 1090 Clause(s)
Applicability & Scope	“Check if EN 1090-1 applies to your product’s use, materials and market”	EN 1090-1 Clause 1 (Scope of standard for steel/al components)
Execution Class	“Choose the correct EXC (EXC1–EXC4) based on project”	EN 1090-2 §4 + Annex (defines EXC levels and requirements). Needed by EN 1090-1 Annex ZA.
FPC System (Manual)	“Set up a robust FPC covering responsibilities, production controls, inspections, records”	EN 1090-1 §6.3.1 (Establish, document and maintain FPC with written procedures)
Incoming Materials	“Verify incoming steel/al matches required grade, size, spec, with certs”	EN 1090-1 §6.3.5 (Inspections of constituent products used in manufacture); EN 1090-2 sets material standards
Material Traceability	“Track materials from certificate through to finished part”	EN 1090-1 §6.3.5 (Identification & traceability of materials)
WPS Control	“Use only approved WPS, ensure it is followed during welding”	EN 1090-2 §7.4 (Welding procedure specification requirements per ISO 15614)
WPQR Validation	“Ensure each WPS has a valid WPQR covering actual weld conditions”	EN 1090-2 §7.4.1 (Qualification of welding procedures with appropriate tests)
Welder Qualifications	“Confirm welders/operators are qualified for the work they do”	EN 1090-2 §7.5 (Welder and operator qualification requirements, e.g. ISO 9606)
Welding Coordination	“Assign qualified welding coordinators with defined roles”	EN 1090-2 §4.2 (Welding coordination tasks and qualifications for EXC2–4)
ISO 3834 Compliance	“Meet appropriate level of ISO 3834 (welding QA standard) as needed”	EN 1090-1 does not mandate ISO 3834, but notified bodies require welding to ISO 3834 (RINA: “perform all welding in conformity with ISO 3834”).
Consumables Control	“Control welding consumables: procurement, ID, storage, distribution”	EN 1090-2 §5.5 (Filler metals & fluxes must comply with EN 13479); ISO 3834 also covers consumables traceability.
Equipment Calibration	“Maintain/calibrate all production and test equipment”	EN 1090-1 §6.3.3 (Calibrate and inspect measuring/testing equipment; maintain production equipment)
Inspection & Testing	“Plan/document all required inspections (dimensions, welds, NDT)”	EN 1090-1 §6.3.6–6.3.7 (Inspection plan and ongoing conformity evaluation of components)
Nonconforming Products	“Record and fix any production issues; segregate bad parts”	EN 1090-1 §6.3.8 (Written procedures for nonconforming products; record and correct deviations)
Records & CE Marking	“Keep all necessary records and CE marking documentation (DoP, CE label)”	CPR Art. 11: DoP and technical docs must be kept 10 years; EN 1090-1: records per FPC.

Table: PZVAR’s 15-point checklist vs the specific EN 1090 clauses. PZVAR’s advice (left) comes from its blog guide, while the official requirements (right) are drawn from EN 1090-1/2 text and CPR.

FPC Flowchart (Process Overview)

flowchart: A sample FPC process flow. It shows raw materials being inspected and logged (traceability), followed by fabrication under controlled procedures, with inspections at each stage. Good parts are CE-marked and released; any issues loop back for rework. All steps are documented (records archived), and the system is reviewed continuously.

Records & Retention Periods

EN 1090 itself does not prescribe fixed retention periods for FPC records (except where noted below). In general, records must be kept “for the period specified in the manufacturer’s FPC procedures”. The table below summarizes key documents and how long to retain them:

Record / Document	Retention
Declaration of Performance (DoP) & Technical Docs	10 years after last product is placed on market (per CPR Art. 11)
Initial type test / calculation reports	≥ 5 years (per EN 1090-1 clause 6.2.8)
Inspection & Test Records, NCR logs	As per FPC manual (not specified in EN 1090); typically 5+ years
Equipment calibration & maintenance logs	As per FPC manual (not specified); typically aligned with audits
Material mill certificates (EN 10204)	As per FPC/contract (not specified); best practice ≥ 5 years
WPS/WPQR documents	As long as procedure is in use (not specified)
Welder/operator qualification certificates	While employee is in role (not specified)
Internal audit & management review records	As per company policy (not specified; often 3–5 years)

Table: Key FPC-related records and suggested retention periods. EN 1090 requires some records (e.g. type test results) to be kept for 5 years and CPR mandates 10 years for the DoP. Other retention periods are determined by each manufacturer’s procedures.

Prioritized Sources

Regulation (EU) No. 305/2011 (CPR) – Articles 2 & 11 (definitions and manufacturer obligations).

EN 1090-1:2009+A1:2011, “Execution of steel structures – Part 1” – Clause 6.3 (Factory Production Control requirements).

EN 1090-2:2008, “Execution of steel structures – Part 2” (Technical requirements for welding and bolting of steel structures).

EN ISO 3834 series, “Quality requirements for fusion welding” (as referenced by EN 1090-2 and NB guidelines).

European Commission Guidance (Construction Products Regulation Guidance).

Notified Body Guidance (RINA, DNV, etc.) – RINA: EN 1090-1 overview (FPC, ISO 3834 requirement).

PZVAR (First Welding Certification) technical blogs: “EN 1090 Certification Requirements: 15-Point Checklist”; “EN 1090 Audit Checklist: 5 Mistakes”.