10/18/2017 EN 10204 Type 3.

2 Certification Confusion │ Lloyd's Register

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David Thompson, Lloyd's Register Senior Surveyor, Birmingham, 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, Lloyd’s 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 manufacturer’s test
results. The document is validated by the manufacturer’s 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, Lloyd’s 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
assemblies.

The goal: traceability

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10/18/2017 EN 10204 Type 3.2 Certification Confusion │ Lloyd's Register

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.
Lloyd’s 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 third-
party can carry out a “paperwork review” for type 3.2
certification at the stockist and then certify to 3.2. Lloyd’s
Register does not recognise this practice as it does not verify
traceability of the material, nor does it verify the properties.
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.
Lloyd’s 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.
To download our guide about Understanding EN 10204:Type 3.2 certification, click here.
About the author:
David Thompson is a senior surveyor for Lloyd’s Register's Inspection Services. He has been with
Lloyd’s Register since 2008, and is a Graduate Materials Engineer and Chartered Engineer. Prior to
working for Lloyd’s 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
david.thompson@lr.org.

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