CE marking and declaration of performance (DoP) under EN 1090

The declaration of performance (DoP) is the document in which the manufacturer states the performance of a steel or aluminium component. The CE marking is the label that refers to that declaration. Under the Bouwproductenverordening 305/2011 (Construction Products Regulation) , you may only apply CE marking if you have first drawn up a DoP.

Under EN 1090, you may use both only once a notified body has certified your FPC system. Bouwen met Staal describes the CE marking as a kind of passport for the construction product. The certificate gives you the right. You prepare the DoP and the CE label yourself for each delivery.

In short: certificate (one-off, from the notified body), declaration of performance (per product type or delivery, from you) and CE label (on the product or the accompanying documents, from you). The CE label always refers to a DoP.

What must a declaration of performance under EN 1090 contain?

Article 6 of the Construction Products Regulation sets out the minimum content of a DoP. Annex III provides the model. Focused on EN 1090, it looks like this:

Part of the DoP	What do you fill in for EN 1090?
Unique identification code of the declaration	Your own numbering, for example per order
Unique identification code of the product type	For example “Steel structural parts order 2026-114”
Intended use	Structural parts in buildings or civil engineering works
Name and address of the manufacturer	Your registered name and address
System of assessment and verification	System 2+
Harmonised standard	EN 1090-1:2009+A1:2011
Notified body	Name, identification number and number of the FPC certificate
Essential characteristics and performance	Including tolerances, weldability, fracture toughness, structural properties, fire behaviour and durability
Signature	Name, position, place and date

A characteristic you do not determine, you state as “no performance determined” (NPD). You must state at least one essential characteristic.

The four declaration methods in EN 1090-1

EN 1090-1 offers different ways to state the structural properties. Which one you use depends on who makes the design. The overview below is simplified.

Method	When	What is in the DoP?
Method 1	You supply parts without a structural calculation	Geometry and material properties
Method 2	You calculate the structural properties yourself, for example using the Eurocodes	For example load-bearing capacity or fire resistance
Method 3a	You make the part to the client’s design	Reference to the client’s design specification
Method 3b	You design the part yourself based on the client’s specification	Reference to your own design

Many steel contractors work with method 3a: the client’s engineer does the calculations and the steel contractor fabricates. If you do the calculations yourself, the notified body asks for your initial type calculation.

Example: CE label on an EN 1090 delivery

A fictional steel contractor delivers the rafters and columns for an industrial hall in EXC2. The CE label appears on the delivery note or in the delivery documents:


CE
1234                                   (notified body identification number)
Staalbouw Voorbeeld B.V., Industrieweg 1, 1234 AB Plaatsnaam
26                                     (year of first CE marking)
1234-CPR-0567                          (FPC certificate number)
DoP nr. SB-2026-114
EN 1090-1:2009+A1:2011
Steel structural parts for buildings, order 2026-114
Tolerances: EN 1090-2 | Weldability: S355J2 according to EN 10025-2
Fracture toughness: 27 J at -20 °C | Fire behaviour: class A1
Execution class: EXC2
Structural properties: according to client's design specification (method 3a)

All names and numbers in this example are made up. It shows which kinds of data come together. Use Annex ZA of EN 1090-1 and your notified body for the exact layout.

How do you deliver and keep the DoP?

You give the customer a copy of the DoP, on paper or electronically. A European delegated regulation also allows you to publish the DoP on a website, under conditions. Record in your FPC system which route you choose.

The Construction Products Regulation requires you to keep the technical documentation and the DoP for ten years after the product is placed on the market. Also keep the underlying records, such as material certificates and inspection reports, with the order number. That way you can show, in the event of a complaint or inspection, what your declaration is based on.

What changes with the new Construction Products Regulation?

The new Construction Products Regulation (EU) 2024/3110 applies largely from 8 January 2026. The old regulation 305/2011 has been withdrawn from that date, but a number of provisions remain in force until 8 January 2040. Harmonised standards that applied on 8 January 2026 remain valid until they are withdrawn.

For EN 1090-1 this means that for now you continue with the DoP and CE marking as described above. The new regulation introduces a combined performance and conformity declaration and a digital product passport. These only take effect once a new standard for this product family is designated under the new regulation. The European Commission keeps a transition period of at least one year after such a designation.

What does the notified body want to see for DoP and CE?

At the initial inspection and during surveillance, the auditor often asks for:

A recent DoP, with the matching CE label and the delivery documents.
The link between the declared performance and your records, such as material certificates.
A procedure for who prepares and signs the DoP.
The archive of previous declarations, including the retention period.

Common mistakes with CE marking under EN 1090

Execution class higher than the certificate. You declare EXC3, but your certificate covers only EXC2. That is an incorrect declaration. Check the execution class against your certificate.

One DoP for everything. A general declaration without a link to the delivery cannot be verified. Make declarations per product type or order.

CE marking without a valid certificate. If your certificate is suspended or has expired, you may not apply CE marking. Check the status, just as you would for a supplier certificate. For what a suspension or expired certificate means for your surveillance, read the page on certificate validity.

Only changing the delivery note. A CE logo on the delivery note without a declaration of performance behind it is not sufficient. The label always refers to a DoP.

Frequently asked questions about the declaration of performance

Do I also need CE marking for bespoke work for one project?

Article 5 of the Construction Products Regulation contains exceptions, including for products made individually and not in series for one construction work. The conditions are strict and also depend on national rules. Many clients also require CE marking regardless. Do not rely on the exception without consulting your notified body.

Must the CE label be on the steel part itself?

Not always. According to Article 9 of the Construction Products Regulation, the CE marking should in principle be on the product or on a label attached to it. If that is not possible, or not sensible given the nature of the product, it may go on the packaging or in the accompanying documents. For steel structures, you often see the latter route. Record in your FPC system where you place it and why.

May I make my own DoP template?

Yes. The model is in Annex III of the Construction Products Regulation. Many notified bodies and trade associations offer examples. Keep your template as part of your FPC documentation.