EN 10204 Type 3.

2 Certification
An increasing requirement in the industry is to provide proof that
materials meet defined chemical and mechanical properties. This has
led to the authentication of material certificate requirements under
the standard EN 10204:2004.
EN 10204:2004 has its origin in the German standard DIN 50049, which
specified certificate types. These types were adopted when EN 10204 was
first published in 1991.
The European Commission revised the standard in 2004 and simplified the
range of those certificate types. These are now:

Type 2.1: Document issued by the manufacturer, stating compliance

with the order
Type 2.2: Test report issued by the manufacturer,
Type 3.1: Inspection document endorsed by the manufacturer's
authorised representative stating compliance with the order
Type 3.2: Inspection document endorsed by the manufacturer's
authorised representative and either an inspection representative
named by the purchaser or an independent third-party inspection body

What is a true Type 3.2 certification?

An EN 10204 type 3.2 certificate declares the products or material supplied
by the manufacturer are in compliance with the requirements of the order.
According to the standard, a Type 3.2 certificate is a:
"Document prepared by both the manufacturers authorized inspection
representative, independent of the manufacturing department and either the
purchasers authorized representative or the inspector designated by the
official regulations and 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 "authorized inspection representative or the inspector

designated by the official regulations" is fulfilled by an independent
third-party inspection body like Lloyd's Register.

A manufacturer is any party which carries out operations affecting the

material properties of the finished product. Examples are steelmakers,
foundries, smelters, forgers, and pipe/plate mills.
Therefore, true EN 10204:2004 Type 3.2 certification is produced by the
manufacturer, with test results supplied. The independent third-party
inspector will have witnessed the test results and verified the material's
identification and traceability through objective evidence.

What is certification "to the intent of Type 3.2"?

A common practice in the industry is for the purchaser to order material
from an intermediate material handler. That handler may select material
that has only been certified by the manufacturer using a Type 3.1 certificate.
In the standard, this has not been verified by a third-party inspector.
However, it is widely accepted that material with a Type 3.1 certificate can
be "validated" to the intent of Type 3.2. This happens when the material
handler uses an independent third-party to validate the material by way of
verification tests.
Lloyd's Register can provide "intent-of" Type 3.2 certification by visiting the
material handler to identify the material to be verified. This includes:

Visual examination
Sample dimensional checks
Confirmation the material is traceable back to the ladle chemical
analysis which may be in the form of a Type 3.1 certificate.

Our surveyor also visits the test house to witness all additional testing of the
material necessary to confirm compliance with the specification.
If all of the above meet with the requirements, the surveyor carries out a
final visit to the intermediate material handler to review documentation,
verify that the material meets the product specification and the customer's
purchase order requirements, then inspect and hard stamp the material.
This material then carries an "intent of EN 10204:2004 Type 3.2" certificate,
and must not be passed off to customers as being certified in accordance
with true EN 10204:2004 Type 3.2 certification. This is why it is important
that the purchaser knows and accepts an "intent-of" Type 3.2 certificate.

Clearing up EN 10204 Type 3.2

certification confusion as supply chain
complexity grows
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, Lloyds 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 manufacturers test results. The
document is validated by the manufacturers 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, Lloyds 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

True type 3.2 certification involves visits to the manufacturer by the thirdparty 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.
Lloyds 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. Lloyds 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.
Lloyds 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.
For more information about the briefing in the UK and to download a copy of
the presentation, click here.
About the author:
David Thompson is a senior surveyor for Lloyds Register's Inspection
Services. He has been with Lloyds Register since 2008, and is a Graduate
Materials Engineer and Chartered Engineer. Prior to working for Lloyds
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.