Understanding

EN 10204:2004
Type 3.2
Certification
A Lloyd’s Register Guide

v 1.1 October 2018

EN 10204:2004 Type 3.2 Certification
Table of contents
● History and Development of the Standard
– Applicability; definitions

● True 3.2 certification v. “Intent of” 3.2 certification

– Background; definition; client classification

● Common client misconceptions

● Inspection Practicalities
– What, why and how we do our inspections
EN 10204:2004 Type 3.2 Certification
The History of the standard
● Originally issued in 1991 – derived from DIN50049.

● Re-issued in 2004 (current version), with reduced number of

certificate types – seven to four.

● Certificate types which require independent third-party

involvement were called type 3.1c in 1991 version, changed to
type 3.2 in 2004 version.
History of the standard
Applicability and definitions
– Scope (1.1) – “All metallic products e.g. plates, sheets, bars, forgings, castings”.
– Definition (2.3) – “Manufacturer – organization that manufactures the respective
products according to the requirements of the order and to the properties
specified in the referenced product specification”.
– Definition (2.5) – “Product Specification – complete detailed technical
requirements relevant for the order, stated in written form e.g. referenced
regulations, standards or other specifications”.
– Technical Committee responsible for EN 10204 comprises mainly representatives
of “primary steelmakers” - hence its focus on primary metallic products.

Lloyd’s Register (LR) often visits “stockists” – where do they

fit in with EN 10204?
History of the standard
Purpose of third-party Inspection
● The main purpose of Type 3.2 certification is to independently verify:
– Material traceability – from original cast to despatch to customer.
– Material properties – ensures material is fit for its intended purpose.

● The Independent Third Party’s activity should “add value” to the

material/product.

● The customer/end user should have assurance that the material is correct
and fit for purpose.
True 3.2 v. “intent of” 3.2
Background
● Rise in importance of “stockists” – no longer
just steel merchants. Ref:- “Intermediate
Material Handler” – LR 3.2 factsheet.

● Stockists now specialise in selling material

into Oil & Gas supply chain

● Oil & Gas “end-users” often require third-

party inspection/verification of raw
materials for critical applications – EN 10204
Type 3.2 certification
True 3.2 v. “intent of” 3.2
Background
● Not always economically viable to buy 3.2 certified raw material from primary
steelmaker (minimum batch quantity)

● Industry-driven requirement for Type 3.2 certification of material handled by

stockists

Can stockists be classified as manufacturers as per

EN 10204?
If not, how can we certify to Type 3.2 as required
by the industry?
True 3.2 v. “intent of” 3.2
Definition of a manufacturer
● LR has adopted the same definition of a manufacturer as stated
in NORSOK standard M-650 – Qualification of Manufacturers
of Special Materials:
– “…party, including sub-contractors, which carry out operations
affecting the material properties of the finished product”.
● It is clear that foundries, forges, extruders, etc. are
manufacturers.
● A stockist – depending on their production route – could be
classed as a manufacturer.
Is this stockist a manufacturer?

Saw Drill

Steelmaker Stockist Customer

Grind Turn

● No “mechanical property changing” operations were carried out.

● This stockist has not “manufactured” the material, therefore the
certification can only be “to the intent of “ EN 10204 3.2.
Is this stockist a manufacturer?
Heat
Forge treat

Steelmaker Stockist Customer

Extrude Wire
draw
● “Mechanical property changing” operations were carried out.
● This stockist is considered to have “manufactured” the material, therefore the certification can be in accordance
with EN 10204 3.2.
● Material must be traceable through stockist’s and sub-contractor’s operations.
Common client misconception #1
If the material has been 3.2 certified at the steelmaker – there is nothing
else to do.
● Not necessarily - complicated supply chains lead to potential traceability
issues

Steelmaker Stockist A Stockist B Customer

● How can we preserve the material’s 3.2 status?

Solution – Independent Third Party involvement at every stage of
supply chain: cast transfer.
Common client misconception #2
The Independent Third Party can carry out a “paperwork review” for Type
3.2 certification.

● Does this verify the material’s traceability or properties?

● Does this “add value” to the material?

No. The Independent Third Party is just acting as an expensive

“spell-checker”.
Common client misconception #3
We can ask the test house to add “EN 10204 3.2” to their
Mechanical Test Report.

● Irrelevant: The test house is not the manufacturer (refer to the

definition of Type 3.2 certificate in EN 10204)

● This ignores other testing that may be a requirement of product

specification (e.g. NDE).

This only causes confusion in the industry.

Inspection practicalities

The main purpose of 3.2 certification is to

independently verify the material’s:
• Traceability – from original cast to despatch to
customer
• Properties – to ensure the material is fit for its
intended purpose

The Independent Third Party’s activity should

“add value” to the material/product.
Inspection practicalities
We’ll discuss a “generic” inspection process – applicable for true and
“intent of” 3.2 certification.
● Additional inspection/witnessing can be done as required by specific customer requirements
(Bills of Material; ITPs, etc).
● All clients are different. Many scenarios can arise.
● LR Surveyor’s experience and collaboration with the client can formulate a suitable work-
around where necessary.
● We adopt a 3-stage inspection process:-

Review all client’s

Check material’s documentation
Stage identity and stamp
piece/area to be Stage Witness/review
mechanical and Stage against “product
specification”,

1: 2: 3:
used for metallurgical endorse paperwork
mechanical testing testing. and inspect/stamp
– “Stamp for test” material for
release.
Inspection Practicalities Stage
Check material’s
identity and stamp
piece/area to be Stage Witness/review
mechanical and Stage
Review all client’s
documentation
against “product
specification”,
endorse
1: used for
mechanical testing
– “Stamp for test”
2: metallurgical
testing. 3: paperwork and
inspect/stamp
material for

Stage 1
release.

● Objective is to verify the material’s identity. Look for original, unique

identification, e.g. cast/melt No., serial No., etc.

● Identification should be traceable within client’s facility and back to the

melt/cast (if a foundry), or traceable to the original steelmaker’s Type 3.1
certificate (stockist, etc.).

● If all is satisfactory, the test material is hard stamped with the Surveyor’s
personal stamp (initials). This identifies the material to the attending
Surveyor at the Test House.
Inspection Practicalities Stage
Check material’s
identity and stamp
piece/area to be Stage Witness/review
mechanical and Stage
Review all client’s
documentation
against “product
specification”,
endorse
1: used for
mechanical testing
– “Stamp for test”
2: metallurgical
testing. 3: paperwork and
inspect/stamp
material for

Stage 2
release.

● Witness mechanical testing – usually carried out at a sub-contracted, accredited (ISO 17025)
testing facility.

● All testing equipment will be verified by the attending Surveyor as being within calibration.

● Testing should be carried out to the client’s requirements.

● Failed tests will be “noted” on the Test Report.

● LR’s standard policy for 3.2 certification is to “witness” mechanical testing – tensile, impact,
hardness, bend, etc. – but “review” metallurgical testing – grain size, ferrite count, corrosion
test, etc. Ref: LR’s 3.2 factsheet
Inspection Practicalities Stage
Check material’s
identity and stamp
piece/area to be Stage Witness/review
mechanical and Stage
Review all client’s
documentation
against “product
specification”,
endorse
1: used for
mechanical testing
– “Stamp for test”
2: metallurgical
testing. 3: paperwork and
inspect/stamp
material for

Stage 3
release.

● Review client documentation against ALL customer’s requirements – Product Specification.

– Includes all processes that affect the material’s properties and all processes required by the Product
Specification (NDE, etc.).

● Endorse client’s paperwork.

● Inspect material to be despatched (quantity/quality, size, identification) and hard stamp

“iLRs” + personal stamp.

● If required, LR can issue certification that supplements the client’s certification.

– Includes a “scope of survey” and conclusion statement that material either conforms to, or is “to the
intent of” EN 10204 Type 3.2
EN 10204:2004 Type 3.2 Certification
Conclusions
– EN 10204 Type 3.2 certification provides assurance to the customer that:
• The material is fully traceable.
• The material’s properties meet specified requirements.

– Type 3.2 certified material, carried out by LR, will as a minimum have
been subject to the inspection/testing/witness regime described
previously.

– EN 10204 Type 3.2 certified material can be used in many applications –

not just the Oil & Gas industry – where a high-level, independent
assurance is required.
EN 10204:2004 Type 3.2 Certification

● Further Information:-
– EN 10204: 2004 – Type 3.2 Inspection Certification factsheet.
• Explains our inspection process in more detail.

● LR has an extensive global network of qualified and trained Surveyors, capable of inspecting
material to EN 10204 Type 3.2 and discussing technical queries.

● Higher concentration of Surveyors in “industrial centres” to meet client demand

● Click here to request a quote, ask a question or request a surveyor.

David Thompson
Senior Surveyor, Lloyd’s Register UK

For questions, quotes or queries

We’re happy to help. Just email us at inspection@lr.org.

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