When hardware structural components are used in construction (e.g., load-bearing members, door and window hardware, curtain wall accessories, guardrails), their export to the EU falls under the jurisdiction of the Construction Products Regulation (CPR, EU 305/2011). The CE mark shifts from a “voluntary quality label” to a mandatory declaration of conformity; manufacturers must complete assessments based on harmonized standards or European Technical Assessments and issue a Declaration of Performance (DoP).
This article outlines the certification pathways and key points for structural construction components.
I.
Classification: Certification pathways for three types of structural construction hardware
- Load-bearing steel/aluminum structures: Permanent load-bearing components such as steel beams, columns, and structural assemblies. These fall under the EN 1090 system, requiring Factory Production Control (FPC) certification by a Notified Body. Welding processes and welder qualifications must comply with EN 1090-2 (EN ISO 9606-1 for welders, EN ISO 14731 for coordinators, and EN ISO 15614 for process qualification), generally following Assessment and Verification System 2+;
- Construction hardware: Items such as hinges, locks, door closers, and emergency escape devices. These are subject to specific harmonized standards—such as EN 1935 (hinges), EN 179 (emergency exit devices), EN 1125 (panic exit devices), and EN 1154 (door closers)—with most following System 3 (third-party laboratory type testing);
- New products without harmonized standards: These follow the European Technical Assessment (ETA) pathway. A Technical Assessment Body (TAB) issues an ETA based on a European Assessment Document (EAD), followed by CE marking. Examples include specialized curtain wall connectors and unique guardrail systems.
II. Fire Performance: A Critical Benchmark for Architectural Hardware
Products related to fire compartmentation and means of escape must be evaluated against fire resistance standards: doors, windows, and their hardware undergo fire resistance testing and classification according to EN 1634-1, while structural components follow the EN 1363 series. If products claim fire resistance or smoke control properties, they must also satisfy “reaction to fire” testing requirements (classified under EN 13501-1).
The fire resistance rating of fire-rated hardware (e.g., fire door hinges, door closers) directly determines market access eligibility; testing timelines and costs are significantly higher than those for standard hardware.
III.
Five-Step Certification Process
Confirm the product falls within the scope of the CPR → Identify the applicable harmonized standard (hEN) or apply for an ETA/EAD → Determine the assessment pathway based on the AVCP system (a combination of type testing and factory audits) → Complete testing and establish Factory Production Control (FPC) → Issue the Declaration of Performance (DoP) and affix the CE mark (including the Notified Body number, if applicable).
The DoP must accompany the product, and the CE mark may be affixed to the product itself, its packaging, or the accompanying documentation.
IV.
Three Often-Overlooked Requirements
- Welding qualifications are product-specific: Welding operations for stainless steel structural components are subject to specific qualification requirements—building regulations in countries like Germany mandate welding certificates compliant with EN 1090-1; manufacturers of stainless steel railings or embedded parts should not overlook this;
- AVCP systems dictate the workload: System 1 requires product certification by a Notified Body (e.g., for structural sealant curtain wall assemblies), whereas System 3 requires only type testing by a Notified Laboratory—similar products may fall under different systems depending on their intended use, so verify the system before proceeding;
- The ETA pathway is not a “shortcut”: While products lacking a harmonized standard can pursue an ETA, the development of the EAD (European Assessment Document) and the assessment process involve long timelines and high costs, requiring advance planning.
V. Trends: CPR Reform and Digital Product Passports
The EU is advancing the revision of the Construction Products Regulation (CPR) and the implementation of Digital Product Passports for construction products, with a clear shift toward the digitization and traceability of Declarations of Performance (DoP). Meanwhile, market surveillance authorities across various countries are intensifying inspections regarding CE marking for construction hardware.
Industry experts advise export enterprises dealing in structural components to formalize a “Product Classification → Standard Identification → AVCP Pathway” workflow within their order review process. This entails first determining whether the product falls under the EN 1090 route (for load-bearing components), the harmonized standard route (for general hardware), or the ETA route, before initiating testing and establishing factory production control systems;
selecting the correct certification pathway is the key to unlocking access to the construction market.
