Client and/or Main Contractor’s Responsibility
For all fabricated structural steelwork delivered to site there is now a legal requirement under the Construction Products Regulation (EU) No.305/2011 (CPR), that it is CE marked.
In order to achieve this, the client, or main contractor should appoint a steelwork contractor with an Execution Class equal to that required for the project, as determined by BS EN 1090-1. It should be noted that steelwork contractors with EXC3 capability can be used for EXC1, 2 & 3, whilst a steelwork contractor with EXC2 capability can only be used for EXC1 & 2.
Contract documentation should also be updated to incorporate the CE marked version of NSSS 5th Edition, which incorporates the obligations of BS EN 1090-1 and BS EN 1090-2 on the steelwork contractor.
It should be noted that even if a non-EU steelwork contractor is used on a project, the CPR puts liability on clients and/or main contractors. In that instance, the party engaging the steelwork contractor would be classed as an importer under the CPR and must comply with obligations of importers given in art.13 of the regulations.