STOCKHOLDER / DISTRIBUTOR

Steel stockholders generally purchase steel sections which have been CE Marked by the steel manufacturer to EN 10025-1 for I and H sections, EN 10210-1 for hot- finished structural hollow sections and EN 10219-1 for cold formed structural hollow sections.

Sometimes these sections are then cut to exact length, drilled, blast cleaned and painted by the stockholder before being supplied to the steelwork contractor. All of these activities are fabrication activities which are covered by the CE Marking standard EN 1090-1. For example, it is important that the section is cut into exact length and holes are drilled into accordance with the tolerances given in BS EN 1090-2.

Stockholders who provide these services will therefore need to extend the CE Marking for the modified steel sections in accordance with the fabrication CE Marking Standard EN 1090-1. This will require initial type testing (ITT) and the setting up a certified factory production control (FPC) system as described in section 10.

Sometimes stockholders re test steel sections to re-evaluate fracture toughness, Fracture toughness is one of the performance values declared on the CE Marking by the steel manufacturer. Therefore a change to the product’s original performance values for the fracture toughness will require the section to be re-CE Marked.

The stockholder will therefore have to perform ITT for the change in the performance value for the fracture toughness and set up an appropriate FPC System. In this case, setting up an FPC system cannot be based on the original steel production process as the stockholder has no control over the raw materials or the production process.

The FPC system will be based on documentary controls and testing of the finished product. The laboratory testing will need to be checked by the NB as described above.

A distributor is a person or organisation which stores and distributes a CE Marked product that has already been placed on the EU market. Some steel stockholders fall in to this category. The distributor does not alter the product in any way nor does it put its name on the product. For example, some stockholders re-test steel sections or the plates in order to establish improved CVN values. This process changes the declared propertied of the product and the stockholder then becomes a manufacturer.

Although distributors do not have any responsibilities under the CPD they do have a duty to ensure that the correct CE Marking is associated with the correct CE Marking is associated with the correct product and that clearly non-compliant products are not placed on the EU market.

The issue of an organisation buying a CE Marked product changing some of its declared properties and putting it back on the market is worth exploring further with reference to certain parts of the steel construction supply chain. For example some steel stockholders offer a service to steelwork contractors which involves modifying the original CE Marked steel section. Steel benders provide a service which bends the original steel beam modifying some of declared properties. In both cases the stockholders and steel benders are classed as manufacturers.