If you fabricate structural steel or aluminium for use in construction in Great Britain (England, Scotland and Wales), compliance with BS EN 1090-1 is not optional. It is a legal gateway to placing load-bearing structural components on the market.
Failure to comply can result in enforcement action, project suspension, reputational damage, and financial penalties.
This article sets out what the standard requires, who it applies to, and the risks of non-compliance.
To get customised support specific to your organisation, please get in touch with us.
What Is BS EN 1090-1?
BS EN 1090-1 is the UK-adopted version of the European standard governing the execution of steel and aluminium structures.
Part 1 specifically covers:
- Assessment and verification of constancy of performance (AVCP)
- Factory Production Control (FPC)
- Requirements for CE marking (historically) and now UKCA marking in GB
It applies to load-bearing fabricated structural components, including:
- Beams, columns, frames
- Staircases and balustrades (where structural)
- Steelwork assemblies
- Aluminium structural systems
If the product contributes to the mechanical resistance or stability of a building or civil engineering works, the standard applies.
Legal Context in Great Britain
Following Brexit, CE marking transitioned to UKCA marking for products placed on the GB market.
For structural steel and aluminium:
- Products must meet BS EN 1090-1
- Fabricators must operate a compliant Factory Production Control system
- Certification must be issued by a UK Approved Body
- The certification body must be UKAS-accredited
UKAS (the United Kingdom Accreditation Service) ensures the certification body itself meets competence and impartiality requirements.
Without this certification, you cannot legally affix the UKCA mark to applicable structural components.
What Is Factory Production Control (FPC)?
Factory Production Control is a documented, audited quality management system specific to fabrication activities.
It is not simply “having procedures.”
An FPC system under BS EN 1090-1 must include:
- Control of incoming materials (traceability of steel/aluminium)
- Welding coordination (qualified personnel)
- Welder qualifications (e.g., ISO 9606)
- Welding Procedure Specifications (WPS) and approvals (WPQR)
- Control of subcontracted processes
- Calibration of inspection and test equipment
- Non-conformance control
- Inspection and testing records
- Documented responsibilities and authority
The system must operate continuously, not just during audits.
Role of the UKAS-Accredited UK Approved Body
A fabricator cannot self-declare compliance.
A UK Approved Body:
- Assesses your Factory Production Control system
- Conducts initial inspection of the factory and FPC
- Performs ongoing surveillance audits
- Issues and maintains your FPC certificate
That certification is mandatory before you place structural components on the GB market.
Execution Classes (EXC)
BS EN 1090 works alongside BS EN 1090-2 (steel) and BS EN 1090-3 (aluminium), which define technical fabrication requirements.
Projects are categorised into Execution Classes (EXC1–EXC4) based on structural risk and consequence of failure.
Higher execution classes require:
- Greater welding control
- More inspection and testing
- Increased documentation
- Higher competence levels
Fabricators must be certified for the appropriate execution class relevant to their work.
What Happens If You Are Not Compliant?
Non-compliance is not a minor administrative issue. The consequences can be severe.
1. Market Exclusion
Main contractors and structural engineers will require:
- Valid FPC certification
- Proof of UKCA marking capability
Without this, you will be excluded from tender opportunities.
2. Project Delays
If non-compliance is identified during:
- Building control inspections
- Principal contractor audits
- Client due diligence checks
Projects can be halted while compliance issues are resolved.
This can lead to liquidated damages and contractual disputes.
3. Heavy Fines and Enforcement
Enforcement authorities can:
- Issue compliance notices
- Prohibit supply
- Pursue financial penalties
Supplying structural components without proper conformity assessment may also expose directors to legal liability.
4. Insurance and Liability Exposure
In the event of structural failure:
- Lack of compliant FPC certification significantly weakens legal defence
- Professional indemnity and product liability insurers may refuse cover
Common Misunderstandings
“We only fabricate small items.”
If they are structural, the standard still applies.
“We don’t weld much.”
If welding forms part of the structural integrity, you require compliant welding control.
“We’ve always done it this way.”
Historical practice is irrelevant. Legal conformity is mandatory.
“We have ISO 9001.”
ISO 9001 alone is not sufficient. BS EN 1090-1 has specific technical and competency requirements.
Practical Compliance Steps
For fabricators not yet certified:
- Gap analysis against BS EN 1090-1
- Appoint a competent Welding Coordinator
- Develop and implement an FPC system
- Qualify welders and procedures
- Apply to a UKAS-accredited UK Approved Body
- Pass initial inspection
- Maintain ongoing compliance
Certification is not a one-off exercise, surveillance audits typically occur annually.
Strategic Business Impact
Compliant fabricators gain:
- Access to larger commercial projects
- Improved credibility with principal contractors
- Reduced risk exposure
- Stronger quality control across operations
Non-compliant businesses increasingly find themselves unable to compete in regulated construction supply chains.
Final Position
If you fabricate structural steel or aluminium for the GB market, UKAS-accredited FPC certification under BS EN 1090-1 is mandatory.
The cost of certification is predictable and manageable.
The cost of non-compliance, project exclusion, fines, legal action, and reputational damage, is not.
For any fabricator operating in structural markets, this is a core regulatory requirement, not an optional accreditation.
Ensure Your BS EN 1090-1 Compliance Is Audit-Ready
If you’re unsure whether your Factory Production Control system fully meets BS EN 1090-1 requirements — or you need support preparing for UKAS-accredited certification — now is the time to address it.
Non-compliance risks project delays, rejected tenders, and serious financial exposure.
Request a call back today to discuss your current position, identify gaps, and put a clear plan in place to secure or maintain your certification with confidence.
