EN 10204 3.1 and 2.2: The Difference Is the Batch, Not the Paper

"Certificate included" is the most common line on a rigging hardware enquiry, and one of the least useful. A certificate can be a declaration with no measured results at all. EN 10204 exists to make that difference nameable — but it does not tell anyone what to test.

1. The line that looks like a specification

Two suppliers quote the same shackle. Both confirm that a certificate will be supplied. One delivers a declaration of compliance with the order; the other delivers results from tests carried out on the material actually shipped. Both statements were true when they were written. At goods-in, one of them answers the buyer's question and the other does not, and the difference was never in the product. It was in a document type that nobody named.

This is a purchasing problem before it is a metallurgical one. The paperwork is agreed at the enquiry stage, long before anyone can look at a heat number. Once the goods are on the quay, the range of documents that can honestly be issued has already been fixed by what was inspected, when, and by whom.

2. What EN 10204 standardises — and what it does not

EN 10204 is the European standard defining the types of inspection document supplied with metallic products. Public descriptions of the standard, including the glossary entry on this site, converge on a narrow scope: it defines document types and who confirms which information. It distinguishes non-specific inspection, carried out on products from the same production process, from specific inspection carried out on the products actually delivered or on the test unit of which they form part.

What it does not do is specify the tests to be performed, the acceptance limits, the material grade, or the mechanical properties required. Those come from the product standard and from the order. EN 10204 tells you the form of the evidence and the authority behind the signature; the product standard tells you what the evidence has to show. Asking for "a 3.1 certificate" without naming the product standard and its edition is therefore only half a specification.

3. The four document types, one line each

• Type 2.1 — declaration of compliance with the order. The manufacturer states that the products comply with the order. No test results are given.
• Type 2.2 — test report. Test results are included, but they come from non-specific inspection: routine testing of products made by the same process, not necessarily the exact items delivered.
• Type 3.1 — inspection certificate 3.1. Results come from specific inspection of the delivered products, validated by the manufacturer's authorised inspection representative, who is independent of the manufacturing department.
• Type 3.2 — inspection certificate 3.2. As 3.1, with the results additionally confirmed by the purchaser's representative or an inspector designated by official regulations.

These definitions are reproduced in the glossary on this site and in public industry references to EN 10204:2004. The wording matters, because "test report" sounds stronger than "inspection certificate" to a reader who has not met the standard before.

4. The dividing line is specific versus non-specific

The jump from 2.2 to 3.1 is not "one more signature". It is the jump from this is what our material is usually like to this is what your material actually is. A 2.2 test report can be entirely correct and still describe a different heat from the goods on the pallet. A 3.1 certificate reports results obtained on the delivered batch or its test unit, and is expected to be traceable to a heat or batch number that can be reconciled with the physical items.

That is why a project specification that calls for a 3.1 certificate cannot be satisfied by a neatly presented 2.2 report, however detailed the numbers look. Conversely, requiring 3.1 for every non-critical item adds cost and lead time without adding information anyone will use. The decision is about evidence, not about paper quality.

5. Who signs, and why independence is the point

Under the 3.1 type, the signatory is a person within or contracted to the manufacturer's organisation whose inspection function is independent of production. This is internal independence, not third-party independence. It is designed so that the people who made the material are not the people who certify the results. It is a meaningful control, and it is also routinely over-described in sales language: a 3.1 certificate is not a third-party witness statement.

External validation appears at 3.2, where the purchaser's representative or an inspector designated under official regulations confirms the results alongside the manufacturer's representative. Because that person may need to witness the testing, the requirement has to be arranged before the material is produced. No amount of goodwill after despatch converts a 3.1 into a 3.2; the inspection either happened under the required conditions or it did not.

6. Why the type belongs in the purchase order

Public guidance on EN 10204 repeatedly makes the same practical point: the type of inspection document is not supplied automatically, and it must be stated in the order. Specific inspection has to be planned, performed on the delivered lot and recorded with its traceability intact. If that work was not done, a manufacturer often cannot issue the document retrospectively — not because of unwillingness, but because the evidence does not exist.

The classic failure is a project that requires 3.2, a buyer working to a tight schedule who sources from stock, and a consignment that arrives with 3.1 documentation because no independent inspector was present when the stock was produced. At goods-in the certificate is rejected, the material cannot be used, and the only remaining options are new material with inspection arranged in advance or a formal concession from the end client. Flagging the requirement in the enquiry costs nothing.

7. Traceability has to reconcile with the goods

A certificate is only as useful as the link between the number on it and the marking on the part. The glossary defines the batch or heat number as the identifier tying a finished batch back to the melt, the material certificate and the inspection records, and notes that traceability is only meaningful if the number can be reconciled with the marking or record on the delivered goods. It also distinguishes a certificate of conformity — a statement of compliance — from a set of measured results.

At goods-in, the checks are straightforward: does the certificate name the standard and edition the order named; is there a heat or batch number; does that number appear on or with the delivered items; does the product description on the document match the item physically present; and are the reported results the ones the order required, rather than a generic set the supplier routinely issues? If the numbers cannot be reconciled, the correct response is to stop and query, not to file the document.

8. An inspection document does not replace the product standard

In lifting hardware, three documents are often conflated. The product standard — EN 13889 for forged steel shackles, EN 818-2 for Grade 8 short link chain, EN 13414-1 for general-purpose steel wire rope slings — defines the object and its requirements. The inspection document type under EN 10204 defines the form and authority of the evidence. A declaration of conformity states that goods comply with an order and a named standard, without itself supplying measured results.

None substitutes for another. A 3.1 certificate attached to the wrong product standard describes the wrong object with great precision. A declaration of conformity to the right standard tells you nothing about measured chemistry or mechanical properties. When a buyer needs measured values, the type must be specified at the time of order, and the properties to be reported must be specified by the product standard or by the order itself.

9. What European buyers usually mean by "we insist on 3.1"

In most industrial procurement the request is not for a more impressive sheet of paper. It is for two things: results bound to the batch actually delivered, and a signature separated organisationally from the department that produced the goods. Where a classification society, a notified body, a regulator or an end-client specification requires independent witnessing, the request is for 3.2 and must be planned early. Where neither is required, 2.2 may be entirely adequate — provided everyone knows that is what was ordered.

There is no hierarchy of honesty here. A correctly issued 2.2 report is an accurate document; a 3.1 certificate describing a different batch would not be. The problem is almost always a mismatch between what the buyer assumed the words meant and what the supplier was asked to provide.

10. What to put in the enquiry

1. The EN 10204 inspection document type, with edition, stated explicitly — 2.1, 2.2, 3.1 or 3.2 — rather than "certificate included";
2. The product standard with edition that the document must reference, and the product description it must match;
3. The batch or heat number requirement, and how it will be reconciled with the marking on the delivered goods;
4. The properties or test results the order requires, where these are not already fixed by the product standard;
5. Whether independent witnessing is required, in which case the inspection must be arranged before manufacture, not requested at delivery;
6. Confirmation that the agreed documents will accompany the consignment and be available for goods-in checking before the items enter stock.

That list turns a vague assurance into an answerable question. It also removes the most common source of a dispute at delivery, where one party is holding a perfectly valid document and the other is holding a specification the document was never asked to meet.

11. The short version

EN 10204 is not a test method and not a product approval. It is a vocabulary for who signs the evidence and whether that evidence describes the batch in front of you. Type 2.2 reports non-specific results; type 3.1 reports specific results validated by an inspection representative independent of production; type 3.2 adds outside confirmation. Because specific inspection has to happen before delivery, the type belongs in the purchase order. Words added at goods-in cannot change what was inspected.

Sources: published descriptions of the EN 10204:2004 inspection document types and of specific versus non-specific inspection (industry and standards references including KTB Europe, TestCert and MDB Builder); the glossary entries on inspection document types, certificate of conformity and batch / heat number; the standards overview and quality pages on this site. Readers should consult the standard itself, the product standard named in the order, the certificate and their own goods-in procedure. No chemical limits, mechanical property values, test results, certification numbers or conformity claims are asserted in this article.