Manufacturing & Engineering UK-wide

Place basic metal products on the GB market: conformity and marking

If you place metal products on the market — structural steel and reinforcing steel for construction, or other finished metal goods — they must be safe and, where a product regime applies, carry conformity marking and a declaration of performance before you place them on the Great Britain market. This guide takes you through construction products and structural steel, and the residual general product safety duty.

Guide summary

You must make sure metal products are safe before selling them in Great Britain. For construction products like structural steel, you need a Declaration of Performance and either a UKCA or CE mark. For other metal goods, follow the general product safety rules. Keep your records for at least 10 years.

  • Check if your product is a construction product or general metal good
  • Get a Declaration of Performance for construction products
  • Use a UKCA mark (via UK Approved Body) or CE mark (both accepted in GB)
  • Write the Declaration of Performance in English
  • Keep the Declaration of Performance for 10 years after sale
  • Give the Declaration to the buyer – on paper, by email, or on a website
  • Meet 7 basic requirements for construction works, like strength and fire safety
  • Set up factory production control for structural steel
  • For Northern Ireland, follow separate EU rules under the Windsor Framework
  • If your product has no specific rules, still make sure it is safe
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Related guides in General Compliance

If you place metal products on the market, you must make sure they are safe and meet the right conformity regime before you place them on the market. Which regime applies depends on the product. Structural and reinforcing steel and other load-bearing metal components placed on the market for use in construction works follow construction-products rules; metal goods that fall outside any specific regime must still meet the general product safety duty.

These are Great Britain market-access regimes. UKCA is the GB conformity mark, but CE marking also continues to be accepted on the GB market, so for these regimes you can use either. If you also supply the Northern Ireland market, check the position separately — Northern Ireland follows EU product rules under the Windsor Framework, so the marking and conformity route can differ. Most basic-metal output is a business-to- business intermediate rather than a finished consumer product, so work through the regimes that actually apply to what you place on the market.

A. Structural steel and construction products

Structural steelwork, reinforcing steel and other load-bearing metal components covered by a designated standard — for example fabricated structural steel to BS EN 1090 — must have a declaration of performance and carry conformity marking — UKCA, or CE marking, which continues to be accepted on the GB market — before being placed on the GB market, with execution-class factory production control. Assessment and verification of constancy of performance follow the assimilated Construction Products Regulation, enforced by the Office for Product Safety and Standards (OPSS) with local Trading Standards. This applies to construction-product output; it does not apply to semi-finished feedstock such as billet, ingot or coil sold on for further processing.

B. General product safety (the residual duty)

Metal products placed on the GB market must be safe. The General Product Safety Regulations 2005 are the residual safety duty that applies where no specific product regime covers your product — for example semi-finished bar, sheet or castings sold on to, or likely to be used by, consumers. Where a specific regime does apply — construction products, pressure equipment, machinery — you meet that regime's essential requirements and carry the appropriate conformity marking instead. General product safety is enforced by OPSS with local Trading Standards.

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    1. Identify the regime for each product

    Decide whether your product is a construction product (e.g. structural or reinforcing steel to a designated standard) or falls under general product safety only. Semi-finished feedstock for further processing is generally outside both.

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    2. Find the designated standard and conformity route

    For construction products, identify the designated standard (e.g. BS EN 1090) and execution class, and the assessment and verification of constancy of performance system that applies.

  3. 3

    3. Set up factory production control

    Put the factory production control and technical documentation in place to support your declaration of performance.

  4. 4

    4. Draw up the declaration and apply conformity marking

    Issue the declaration of performance and apply conformity marking — UKCA, or CE which is still accepted on the GB market — before placing the product on the GB market.

  5. 5

    5. Check Northern Ireland separately if you supply there

    Northern Ireland follows EU product rules under the Windsor Framework, so confirm the marking and conformity route that applies before you supply the NI market.

What to do next

Product conformity sits on top of the workplace, environmental and major-accident duties every producer shares. Make sure those are in place with Set up and run a safe metal production plant, then confirm you have covered everything with the basic metal manufacturer compliance checklist.

Official sources

Authoritative guidance on construction products and product safety.