Mailong Metals

EN 10204 Mill Test Certificates: 2.1 vs 2.2 vs 3.1 vs 3.2 Explained

Published: 11 min readBy Wang Bo
WB
By
Wang Bo
Quality Assurance Manager Β· Mailong Metal
ISO 9001 Lead AuditorEN 10204 specialist20 yrs QA
LW
Reviewed by
Li Wei
Senior Metallurgical Engineer Β· Mailong Metal
MSc MetallurgyASM International16 yrs nickel alloys
A typical EN 10204 3.1 mill test certificate page showing chemistry, mechanical, hardness and certifying official's stamp.

A mill test certificate (MTC) is the single most-asked-for document in metal procurement. It travels with the material from melt-shop to job site, gets photographed at goods-receipt, audited by the third-party inspector, archived for the project life. Get the type wrong and your shipment can sit at the dock for weeks while engineering issues a deviation. Get a forged one and you ship a product whose chemistry might not even be the right grade.

This guide explains the four types defined in EN 10204:2004, what each section of a 3.1 actually means, how to spot the most common falsifications, when 3.2 is mandatory, and provides a clean PO-language template. Skip to the type comparison if you only need the bottom line.

What is an MTC and why it matters

EN 10204 β€” first published in 1991 and revised in 2004 β€” is a European standard that codifies the four types of inspection documents a manufacturer can supply with metallic products. The closely aligned ISO 10474 makes the structure identical for non-EU markets. An MTC's job is to bind the physical product to a documented chain of evidence: which heat melted it, what its chemistry is, which mechanical tests it passed, who signed off, against which spec.

For pressure equipment under the EU Pressure Equipment Directive (PED 2014/68/EU) or ASME B&PV Code, an MTC is non-negotiable. For industrial fabrication β€” ductwork, tanks, structural β€” the MTC is what the QA department audits during IQA receiving. For end-customer warranty claims, the MTC is the primary traceability artefact.

The 4 EN 10204 types side-by-side

TypeNameTests on actual product?Issued byWhen to use
2.1Declaration of compliance with the orderNo β€” generic statement onlyManufacturer (production)Lowest-criticality items (e.g. fasteners commodity)
2.2Test reportNo β€” based on non-specific tests on similar productManufacturer (production)Standard structural sections, low-pressure piping
3.1Inspection certificate 3.1Yes β€” specific to the actual heat / batchManufacturer's authorised inspection representative independent from productionMost pressure equipment, alloy materials, ASME, EN 13445
3.2Inspection certificate 3.2Yes β€” witnessed by an independent third partyManufacturer + independent third-party (TÜV/SGS/BV) or purchaser's representativeCritical service: lethal / sour / nuclear / offshore class 1

The legacy types 3.1.A, 3.1.B, 3.1.C and 3.2 from EN 10204:1991 were consolidated into 3.1 and 3.2 in the 2004 revision. You will still occasionally see "EN 10204 3.1.B" on older specifications β€” this is equivalent to the modern 3.1.

Anatomy of a 3.1 certificate

A compliant 3.1 lists the data points specified by EN 10168 (the companion information-list standard). At minimum, expect these blocks:

  • Header: certificate number, date of issue, manufacturer name and address, customer PO number, delivery note number.
  • Product description: standard (e.g. ASTM A240), grade (e.g. 304L), form (plate / sheet / bar), nominal dimensions, surface finish, heat number, batch / lot number.
  • Chemistry: full elemental analysis from ladle and (where required) product analysis. Each value with its specification range.
  • Mechanical properties: tensile, yield, elongation, hardness; sometimes Charpy impact, bend test.
  • Heat treatment record: temperature, time, cooling medium.
  • NDT results (when required): ultrasonic, radiographic, hydrostatic, eddy current.
  • Specific tests: e.g. ASTM A262 for sensitisation, ASTM A923 for sigma, ASTM E45 for inclusion rating.
  • Standards compliance statement: "We hereby certify that the material described above complies with…"
  • Authorised signature + stamp: name, title, ID number of the manufacturer's inspection representative; manufacturer's official stamp.

How to spot a forged 3.1

Forged 3.1 certificates are unfortunately common in the global metals trade, especially for high-margin alloys. The forgery patterns are surprisingly consistent.

Red flagWhy it's suspiciousWhat to do
Heat number on cert does not match the stamped marking on the productMost basic check β€” fakes often use stock heat numbersReject the shipment and demand original
Chemistry exactly hits the centre of every spec rangeReal heats deviate; centred values suggest the certificate was filled in by hand without real lab dataDemand the original PDF from the lab, not just a scanned cert
Tensile/yield ratio implausibly low or highFor 304L, yield is typically 35-45% of tensile; 80% suggests cold-worked, fabricated numberCross-check against ASTM specifications
Stamp / signature looks pasted (low-resolution PNG over text)Modern PDFs preserve vector graphics; rasterised stamps suggest scanned-and-recombinedOpen in Adobe Acrobat, check object structure
Mill name does not match a real registered millSome forgeries invent plausible-sounding factory namesVerify against ISO 9001 / API / Lloyd's registers
No EN 10168 data block; certificate is just a one-page summaryReal 3.1s are 2-4 pages with detailed lab dataRequest the full data appendix

The single most effective verification step: ask the issuing mill directly. Most reputable mills have a certificate-verification email or web portal. Send them the cert number and they will confirm authenticity within 1-2 business days.

When to insist on a 3.2

A 3.2 typically costs 1-3% extra and adds 7-14 days lead time, so it's not appropriate for every order. Insist on 3.2 when any of the following apply:

  • The end product is a pressure vessel under PED 2014/68/EU Category III/IV.
  • ASME B&PV Section VIII Division 2 Class 2 or above.
  • NACE MR0175 / ISO 15156 sour service in oil & gas.
  • Lethal service per ASME B31.3.
  • Offshore project class 1 β€” most operators (BP, Equinor, Total) require 3.2 by default.
  • Nuclear class 1, 2 or 3 components.
  • Ammonia plants, hydrogen service above 200 Β°C.
  • Project-specific QA requirement β€” read the spec carefully.

Purchase-order language template

Drop this language into the PO body or a separate quality clause attached to the PO. It eliminates the most common source of certificate disputes: ambiguous ordering language.

Material shall be supplied with an EN 10204 type 3.1 inspection certificate as a minimum. The certificate shall include the manufacturer's heat number, full ladle and product chemical analysis per the applicable specification, all mechanical properties required by the specification (including but not limited to tensile, yield, elongation, hardness and Charpy impact where applicable), heat treatment record, surface and dimensional inspection records, NDT records where required, and any product-specific tests called out by the specification (e.g. ASTM A923, ASTM A262, NACE TM0177). The certificate shall be signed by the manufacturer's authorised inspection representative, independent from the production department, and shall reference each applicable governing standard. For type 3.2, witness shall be provided by [TÜV SÜD / SGS / Bureau Veritas / purchaser's representative] and a copy of the witness report attached to the certificate. The original signed certificate shall accompany each shipment; an electronic PDF copy shall be emailed to [QA contact] within 24 hours of despatch. Any non-conformance shall be reported to the purchaser within 24 hours of discovery.

For more on Mailong Metal's QA process, see our services page and about us. For the full text of the standard, see EN 10204:2004; for the data-list companion, EN 10168.

Frequently Asked Questions

What is the difference between EN 10204 3.1 and 3.2?
Both certify that the actual product passes inspection on the actual heat. A 3.1 is signed by the manufacturer's authorised inspection representative, who must be independent from the production department. A 3.2 adds a second signature from either an independent third-party inspector (TÜV, SGS, Bureau Veritas) or the purchaser's authorised representative who physically witnessed the testing. A 3.2 typically adds 1-3% to material cost and 7-14 days lead time but is mandatory for PED, ASME B&PV and most offshore project specifications.
Is a 3.1 certificate enough for ASME pressure vessels?
It depends on the application and jurisdiction. ASME Section II Part A and Part B accept material qualified to ASTM specifications, which require traceable mill test reports β€” typically a 3.1 is sufficient. For higher-risk applications (lethal service, sour service, very thick sections), the AI may require a 3.2 with witness. Always confirm with the project's Authorised Inspector before placing the order.
Can a 2.2 certificate replace a 3.1?
No. A 2.2 is a non-specific (statistical) test report from the manufacturer based on similar product qualifications, not on the specific batch. It is acceptable for low-criticality applications but never for pressure-bearing or load-bearing components. If your project specification calls for 3.1 or 3.2, a 2.2 is a non-conformance and cannot be substituted without engineering deviation approval.
How can I verify the authenticity of a 3.1 certificate?
Cross-check four things: (1) the heat number on the certificate matches the marking stamped on the actual product; (2) the chemistry and mechanicals fall inside the spec ranges and are internally consistent (e.g. tensile/yield ratio looks plausible); (3) the certifying official's signature and stamp can be verified against the mill's published authorised personnel list; (4) the certificate references real-world applicable standards (ASTM/EN/JIS), not generic labels. For high-value orders, request the original PDF, not a scan, and verify with the issuing mill directly.
Does a 3.1 cover both chemistry and mechanicals?
Yes. A typical 3.1 includes: heat number traceability, full chemistry per the spec, tensile and yield strength, elongation, hardness, impact toughness (when required), heat-treatment record, NDT results (where required), surface condition, dimensional tolerances and any specific tests required by the spec (e.g. ASTM A923 for duplex). The exact contents come from EN 10168, which is the data-list companion to EN 10204.
Is the certificate digital or paper?
EN 10204 itself is media-agnostic β€” both paper and digital are valid. Modern mills increasingly issue PDF or digitally signed XML certificates. For audit and recordkeeping, digital certificates with PKI signatures are easier to verify than scanned paper. Mailong Metal issues both: a stamped paper original and a PDF copy with a verifiable hash.
How long is an MTC valid?
An MTC documents tests done at a specific point in time (production); it does not expire. However, project specifications may require certificate dates within a defined window (e.g. 'material produced within 12 months of delivery'). Storage conditions can also affect material properties β€” surface oxidation, sensitisation in austenitics β€” so even a valid certificate does not guarantee the material remained as-tested if it was stored improperly.
Can I get a 3.2 retroactively on stock material?
Sometimes. If the material was produced with a 3.1, a third party can re-test a sample from the same heat and issue a 3.2-equivalent witness statement. This costs more than ordering 3.2 fresh and may not be acceptable to all project specifications, but it can save significant lead time when stock material is the only option. Discuss with TÜV, SGS or Bureau Veritas before agreeing.

References

  1. [1]EN 10204:2004 β€” Metallic products. Types of inspection documents β€” CEN / iTeh Standards
  2. [2]ISO 10474 β€” Inspection documents (closely aligned with EN 10204) β€” ISO
  3. [3]AD 2000-Merkblatt W0 β€” Pressure-vessel material qualification β€” VdTÜV / Beuth
  4. [4]TÜV SÜD inspection services β€” third-party witness β€” TÜV SÜD
  5. [5]SGS material inspection services β€” SGS
  6. [6]Bureau Veritas β€” third-party material inspection β€” Bureau Veritas
  7. [7]ASTM A480 β€” General requirements for flat-rolled stainless steel plate, sheet, strip β€” ASTM International
  8. [8]ASTM A370 β€” Standard test methods for mechanical testing of steel products β€” ASTM International
  9. [9]ISO 9001 β€” Quality management systems requirements β€” ISO
  10. [10]PED 2014/68/EU β€” Pressure Equipment Directive (EU) β€” EUR-Lex
  11. [11]ASME B&PV Code Section II β€” Materials qualification β€” ASME
  12. [12]EN 10168 β€” Steel products. Inspection documents. List of information β€” CEN / iTeh Standards
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