EN 10204:2004 says an intermediary may only pass on the manufacturer’s inspection document, as an original or an unaltered copy, with suitable means of identifying the product so traceability holds. A distributor cannot issue you a 3.1. It can only forward one. That single clause determines what you can reasonably demand from a stockist and what you must ask the manufacturer for.
The clause that governs the distributor relationship
Most explanations of EN 10204 walk through the four document types and stop. For anyone buying through a distributor, the operative clause is different.
The standard distinguishes the manufacturer, who makes the product, from the intermediary, who supplies it without changing its properties. A stockist is an intermediary. The requirement on an intermediary is narrow: pass on either the original inspection document or a copy without alteration, accompanied by suitable means of identifying the product so traceability between the product and the documentation is maintained.
Two consequences follow, and they are the two most useful things a buyer can know.
An intermediary cannot issue an EN 10204 certificate. If a distributor offers to “provide a 3.1”, what is actually on offer is the manufacturer’s 3.1, forwarded. That is the correct and compliant answer. A certificate on distributor letterhead attesting to material properties falls outside EN 10204 altogether.
The traceability obligation is on identification, not on a specific marking scheme. The standard requires “suitable means of identification” so the product can be tied to its paperwork. It does not require a heat number to be stamped on every individual component. That is a common and sensible contractual requirement, but it is one you impose, not one the standard imposes.
The four documents, and where the line actually falls
| Type | What it is | Results from | Validated by |
|---|---|---|---|
| 2.1 | Declaration of compliance with the order | No test results | The manufacturer |
| 2.2 | Test report | Non-specific inspection | The manufacturer |
| 3.1 | Inspection certificate | Specific inspection | The manufacturer’s authorised inspection representative, independent of the manufacturing department |
| 3.2 | Inspection certificate | Specific inspection | As in 3.1, and either the purchaser’s authorised inspection representative or the inspector designated by official regulations |
The meaningful division is between the 2-series and the 3-series: specific inspection. Specific inspection is carried out on the products supplied, or on test units of which the supplied products form part. The product specification, applicable rules, or the order defines the test unit. It may be a heat, a lot, or another defined unit. Calling 3.1 “batch-specific” is a useful shorthand but not the standard’s language, and on a small fitting the controlling unit may not be what you assume.
A note on 3.2 that is often got wrong. The second signatory has to hold a specific role. It is the purchaser’s authorised inspection representative, or an inspector designated by official regulations. A well-known inspection company qualifies only when acting in that role for your order. Naming a body in your specification without naming the role does not create a valid 3.2.
3.2 also does not automatically mean someone physically witnesses every test. What is witnessed, and at which hold points, comes from the inspection and test plan, not from the certificate type.
What to ask a distributor, in order
Who is the manufacturer of record? For a fitting or valve, the certificate you need may come from the component manufacturer, the upstream raw-material producer, or both. Establish which of them owes you the certificate before the PO is written.
What document type does the manufacturer supply as standard, and what is available by option? This question determines cost and lead time, and it has a factual answer the distributor can give you.
What is the traceability identifier on this product, and where does it appear? Not “will you stamp the heat number on it”. Ask what identifier the manufacturer’s own controlled system uses and how it is presented, then decide whether you need to impose more.
If a copy is supplied, is the original retrievable? The standard contemplates copies. What matters is that the original remains available and the copy is unaltered, apart from the delivered quantity, which the standard allows to be replaced by the actual partial quantity supplied.
For 3.2: who exactly is the second signatory going to be? Name the role.
Reading the certificate
Check the type field first, because a 2.2 and a 3.1 both look like a certificate with numbers on it, and substituting one for the other is the most common documentation failure.
Then the specification and grade against your PO, including any dual certification. Then the chemistry and mechanical properties against the limits in the governing material specification and any further limits your PO or a service standard adds, which is where those limits legitimately come from. The material specification and the service determine which elements matter: for sour service, acceptance criteria come from ISO 15156 (oil and gas production, including gas sweetening) or ISO 17945 (refining) for the actual material and service conditions, and hardness is one of several parameters, not the only one.
Then the identifier, and whether it ties to something on the product.
Genuinely wrong things, and things that only look wrong
A certificate whose type field does not match the PO is wrong. A certificate for a specification or grade you did not order is wrong. A product you cannot tie to its document by any identifier is wrong.
A certificate that covers more than one size, or a date range, is not automatically wrong. The test unit comes from the product specification and the order, and a single document may legitimately cover several supplied items where the controlling specification allows it. What matters is whether the item in front of you belongs to the stated test unit.
An electronic certificate without a wet signature or stamp is not automatically wrong either. The standard allows validation by the responsible person, with name and position, and permits electronic retention and transmission. A wet-ink requirement is a reasonable company policy, and you should present it as such.
Writing it on the purchase order
Put the document type on the line item, not in the general conditions, and separate what the standard gives you from what you are adding:
EN 10204:2004 Type 3.1 inspection certificate required, issued by the component manufacturer, supplied with the goods. State a traceability identifier on the certificate and make it identifiable on the product or its packaging. Where a copy is supplied, the original to remain retrievable on request.
If your project needs individual heat marking on each component, add it as an explicit clause and expect it to be priced, because it is an additional requirement rather than a default.
Where this sits against Malaysian requirements
Where the component goes onto plant requiring a Certificate of Fitness under the Occupational Safety and Health (Plant Requiring Certificate of Fitness) Regulations 2024, the material documentation forms part of the evidence you hold. It is part of that evidence, alongside product marking, controlled traceability records, positive material identification where required, and the design verification documents the Regulations themselves prescribe in defined cases.
No regulation names “an MTR” as a universal requirement for every component. The documentation lets you answer, when asked, that the material in the line is the material specified.
Source: EN 10204:2004, Metallic products — Types of inspection documents. Provisions on intermediaries, specific inspection and validation as summarised from the published standard; confirm against the standard text or BSI for contractual use.
