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EN 10204 3.1 vs 3.2 material certificates and PMI testing

How inspection certificates differ from a declaration of compliance, when a 3.2 independent witness is really required, and why a handheld XRF check is not a substitute for a carbon analysis.

EN 102043.13.2PMIXRF

Short answer: EN 10204 classifies the document the mill or foundry issues with the material. Type 3.1 is the usual commercial requirement for industrial valves: test results from the actual heat, validated by the manufacturer’s own authorised inspection representative. Type 3.2 adds an independent inspector’s validation. It is not automatic. Portable XRF is a useful on-site check of alloying elements; it cannot confirm carbon, and it is not a material certificate.

By Kevin Lyu (吕中国), ValveWitness Inspection, Ningbo · Published 2026-11-14

In our sample report: Section 2 lists material test certificates to EN 10204 3.1 as required. The MTC for heat no. H2611-07 was not available on site, so documents are PENDING. Section 12 is an optional PMI check with portable XRF: the stem is consistent with 13Cr, the seat overlay with a CoCr (Stellite 6 type) alloy, and the body with carbon steel. The report states that carbon is not measured by XRF. See the sample report.

EN 10204 document types

The current widely used edition is EN 10204:2004. The type number describes the document, not the quality of the steel.

TypeWhat it isBased on which tests?Who validates it?
2.1 Declaration of compliance with the orderA statement that the products meet the order. No test results are attached.None shownThe manufacturer
2.2 Test reportA statement of compliance plus test results.Non-specific inspection — results from the same product type, not necessarily from the pieces you are buyingThe manufacturer
3.1 Inspection certificateA statement of compliance plus test results from the delivered lot or heat.Specific inspection of the actual products (or the heat/lot they come from)The manufacturer’s authorised inspection representative, independent of the manufacturing department
3.2 Inspection certificateAs 3.1, plus independent confirmation of the tests.Specific inspection of the actual products (or the heat/lot they come from)The manufacturer’s authorised representative and an inspector designated by the official regulations or by the purchaser

A 3.1 certificate is only as useful as the heat it refers to. If the certificate cannot be tied to the valve on the floor, it does not support that valve.

Heat-number traceability from the MTC to the body

On a typical steel valve, the foundry or forge marks a heat (melt) number on the body. That number should appear on the material test certificate, together with the specified grade (for example ASTM A216 WCB) and the chemical and mechanical results for that heat. The inspector checks three things that often come apart in practice:

  1. The heat number cast, stamped or etched on the body is legible (see also MSS SP-25 vs EN 19).
  2. A 3.1 (or 3.2, if specified) certificate for that exact heat is on site, or is submitted before release.
  3. The grade, heat treatment and any supplementary requirements on the certificate match the purchase order.

In the sample report the body mark H2611-07 was present, but the certificate for that heat was not. The marking section can still be “OK (MTC pending)” while the documents section is PENDING. That is deliberate: the inspector reports what was seen, and does not convert a missing certificate into a silent pass.

When a 3.2 certificate is actually required

Type 3.2 is a 3.1-style inspection certificate that has also been validated by an inspector designated in official regulations or named by the purchaser — typically a purchaser’s inspector or an independent inspection body attending the material tests or reviewing them under agreed procedures.

It is required when the contract, the end-user specification, or the applicable regulation says so. It is not the default for every industrial valve, and it is not created by stamping “3.2” on a 3.1 form after the fact. Some pressure-equipment or energy projects require 3.2 for pressure-containing parts; many commercial valve orders are written for 3.1 only. If you need 3.2, say so in the PO before the foundry pours the heat, because the independent witness has to be arranged around the tests.

ValveWitness can, when instructed, review the certificates presented at the factory and, where the scope includes it, check that heat marks match those certificates. A 3.2 validation of mill tests is a separate appointment at the mill or foundry, agreed in advance. We do not issue material certificates of our own.

PMI: portable XRF versus OES

Positive material identification is an on-site check that the alloy in front of the inspector is consistent with the specified grade. It supports, and does not replace, the MTC.

QuestionPortable XRFOES (spark / optical emission)
Typical use on a PSIOn-site grade check of body, stem, overlay or weldWhen carbon or other light elements must be confirmed
Cr, Ni, Mo, Co (e.g. 13Cr, 316 vs 304, Stellite 6 type overlay)Yes — this is what handheld XRF is good atYes
Carbon in ASTM A216 WCB, or L-grade stainless (304L / 316L)No. Handheld XRF does not measure carbon reliablyYes — this is the usual reason to use OES
Surface effectNone, or a small cleaned patchA small burn spot that may need blending
What a “consistent with grade” result meansAlloying elements are in a range expected for the specified grade — not a laboratory certificateA more complete chemistry, still not a substitute for the MTC of the actual heat

Worked numbers from the sample report (EXAMPLE, portable XRF): the stem read about 12.4% Cr, consistent with a 13Cr grade such as ASTM A182 F6a; the seat hard-facing read about 28.6% Cr and 61.2% Co, consistent with a CoCr alloy of the Stellite 6 type; the body read residual Cr and Ni, consistent with carbon steel. That last result cannot confirm WCB, because WCB is defined with a carbon range that XRF does not measure. The same limit applies to L-grade stainless steels, whose carbon maximum is the point of the grade.

What to write into the purchase order

  • The EN 10204 type required for pressure-containing and trim materials (usually 3.1; 3.2 only if you will actually arrange the independent validation).
  • That heat or melt identification on the body must be traceable to the certificate, and that missing certificates hold the release (PENDING), not a silent pass.
  • Whether PMI is in the inspection scope, which parts are checked (body, bonnet, stem, overlay), and whether XRF is enough or carbon must be confirmed by OES.
  • That PMI results are indicative grade checks, not a substitute for the mill certificate of the actual heat.

Sources

  • EN 10204:2004, Metallic products — Types of inspection documents — sold nationally as BS EN 10204 and DIN EN 10204; see BSI
  • Our sample valve PSI report (fictitious data), Sections 2 and 12.

We report facts from the samples inspected. Standards named in these guides are public standards we work to, not certifications or accreditations we hold. We do not issue product certificates or accreditation marks. Test pressures, durations, leakage rates and acceptance numbers must be read from the licensed edition named in your purchase order; we do not reproduce copyrighted tables from the standards.

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