Regulatory frameworks and technical protocols for the reuse of structural steel in the Circular Economy: towards a CE Marking pathway

The transition to a circular economy in the construction sector demands a comprehensive reassessment of regulatory and technical frameworks governing the reuse of building products, particularly structural steel. This paper examines the evolving European normative landscape, with specific reference to Regulation (EU) 2024/3110 on construction products and the recently published technical specification CEN/TS 1090-201:2024, which for the first time introduces harmonized provisions for the reuse of structural steel components. Building upon the four attestation protocols established by the CEN/TS and the complementary French Recommandations Professionnelles, the research proposes two additional protocols, Protocol E (reuse with downgrading) and Protocol F (refunctionalisation), designed to broaden the operational scope of steel recovery beyond the boundaries imposed by current standards. The paper further investigates the pathways for achieving CE marking of reclaimed structural steel, identifying the European Technical Assessment (ETA) procedure, via the development of an appropriate European Assessment Document (EAD), as the most viable current route. A proposed framework for the essential characteristics, assessment methods, and Factory Production Control plan is presented, drawing on analogies with existing EADs for recycled construction products. The paper concludes by identifying critical regulatory gaps, including the absence of provisions for seismic zones and the lack of harmonized technical specifications for non-structural applications, and calls for coordinated European action to fill these lacunae.