At a glance
- Which process family you use (DED-arc, DED-LB, PBF-LB, PBF-EB) does not change the category, but it does change what evidence is realistic and which document you can point to as your qualification framework.
- On a fully printed part there is no joint you can point at — there is only joint. My reading: Annex I point 3.1.2 then applies to the entire part.
- Where no harmonised standard exists for approving personnel, PED Guideline F-06 gives the way out: point to an existing document or draw up a specific one, covering four mandatory elements.
- NDT is the underestimated cost: an as-built surface is poorly suited to ultrasonic testing, and critical surfaces are machined in practice to make them inspectable.
Which AM process you use changes the legal question
Most of what is written about the PED and additive manufacturing tacitly concerns WAAM. That is not harmless: of the three process families, WAAM is the only one in which the part is unmistakably deposited weld metal. For a powder bed process or binder jetting that argument largely falls away, and your route then looks different.
| Process | Feedstock | What that does legally | Operator qualification |
|---|---|---|---|
| DED-arc (WAAM) | Welding wire — a welding consumable within the meaning of Guideline G-10 | The part is entirely deposited weld metal. Point 3.1.2 on permanent joining is most obviously engaged here, and the wire trap below applies in full | ISO/ASTM 52926-5 |
| DED-LB (laser, wire or powder) | Wire or powder | The same reasoning as DED-arc where wire is used. With powder the feedstock is not a welding consumable, but the result is still fused metal | ISO/ASTM 52926-4 |
| PBF-LB (laser powder bed) | Metal powder | A melting process, but no two parts are joined. Point 3.1.2 is arguable and defensible, yet less self-evident; the guidelines on welding consumables do not apply | ISO/ASTM 52926-2 |
| PBF-EB (electron beam powder bed) | Metal powder | As PBF-LB. Note in addition the vacuum environment and the higher build temperature: those belong to the process window and therefore to the material data | ISO/ASTM 52926-3 |
| Binder jetting + debinding and sintering | Metal powder with a binder | Not a melting process. This sits closer to powder metallurgy than to welding; point 3.1.2 is hardest to sustain here. Sintering shrinkage is a control question of its own | no dedicated part in the 52926 series |
| Cold spray | Metal powder | A solid-state process without melting, usually building up on an existing part. Almost always a repair discussion, not a new-build discussion | no dedicated part in the 52926 series |
Question 4: process, personnel and NDT
Does point 3.1.2 apply to the whole part?
Annex I point 3.1.2 requires permanent joints and the adjacent zones to be free from surface and internal defects, and requires both the joining procedures and the personnel to be approved. In WAAM the entire part is deposited weld metal. There is then no joint you can point at — there is only joint.
My reading: point 3.1.2 then applies to the whole part. That is the conservative and defensible reading, and it is the reading that will not get you into an argument with a notified body. It is expressly not legal text and not a guideline — the Working Group Pressure has not pronounced on this. Support for the direction comes from Guideline F-05: points 3.1.2 and 3.1.3 apply to permanent joints other than welded ones as well, including brazing, expansion, gluing and riveting. The criterion is the definition in Article 2(13), not the process.
There is no harmonised standard — and the directive has an answer for that
This is the part systematically skipped in AM discussions. PED Guideline F-06 describes exactly what you do when no harmonised standard exists for the approval of personnel carrying out permanent joining: the manufacturer refers to an existing document — a draft standard candidate for harmonisation, a professional document, a guide, a document from a recognised third-party organisation or notified body, or a company document — or draws up a specific document himself. That document must define at least four things:
- the equipment to be used by the personnel;
- the degree of automatisation of the process and the operations the personnel actually carry out;
- the conditions for making the test piece and the results to be achieved;
- the range of validity and the conditions for the duration of that validity.
For DED-arc that fits without strain: ISO/ASTM 52926-5:2023 deals specifically with the qualification of operators for DED-arc and is precisely the "existing document" F-06 has in mind. The degree of automatisation is not mentioned by accident — in WAAM the difference between an operator who adjusts a path plan and an operator who presses start is a difference in range of validity.
On the procedure side the counterpart is a build process qualification instead of a WPQR for a single joint: the same principle, but the range of validity is expressed in build parameters and build directions rather than in plate thickness and welding positions.
From category II the approval of procedures and personnel must come from a notified body or a recognised third-party organisation; from category III that also applies to the personnel carrying out non-destructive testing (point 3.1.3), and that approval can come only from a third-party organisation recognised by a member state.
NDT is the underestimated cost
- An as-built AM surface is wavy. Ultrasonic testing that is straightforward on a rolled or machined surface becomes unreliable there: coupling varies and the sound path is no longer unambiguous.
- The acceptance levels of ISO 5817 were written for welded joints between parts, not for a fully deposited volume. They are not applicable one-to-one; you will have to justify per defect type which criterion you apply and why.
- Critical surfaces are therefore machined in practice to make them inspectable. That is a design decision with a price: extra material in the build, extra machining time, and sometimes a thicker wall than the strength calculation requires.
- Put that machining in your quotation. In the quotations I see it is not there, and the discussion about it then arrives at the worst possible moment: after the part has been built.
Frequently asked questions
Does point 3.1.2 on permanent joining apply to a fully printed part?
That is a question of interpretation; the Working Group Pressure has issued no guideline on it. My reading is that point 3.1.2 applies to the whole part, because in WAAM it consists entirely of deposited weld metal. Support for that direction comes from Guideline F-05, under which points 3.1.2 and 3.1.3 apply to non-welded permanent joints such as brazing, expansion and gluing as well: the criterion is the definition in Article 2(13), not the process.
Do I have to qualify my operators when no harmonised standard exists?
Yes. Annex I point 3.1.2 requires approval of both the procedures and the personnel for permanent joining, whether or not a standard exists for it. PED Guideline F-06 sets out what to do when it does not: you refer to an existing document or draw up a specific one yourself, covering at least the equipment, the degree of automation, the test-piece conditions and the range of validity. For DED-arc, ISO/ASTM 52926-5:2023 is such an existing document. From category II that approval must come from a notified body or a recognised third-party organisation.
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The qualification requirements hang off the category: from II a notified body or recognised third-party organisation, from III also for the NDT personnel. The free check gives you the category in a minute.
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