Which fire rule actually binds, market by market

Italy names the furniture, then takes it back for existing hotels

Italy is the one market of the four whose fire-prevention rule for hotels names the furniture directly. The decree of 9 April 1994 sets out the technical rule for tourist-hotel accommodation, and its punto 6.2 lists what the installed materials have to be. Letter e) is one line: "i mobili imbottiti ed i materassi devono essere di classe 1 IM." Upholstered furniture and mattresses, class 1 IM.

It does not stop at a class. The paragraph closing punto 6.2 requires the materials in the preceding letters to be "omologati ai sensi del decreto ministeriale 26 giugno 1984", so the Italian obligation runs through a named type-approval regime.

Now the part that is missing from every supplier page that quotes the class. The decree's Titolo II, which covers accommodation over twenty-five beds, splits into new-build and existing properties. For existing properties, article 19.2 reads in full: "È richiesto il rispetto del punto 6.2 con esclusione della lettera e) relativamente ai mobili imbottiti." Compliance with 6.2 is required, excluding letter e), and letter e) is the upholstered-furniture class.

So "Italy requires Classe 1 IM" is the new-build rule quoted as if it were the whole rule. On a refurbishment of an existing property the decree itself lifts it, and whether it still applies to your project is then a question about the contract and the fire-safety file. Ask which one you are before pricing the testing.

France switches its decoration articles off inside the bedroom

The French rule everyone quotes is an M-class, and M-classes are a classification of materials and decoration. Where they bite in a public building is the arrêté of 25 June 1980, the règlement de sécurité for établissements recevant du public, whose articles AM 4 to AM 14 cover interior fittings, coverings and hangings.

Hotels are ERP type O, and type O has its own article about those fittings. Article O 10, in force since 1 January 2012, says: "les articles AM 4 à AM 7 et AM 9 à AM 14 ne sont pas applicables à l'intérieur des chambres et des appartements." Inside the rooms and apartments, those articles do not apply.

What survives is the furniture. The derogation reaches AM 4 to AM 7 and AM 9 to AM 14, and does not reach Section IV, gros mobilier et agencement principal, which runs from AM 15 to AM 19. Article AM 18, in its version of 4 November 2023, requires that "les matériaux constituant les sièges non rembourrés et les structures de sièges rembourrés doivent être de catégorie M3", with wood or wood derivatives of 9 mm or more accepted, and that "les sièges rembourrés doivent satisfaire aux deux critères définis dans l'instruction technique relative au comportement au feu des sièges rembourrés."

Read that carefully, because it is not the rule the market repeats. The frame is M3, which is a lower category than M1. The upholstery is not given an M-class at all: it answers to the two criteria of an instruction technique. A French specification that simply says "M1" for guest-room seating has named a classification the arrêté does not ask of that object.

The German accommodation ordinance does not mention furniture

The Muster-Beherbergungsstättenverordnung is the model ordinance for the construction and operation of accommodation buildings, issued by the Fachkommission Bauaufsicht of the Bauministerkonferenz and adopted by the Länder. Its §1 is one sentence: "Die Vorschriften dieser Verordnung gelten für Beherbergungsstätten mit mehr als 12 Gastbetten." More than twelve guest beds.

Its sixteen paragraphs cover escape routes, load-bearing walls and columns, partition walls, corridors, doors, emergency lighting and power, alarm and fire-detection systems, accessible guest rooms, keeping escape routes clear, the fire-safety order, additional building submissions, existing premises and penalties. Search the May 2014 text for Polstermöbel, Matratzen, Vorhänge, Einrichtungsgegenstände, schwerentflammbar or DIN 4102 and it returns nothing, which is the shape of an ordinance written about the building.

The one paragraph that opens a door is §10, Weitergehende Anforderungen, and it is also one sentence: "An Beherbergungsstätten in Hochhäusern können aus Gründen des Brandschutzes weitergehende Anforderungen gestellt werden." Accommodation in high-rise buildings, and nothing else.

None of which means a German project will not ask for a fire rating on its upholstery. Many do. It means the request is arriving from the specification, the insurer or a condition attached to the building approval, and those are three different authors with three different appetites for negotiation. Worth finding out which one wrote the line before treating it as law.

The 1988 Regulations are written about the home

Britain's statutory instrument on furniture flammability is the Furniture and Furnishings (Fire) (Safety) Regulations 1988. Regulation 3 scopes it: "furniture of any description which is ordinarily intended for private use in a dwelling", together with a list that names beds, divans, sofa-beds, children's furniture, cots, cushions, high-chairs, mattresses and pillows, plus outdoor furniture that is also suitable for use in a dwelling. Bedding and floor coverings sit outside it.

That scoping is why the contract world has a separate document at all, and why the thing a UK specification names for a hotel is a standard rather than a regulation. What that standard requires, and the fact that compliance with it takes the form of a manufacturer's declaration supported by evidence on the composite, are set out on our fire-rated upholstery page and are not repeated here.

Is the name in your specification a law, a standard, or an organisation?

Specifications mix the three freely, and the mixing is where arguments start. A law is an instrument with a jurisdiction and a commencement date, like the four above. A standard is a document published by a standards body, which becomes binding only when something else points at it: a regulation, a contract, an insurer, or a brand book. An organisation is neither, however often its initials appear beside the other two.

UKCA is worth checking against its own source, because it turns up in this conversation constantly. The UK government's guidance describes the UKCA and CE regimes as spanning "over 20 product types, including goods known in the EU as 'new approach goods', and additional sectors such as aerosols and rail", and furniture is not named anywhere in that guidance. The same page records that legislation in force permits the UKCA marking to be placed on a label or an accompanying document "until 11pm on 31 December 2027".

The practical form of the question is short. For each standard named in your specification, ask which of the three it is, and who is the party actually requiring it. On a hotel project the answer is more often the brand book or the insurer than the statute, and those are the two you can hold a conversation with while the specification is still open.

What this changes about how the clause gets written

A fire clause that names a class and a market is doing half the job. A clause that names the class, the instrument behind it, and whether the property is new-build or existing can be priced without a phone call, because the three things that move the testing bill are all in it.

For the same reason it is worth writing the hazard position for public areas separately from the guest room. Three of the four regimes above treat the two differently, and a single line covering the whole property resolves to the higher reading every time it is quoted.

When a specification reaches us with a fire standard named in it, the build-up is specified to meet that standard and the evidence is issued against the build-up that was approved. Send the fire clause with the fabric schedule and both come back answered together, in writing.