Do a chair's armrests and writing tablet need certifying with the chair?

In short. No rule puts armrests and writing tablets outside the scope: it is written nowhere, in either direction. What is written is that for rigid furniture the class comes from the materials the piece is made of, one by one, and that Italian type approval covers the prototype that was actually tested. An accessory bolted to the chair is one more material. The rule everyone quotes — «the frame does not count» — does exist, but it applies to upholstered armchairs, and that is where the confusion starts.

Where the question comes from

January 2025, an Italian fire-safety engineers' forum. A professional asks whether, in the certification of chairs for training rooms and conference halls with no upholstery, the armrests and writing tablets fixed to the chair must themselves be classified. From manufacturers he finds a certificate for the chair but never for the accessories; some manufacturers and dealers claim accessories fall outside the rules, and he asks whether that is written anywhere, noting that the Code's table says generically «non-upholstered chairs and seats» and does not exclude add-on components.

His colleagues give three replies and none is an answer: never having worried about accessories; accepting the certificate if it matches the model, accessories aside; rejecting instead test reports where only the covering fabric was tested. The practice is well established, and the source that would justify it is never cited. Because there is none.

What the table says, and what it does not

The relevant row of table S.1-5 of the Italian fire prevention Code reads «Furniture fixed and not fixed to structural elements (non-upholstered chairs and seats)», with Italian class 1 for GM1, 1 for GM2 and 2 for GM3, and European classification not applicable. How far that row reaches — whether the bracket narrows it to seating alone or takes in wardrobes, tables and bedside units — is disputed among professionals, and it need not be settled here: a non-upholstered chair is inside the row on any reading. The question becomes a different one: what counts as «the chair».

First, though, a very common misreading needs defusing. The long list that circulates in specifications — bookcases, tall and low cabinet units, desks, tables, counters, reception desks — sits in the query submitted to the Fire Brigade in 2020 by a company, as an interpretation it asked to have confirmed. The Department's reply of 2 September 2020 does not take it up: it offers «general guidance», refers the matter to the territorial fire-brigade offices, and states that table S.1-5 lists precisely the materials that require reaction-to-fire characteristics. Anyone looking there for a sentence about accessories will not find one, in either direction; anyone who thinks they have found it is quoting the query. Professionals make the same slip: in the forum thread two of them catch it, and one writes «I misread it».

The rule everyone quotes applies to armchairs

A Ministry of the Interior circular of 21 September 1985 identifies the characteristics that are not essential for type approval. It states that the tests classifying armchairs in classes 1 IM and 2 IM concern only the filling material, the interliner where present and the relevant covering, and that consequently the materials of the frame or support are irrelevant. It adds that the outcome does not depend on size, shape, colour or fabric pattern, which is why extensions can be issued without repeating the tests.

That rule is real and widely used. But it applies to an upholstered piece, where what burns and gets tested is the filling-interliner-covering package. On a rigid chair it turns upside down: there is no textile package to test, and what is left to classify is the material of the shell, the back, the armrest. Those who say accessories do not count are, nine times out of ten, applying to rigid furniture a rule written for armchairs.

What the circular on multi-material furniture says

For rigid furniture the right source is circular no. 7 of 18 June 2004, on the type approval of furniture fixed and not fixed to structural elements and made of several homogeneous materials: it names chairs, desks, wardrobes and school benches. Two limitations placed at the top matter more than all the rest: every single material constituting the product must be homogeneous, and homogeneity refers both to the physical and chemical characteristics of each material and to the uniformity of use and of installation where applicable. The piece is, in other words, a set of materials, each to be identified. The circular adds that these products are type-approved with the use «FURNITURE» and the intended use specified — FURNITURE (CHAIR), FURNITURE (WARDROBE) — and that the procedures apply even where surface finishes are present.

An armrest and a writing tablet are not surface finishes: they are constituent materials, and they belong inside the classification.

When the approval extends, and when it lapses

The ministerial decree of 26 June 1984 defines the material as the component, or the components variously associated, that can take part in combustion depending on its chemical nature and on the actual conditions of installation for use: the chair as supplied and used, armrests included. Article 9 states that type approval lapses automatically if the material undergoes any modification; and the declaration of conformity certifies conformity to the approved prototype, so if the tested prototype had no armrests, it does not cover them.

The 2004 circular does provide an orderly way out: a manufacturer already holding the approval of a product may request its extension to another model, if that model is made of the same homogeneous materials and has a geometry sharing with the approved product, within the range of thicknesses, the same minimum ones. If the armrest is of the same material already tested, it is paperwork, not a new test.

Three outcomes follow, all of them legitimate. The certificate covers the chair with its accessories, because they were tested with it. Or the accessory is of the same homogeneous material already approved, and an extension is requested. Or it is of a different material: the complete chair is another configuration, and the certificate for the bare chair does not cover it. What is not an answer is saying that accessories fall outside the rules.

What to ask the supplier

The useful question is not «is the chair certified?», because the answer is always yes. It is these four.

• What use is the model approved for? For rigid furniture it is «FURNITURE» with the use specified: if the certificate shows a different use, the problem comes before the accessories;
• Which homogeneous materials were tested, and in which thicknesses? This is the question that reveals whether the armrest is in or out;
• Is there an extension for the version with armrests or with a writing tablet? Ask for it alongside the main approval, not instead of it;
• Is the delivered configuration the declared one? The declaration of conformity must refer to the chair as it arrives on site, accessories fitted.

If the answers do not come, you end up in the situation described in our guide on furniture delivered without certificates. The place to ask for the complete configuration, rather than the base model, is the specification clause. To read the document you receive there is how to read a fire certificate; for why no Euroclass exists for this furniture, Euroclass and Italian class.

How we work

The question reaches us in a more concrete form: a project calls for a small armchair with a wooden armrest, or a chair with a tablet, and the specification asks for the class. At that point accessories are not up for discussion; the configuration is decided: which materials make up the delivered piece, and which document goes with it. We work wood, marble, iron and upholstery in our own workshops in Cantù, and that is what counts here: armrest and tablet do not arrive later from a third supplier, they are part of the piece from the drawing stage.

On a hotel contract the most valuable thing is time: products that comply, with the right documents, delivered on schedule mean opening fast, and a hotel that opens starts invoicing. An accessory that forces a type-approval file to be reopened once the site is running is a delay nobody budgeted for. We follow contracts as described on the Contract page; the models are in the Collections.

Frequently asked questions

Is it written anywhere that accessories fall outside the rules?

No. Neither the Code, nor the 2020 clarification, nor the 1984 decree excludes furniture accessories. Those who claim otherwise cite no source because there is none. What exists is the list of characteristics irrelevant for upholstered armchairs, a different matter.

Does the wooden armrest of an upholstered chair need classifying?

For armchairs the 1985 circular says the tests concern filling, interliner and covering, and that the materials of the frame and support are irrelevant. A structural armrest falls within that logic. The boundary moves when the piece is not upholstered, or when the accessory does not act as frame.

Can I accept the chair's certificate and ignore the accessories?

It is the most common practice, but it has no basis in the texts, and assessing the individual case is for the professional who signs the file and the competent fire-brigade command. The way to avoid the argument is to ask for the complete configuration before ordering.

If the piece is made of several materials, is a certificate needed for each?

No: the 2004 circular requires every single constituent material to be homogeneous, and the piece is classified as a set of identified materials, under one approval. A whole series of furniture may also be approved in a single step, provided all models are made with identical components.

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This page cites: table S.1-5 and chapter S.1 of the Italian Ministerial Decree of 3 August 2015, in the consolidated text published by the Fire Brigade Department; clarification ref. no. 0011297 of 2 September 2020 from the Central Directorate for Prevention and Technical Safety, read in full in both the reply and the query; Ministerial Decree of 26 June 1984, in the definitions of article 2 and in articles 8 and 9; circular no. 27 MI.SA. ref. no. 19648/4190 of 21 September 1985 on characteristics that are not essential for type approval; circular no. 7 ref. no. DCPST/A5/1968/OM/9003 of 18 June 2004 on the type approval of furniture made of several homogeneous materials. The two circulars were read in a professional collection of fire-prevention circulars, not in the ministerial original. No prices, no lead times, no approval of ours is quoted. Assessing the individual case is for the professional who signs the file and for the competent fire-brigade command.