Is my fire certificate still valid?

In short. The Italian reaction-to-fire type-approval under the decree of 26 June 1984 is valid for five years and renewable on the manufacturer's application, without repeating the tests, provided the product has not been modified. Any modification makes it lapse, immediately and by itself. The document that travels with the piece is not the laboratory test report: it is the conformity mark or the declaration of conformity to the approved prototype, and it must state five precise things. Anyone buying contract furniture should look at them at order stage, not on delivery.

What a type-approval actually is, and what it is not

The type-approval does not certify your sofa. It certifies a prototype. The manufacturer has one example tested in a laboratory, built in a precise way with a precise covering and a precise filling; the laboratory issues the test certificate; the Ministry of the Interior, on the basis of that certificate and the technical sheet, authorises reproduction of the prototype (article 8 of the decree of 26 June 1984). From then on the holder of the approval is liable, in civil and criminal law, for production conforming to the prototype.

That distinction changes everything. The piece that arrives at the hotel has not been tested: it has been declared to conform to something that was. The whole documentary chain exists to hold those two objects together, and it breaks at the point where someone changes a component without saying so.

The five years, and why they are a calendar problem

Article 9 is one line: the type-approval is valid for five years and renewable on expiry at the manufacturer's request. Renewal is straightforward — the tests are not repeated, provided the test methods have not changed and the manufacturer declares the material unmodified — but it has to be asked for. A type-approval does not renew itself.

On a hotel contract this becomes a question of timing rather than of technique. Months often pass between the quotation and the filing of the fire file, sometimes more than a year; and the document that was valid when you chose the model may not be on the day it is needed. It almost never happens through negligence: it happens because nobody along the chain has been given the explicit job of looking at that date.

What makes a type-approval lapse

Three things, and the first is the one that bears directly on anyone buying made-to-measure furniture.

• Any modification to the material. The lapse is automatic: no act is required and no notice arrives. A covering changed mid-project, a filling substituted because the first one did not turn up, a different stitching — the approval covered the other product.
• A new classification rule that annuls or amends the one in force. That ends use in production; material already installed remains subject to whatever the relevant fire-prevention provisions require.
• Revocation by the Ministry, where checks show the material to be of a class other than the approved one, or at variance with the prototype.

The first point is why reupholstering is not a cosmetic matter, which we cover at length in the guide to reupholstery and fire certificates.

What has to be written on the mark

The conformity mark is applied by the manufacturer to the material, permanently and indelibly, and must state five things:

• the manufacturer's name or distinctive sign;
• the unique commercial name of the approved product — unique meaning the manufacturer may not use that name for other products;
• the year of production;
• the reaction-to-fire class;
• the details of the type-approval, or of the certificate in an article 10 case.

Where the mark cannot be applied, the manufacturer certifies the same data in a separate certificate. In every case the product travels with the declaration of conformity to the approved prototype, signed by the manufacturer. And there is a step almost nobody knows about: the seller too must declare, under its own civil and criminal responsibility, that the material it sells comes with that declaration, and state its details. A chain of resellers that merely forwards the manufacturer's PDF has not done what the decree asks of it.

Article 8 or article 10: two different instruments

A document headed "certification" sometimes arrives and gets treated as equivalent to a type-approval. It is not. Article 10 covers specific cases: construction products not subject to CE marking, materials already installed, materials for specific uses, materials for uses limited in time — where the certificate runs for six months — and materials of limited production, meaning one-off pieces made to order for a single identified premises.

That last case is worth knowing, because it genuinely occurs in contract work: a unique piece designed for one hotel may legitimately take that route rather than series approval. But then the document is that one, it has to be asked for by that name, and it holds for that premises: it is not an approval that can be reused on the next project. The question of a document referring to an end use other than yours is covered in its own guide.

The four checks to run at order stage

They take ten minutes and are done once, at the order, not on delivery.

• The date. Date of issue plus five years, set against the expected filing date of the fire file. If expiry falls first, ask the manufacturer in writing whether renewal has been applied for.
• The combination. The document must refer to the covering and the filling you have chosen, not to a family of products. This is where most projects stall.
• The commercial name. The one on the mark must match the one on the order. A different name is a different product until somebody shows otherwise.
• Variants already agreed. If the specification allows a fabric variant on the approved sample, that variant has to be resolved before production, not after.

Which documents must arrive with the furniture, one by one, is in the guide to documents; how to write the specification clause that makes them enforceable, in the guide to specifications. Which class is actually required, and on which regulatory route, is the subject of the guide to the 1994 decree and the Code.

How we work

We check the approval date and the tested combination ourselves at order stage, before production, because we make the piece and know its components. It is a check that costs nothing to someone who holds the documentation in house, and becomes expensive once the chain stretches between manufacturer, reseller and installer.

On a hotel contract the most valuable thing is time: a compliant, certified product delivered on schedule is a hotel that opens and starts earning. A line on a certificate that does not match, discovered at handover, costs weeks — because documenting it afterwards means tracing the batch, the covering and the tested combination, and sometimes means a fresh test. The contract page explains how we run a project, and contact reaches the people who run it.

Frequently asked questions

How long does an Italian fire type-approval last?

Five years. Article 9 of the decree of 26 June 1984 provides that the type-approval is valid for five years and renewable on expiry at the manufacturer's request. Renewal does not require repeating the tests, provided the test methods have not changed and the manufacturer declares that the material has not been modified.

What makes a type-approval lapse?

Any modification to the material makes it lapse automatically. It also ends where a new classification rule annuls or amends the one in force, and the Ministry may revoke it if checks show the material to be of a different class or at variance with the approved prototype.

What has to be written on the conformity mark?

The manufacturer applies it to the material permanently and indelibly, and it states the manufacturer's name or distinctive sign, the unique commercial name of the approved product, the year of production, the reaction-to-fire class, and the details of the type-approval or certificate. Where the mark cannot be applied, the manufacturer certifies the same data in a separate certificate.

What is the difference between type-approval and certification?

The article 8 type-approval authorises series reproduction of a prototype tested in a laboratory. The article 10 certification covers different cases: materials already installed, specific uses, uses limited in time, limited production runs, and construction products not subject to CE marking. They are two different instruments, not two names for the same thing.

Does the reseller have to sign anything?

Yes. Every seller must declare, under its own civil and criminal responsibility, that the material it sells comes with the declaration of conformity to the approved prototype, and state the type-approval details. Forwarding the manufacturer's document unchanged is not what the decree asks for.

Talk to us The contract division

This page cites the Italian ministerial decree of 26 June 1984, “Classification of reaction to fire and type-approval of materials for fire prevention purposes”, and in particular articles 8, 9 and 10 and the annex provisions on the conformity mark and the declaration of conformity. The decree has been amended several times, among others by the decree of 3 September 2001. The procedures described here are those of the decree in the text consulted: for an individual case what governs is the document for that product and the assessment of the professional who signs the fire file. This page is not a substitute for that advice.