Does my hotel follow the 1994 decree or the 2015 Fire Code?

In short. For Italian hotels with more than twenty-five beds there are two routes, and neither has been repealed: the traditional technical rule of the decree of 9 April 1994, or the Fire Prevention Code of the decree of 3 August 2015 with its vertical rule for accommodation premises. They are alternatives and they do not mix. For upholstered furniture both routes end at the same document — Class 1 IM — but not for everything else, and not in the same rooms. Which route applies to your site is stated in the technical report filed with the fire authority, not in the furniture specification.

Why there are two routes, and why neither has been repealed

The technical rule for tourist accommodation premises is the ministerial decree of 9 April 1994. It is organised in parts: Part II covers premises with more than twenty-five beds, Part III those with up to twenty-five, Part IV mountain refuges. It is thirty years old and works by prescription: it says what to do, not why.

In 2015 came the Fire Prevention Code, the decree of 3 August 2015, which reasons the other way round: it sets objectives, measures risk and leaves the designer to choose the solutions. The Code has a horizontal part that applies to everything and vertical rules for individual activities. The one for accommodation premises is section V.5, introduced by the decree of 9 August 2016 and then replaced in full by the decree of 14 February 2020, published in the Official Gazette on 6 March 2020. This is already the first place where many documents are out of date: anyone citing "the 2016 decree" is citing a text that is no longer the one in force. Article 2 of the 2020 decree makes clear that the realignment does not force premises already designed under the earlier vertical rules to be brought up to date.

The decisive step is the decree of 12 April 2019, in force since 20 October 2019. It rewrote article 2 of the Code, listing the activities the Code applies to — among them number 66, hotels and accommodation premises, excluding campsites and mountain refuges — and introduced an article 2-bis that preserves the option of applying the traditional technical rules instead. For many activities that decree closed the double route. For hotels it did not. Anyone telling you that "only the Code counts now" is applying to hotels a rule written for others.

The two routes are alternative, not complementary. You do not take compartmentation from 1994 and reaction to fire from the Code: once a route is chosen, it is followed through.

How to tell from the documents which route your site is on

You do not need the text of the standards. You need two pages of the fire file. The technical report attached to the notice of commencement, or to the design submitted to the fire brigade command, states in its opening lines which regulatory framework it is built on. From there the language changes in a way you can recognise.

On the 1994 route you read clause numbers — 6.2, 19.2 — roman-numbered parts, and reaction-to-fire classes written as 0, 1, 2 and 1 IM.

On the Code route the vocabulary is entirely different: the activity is "profiled" with risk levels for life, property and the environment; spaces are coded by use, with type TC areas for sleeping accommodation; the building is classified by number of beds, from PA to PE, and by fire-fighting height, from HA to HE; the safety measures carry codes from S.1 to S.10, and reaction to fire is S.1, expressed in material groups from GM0 to GM4.

If you find the two families of codes mixed in the same document, flag it to the fire engineer before anything goes into production. It may be a leftover from a copied report, or a file that needs correcting. Either way it is not the furniture supplier's call — but it is the furniture supplier who pays for the delay.

What actually changes for the furniture, and what does not

Here is the part almost nobody writes, and the reason to have read this far.

For upholstered furniture the two routes arrive at the same place. The 1994 decree, at clause 6.2, requires upholstered furniture and mattresses to be Class 1 IM and type-approved under the decree of 26 June 1984. The Code, in section V.5, requires upholstered furniture and curtains in sleeping areas to belong to material group GM2. And GM2 is not a new class: in table S.1-5 of the Code, the one covering furnishings, group GM2 for upholstered furniture is written as Italian class 1 IM, with the Euroclass column marked not applicable — because Euroclasses do not exist for upholstery, which we have written about separately. The same table assigns class 2 IM to group GM3 and places non-combustible materials in group GM0.

The practical consequence: the document that comes with a sofa, an armchair or a mattress does not change with the route. It is always the Class 1 IM type-approval, covered in the guide to Class 1 IM furniture.

What changes is everything around it, and where. The 1994 decree governs finishes room by room with a blunt rule: in lobbies, corridors, stairs and passages, class 1 materials may not exceed fifty per cent of the total surface, and the remainder must be class 0; in other rooms floors may be class 2 and other finishes class 1. The Code instead concentrates the stricter requirement on sleeping areas and, outside them, allows timber wall and floor finishes even in group GM4, up to twenty-five per cent of the gross internal surface of the escape routes or of the room.

For a contract furniture supplier this means one thing, and it matters: on the sofa the answer is the same either way; on wall panelling, joinery and timber finishes in the public areas it is not. There the check must be made against the right route, and made before the material is bought.

New or existing: the line that changes the quotation

There is a distinction inside the 1994 decree that is worth money and is often missed. Clause 6.2 applies to new premises. For existing premises, clause 19.2 repeats the same requirements but leaves out precisely the sub-clause on upholstered furniture. Refurbishing an existing hotel and furnishing a new one are not the same job, and the difference must be checked before quoting, not after.

For the rest of the bedroom the official position is settled. A note from the central directorate for fire prevention dated 23 February 2000 clarified that pillows, divan bases and bed linen are not required to demonstrate Class 1 IM, although they count towards the room's fire load — the subject of the guide to pillows and bedding; and a note of 10 May 2001 exempted rugs, pictures and similar objects from classification, on the single condition that they do not reduce the capacity of the escape routes.

The date nobody checks: the five years of a type-approval

Whichever route applies, the type-approval under the decree of 26 June 1984 — later amended, among others, by the decree of 3 September 2001 — is valid for five years. It is renewable on the manufacturer's application without repeating the tests, provided the product has not been modified. Any modification voids it.

On a hotel site this becomes a calendar problem rather than a technical one. A contract that slips by a year can reach the filing date with an expired type-approval, or with a covering changed mid-project that has voided the one held for the prototype — which is why there is a guide to reupholstery and fire certificates. The check to run at order stage is trivial and almost nobody runs it: date the type-approval was issued, expected filing date, and the combination of materials actually tested.

What to ask, and who to ask

Three written questions, addressed to the fire engineer and not to the general contractor, before anything goes into production.

• which framework the file is built on: the decree of 9 April 1994 or the Code with section V.5;
• whether the premises are treated as new or existing;
• for each room that will receive furniture, what reaction-to-fire performance the report requires — not "the compliant one", but the class or the group written in the document.

With those three answers the certificate list closes in half a day. Without them it closes at handover, which is the worst possible moment. Which documents must arrive with the furniture is covered in the guide to documents; how to write the specification clause that makes them enforceable, in the guide to specifications.

How we work

On a hotel contract the most valuable thing is time, because a compliant, certified product delivered on schedule is a hotel that opens and starts earning. That is why we ask which route the file follows ourselves, in writing, at the beginning and not at the end: it is one email that costs five minutes and saves finding out at handover that a wall panel needed a different certificate.

If it helps, we can read your site's fire report with you and tell you what is needed piece by piece: the contract page explains how we work, and you can write to us from the contact page.

Frequently asked questions

Has the Fire Prevention Code replaced the 1994 decree for hotels?

No. The decree of 12 April 2019, in force since 20 October 2019, removed the double route for many activities but introduced article 2-bis, which preserves the alternative for activities that have a traditional technical rule — hotels among them. You choose one route and follow it through.

If the design follows the Code, does my sofa need a different certificate?

No. In table S.1-5 of the Code, group GM2 for upholstered furniture corresponds to Italian class 1 IM, the same class the 1994 decree requires. The document is the same: type-approval under the decree of 26 June 1984.

Can I take some requirements from 1994 and others from the Code?

No. The two routes are alternative, not complementary. A report that mixes them should be corrected before the order is placed.

My hotel has twenty rooms. Which rule applies?

It depends on beds, not rooms. Above twenty-five beds you fall under Part II of the 1994 decree or section V.5 of the Code; up to twenty-five you remain under Part III, and section V.5 does not apply. The exact figure is in the fire file.

Who decides — the designer, the contractor or the supplier?

The fire engineer, who signs the report and carries the responsibility for it. The furniture supplier executes that choice, and should insist on having it in writing.

Talk to us The contract division

This page cites the Italian ministerial decrees of 9 April 1994, 3 August 2015 (the Fire Prevention Code, chapter S.1 and table S.1-5), 9 August 2016 and 14 February 2020 which replaced it, 12 April 2019, 26 June 1984 and 3 September 2001, together with two notes of the central directorate for fire prevention dated 23 February 2000 and 10 May 2001. Which framework applies to your hotel, and with what detailed requirements, is a matter for the fire engineer who signs the file: this page is not a substitute for the fire design or for professional advice.