Do the rugs and entrance mats in a hotel need a reaction-to-fire class?

In short. For reaction-to-fire purposes a rug is not furniture: the lists of furnishing materials name upholstered furniture, mattresses, curtains, drapes and furniture fixed to the structure, and stop there. If it is fixed or recessed into the floor it becomes a floor covering, which is to say a construction product, and its class is set by the European standard. If it is loose it is neither, and there is no document to ask for: the boundary is decided by the installation, not by the catalogue.

Why the rug is not in the furnishings list

Italian fire prevention divides materials into two worlds that do not touch. On one side, construction products: anything «manufactured and placed on the market for incorporation in a permanent manner in construction works or parts thereof». On the other, materials that are not construction products, with the Italian classes 0, 1, 2 and class 1 IM.

The list of materials subject to the Italian rules is annex A.2.1 to the decree of 26 June 1984, replaced in full by article 7 of the decree of 14 October 2022. Its «furnishing materials» chapter has three entries and not one more:

• D.1 — safety curtains, drapes, curtains;
• D.2 — upholstered furniture and mattresses, tested to UNI 9175;
• D.3 — furniture fixed to structural elements.

Rugs, fitted carpet and entrance mats are not named, and the same is true of the furnishings table in the Fire Prevention Code. In October 2024, in a public discussion among fire-safety professionals opened on precisely this point, the person asking put it this way: the table «speaks of upholstered furniture, bedding, fixed and unfixed furniture, marquees for tensile structures, safety curtains, drapes, curtains, scenic material», but «not of entrance mats specifically». He had read it correctly.

Where it does appear: among floor coverings

In the same annex A.2.1, under «completion materials», entry B.4.1 is «Floors», with a reference to EN 13501-1: that is where a fixed rug ends up. In the 2024 discussion the answer the participants settled on is this: technical entrance mats, «permanently installed inside construction works», are «to be considered as floor coverings» and are found certified in Cfl-s1, that is group GM2. Checking at source confirms it: in the table of material groups for covering and completion, as replaced by the 2022 decree, a floor covering is GM1 in Bfl-s1, GM2 in Cfl-s1 and GM3 in Cfl-s2. A second contributor added the rule of thumb: «if recessed and fixed to the floor they take the form of coverings».

The fl suffix stands for flooring and says that the test is the floor test, flame spread across a walkable surface: a document declaring a class without that suffix is not a floor document.

Which class is needed, in a hotel

It depends on the rule the fire-safety design is built on, which is the designer's choice and not the supplier's: the difference between the two routes is in «Does my hotel follow the 1994 decree or the Code?».

Under the hotel technical rule of 9 April 1994, point 6.2 says two things. At letter a), in entrance halls, corridors, lobbies, stairs and passages in general «the use of class 1 materials is permitted up to a maximum of 50% of their total surface (floor + walls + ceiling + horizontal projections of the stairs)», and the remainder must be class 0 material. At letter b), «in all other rooms, floorings, including their coverings, are permitted to be class 2».

The consequence is often overlooked: that 50% is calculated over floor, walls and ceiling together, so carpet laid in a corridor takes a slice of the limit and takes it away from wall finishes and suspended ceilings. Under the Code the logic is different — a performance level is assigned to the fire compartment and the admissible group follows from the level — which is why the correct specification line is not «class 1 carpet» but a reference to the performance level in the design: how to write the furniture specification.

What changed in 2022

Until 2022 the Code table covering finishes carried two columns for each group: the Italian class and the European one. The decree of 14 October 2022 replaced it, and in the new version the column of Italian classes is gone: only the Euroclasses remain. Italian classes survive where the materials are not construction products, which is to say in the furnishings table: that is why a sofa still has class 1 IM and a floor does not. On that boundary, why a sofa has no Euroclass.

The same decree closed the door from the production side: for construction products still holding a valid Italian-class homologation, production was permitted for no more than six months from entry into force and installation for no more than twelve, two deadlines that expired in 2023. Annexes A and B to the decree of 10 March 2005 have been repealed, and for a CE-marked product the class is read from the declaration of performance. It shows in specifications a few years old: asking for «carpet homologated in class 1» means asking for a document that, for a new product, is no longer issued. What to do when the document that arrives is not the one expected is in «Furniture without fire certificates: what now».

And the loose rug, the one that rolls up?

Here the answer is in the negative. A rug that is laid down, not incorporated in a permanent manner into the works, is not a construction product, and it is not among the furnishings listed in annex A.2.1. There is therefore no class the rules demand of it, nor the certificate sometimes insisted on during an inspection. Its contribution is accounted for elsewhere: in the fire load of the room and in fire safety management, design and operational assessments rather than product documents. It is the same logic that applies to pillows and bedding under the 1994 rule.

There is one trap: a rug starts out loose and becomes fixed with hook-and-loop tape, continuous double-sided tape or a bonded installation. The moment it is bonded, it changes regulatory world and changes the document required. The installation decides, not the product: whoever writes the specification has to say how it is to be laid.

What to ask, in practice

• Of the designer, before ordering: which rule the design is built on, which class or performance level applies to the room, and whether the rug is to be fixed or laid loose;
• Of the supplier, if it is fixed: a CE-marked declaration of performance with a class carrying the fl suffix, referred to the end-use condition;
• Of the supplier, if it is laid loose: no reaction-to-fire document. If a certificate arrives anyway, read it, but do not mistake it for a compliance step;
• In the corridor: have the letter a) balance checked together with the wall and ceiling finishes. The documents to expect are listed in «Hotel furniture: which documents should arrive»;
• Always: the answer in writing. With the rooms already dressed, a dispute does not cost the price of the rug: it costs the opening date.

How we work

Brianform was founded in 1982 in Brianza and is a brand of Sibilia S.r.l., with its premises and showroom in Cantù: sofas, armchairs, tables and bespoke furniture for hotels and residences, working wood, marble, iron and upholstery in house. We take on this subject from the side we know, the furniture we manufacture ourselves, with documents referred to the finished piece in the exact combination delivered. For floor coverings the document belongs to that product's own supply chain, and the useful thing we can do is to say so early, while the specification can still be corrected. On a hotel project the most valuable thing is time: products that comply, are certified and arrive on schedule mean a fast opening, and a hotel that opens sooner starts earning sooner.

The seating is in the sofas and armchairs collections; the Contract page explains how we follow projects. Start from contact.

Frequently asked questions

Does a rug in a hotel room need a reaction-to-fire certificate?

If it is laid loose and not fixed, no: it is not a construction product and it is not among the furnishing materials in annex A.2.1 to the decree of 26 June 1984. If it is fixed or bonded, yes: it becomes a floor covering and the European class with the fl suffix is required.

Why does carpet not have class 1 IM like a sofa?

Because class 1 IM comes from UNI 9175 and covers upholstered furniture. Fixed carpet is a construction product and is classified to EN 13501-1, using the floor classes: Bfl-s1, Cfl-s1, Cfl-s2.

Does the entrance mat fall within the checks?

The technical kind, recessed and permanently installed, does: it is a floor covering and is found certified in Cfl-s1, that is group GM2. A loose, removable mat does not.

The specification asks for «class 1 carpet»: is that all right?

It is a superseded wording. Since the decree of 14 October 2022 the Code's covering table gives only Euroclasses for floors, and for products holding an Italian-class homologation the production and installation deadlines expired in 2023. The right line refers to the performance level in the design and asks for a declaration of performance.

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The regulatory texts cited on this page were read at source: Italian Ministerial Decree of 9 April 1994, point 6.2, letters a) and b); Ministerial Decree of 26 June 1984 with annex A.2.1 as replaced by article 7 of the Ministerial Decree of 14 October 2022 (Official Gazette, 26 October 2022, no. 251); articles 8, 10, 11 and 12 of that same decree, which amend the Ministerial Decree of 10 March 2005 and replace tables S.1-6, S.1-7 and S.1-8 of the Ministerial Decree of 3 August 2015; Ministerial Decree of 3 August 2015 (Fire Prevention Code), chapter S.1; Regulation (EU) No 305/2011 and Delegated Regulation (EU) 2016/364; standards EN 13501-1 and UNI 9175. Quotations attributed to professionals come from a public discussion of 9 October 2024 on the Edilclima fire-safety forum, read in full: they are professional opinions, not requirements. The choice of applicable rule, the performance level and the reaction-to-fire requirements of any individual project remain the responsibility of the fire-safety design and of the appointed professional.