Smoke Detector Regulations in the European Union: An Overview

Smoke detectors are covered by various EU regulations, directive, and standards. In this guide, we take a closer look at the Construction Products Regulation and various regulations and directives applicable to electronics and batteries, and how these relate to smoke detectors.

Construction Products Regulation

The Construction Products Regulation covers construction products such as “fixed fire fighting equipment”, which includes fire alarms and smoke control products, as indicated in Annex IV.

The regulation requires those products to:

a. Undergo testing to and comply with relevant harmonised standards

b. Undergo an Assessment and Verification of Constancy of Performance (AVCP)

c. Comply with labelling and documentation requirements

Standards

We found many harmonised standards that cover smoke detectors, smoke alarms, and fire detection products in general. Here are some examples of those standards:

CEN EN 54-2 – Fire detection and fire alarm systems – Part 2: Control and indicating equipment

CEN EN 54-3 – Fire detection and fire alarm systems – Part 3: Fire alarm devices – Sounders

CEN EN 54-4 – Fire detection and fire alarm systems – Part 4: Power supply equipment

CEN EN 54-5 – Fire detection and fire alarm systems – Part 5: Heat detectors – Point heat detectors

CEN EN 54-7 – Fire detection and fire alarm systems – Part 7: Smoke detectors – Point smoke detectors that operate using scattered light, transmitted light

CEN EN 54-10 – Fire detection and fire alarm systems – Part 10: Flame detectors – Point detectors

CEN EN 54-11 – Fire detection and fire alarm systems – Part 11: Manual call points

CEN EN 54-12 – Fire detection and fire alarm systems – Part 12: Smoke detectors – Line detectors using an optical beam

CEN EN 54-16– Fire detection and fire alarm systems – Part 16: Voice alarm control and indicating equipment

CEN EN 54-17 – Fire detection and fire alarm systems – Part 17: Short-circuit isolators

CEN EN 54-18 – Fire detection and fire alarm systems – Part 18: Input/output devices

CEN EN 54-20 – Fire detection and fire alarm systems – Part 20: Aspirating smoke detectors

CEN EN 54-21 – Fire detection and fire alarm systems – Part 21: Alarm transmission and fault warning routing equipment

CEN EN 54-23 – Fire detection and fire alarm systems – Part 23: Fire alarm devices – Visual alarm devices

CEN EN 54-24 – Fire detection and fire alarm systems – Part 24: Components of voice alarm systems – Loudspeakers

CEN EN 54-25 – Fire detection and fire alarm systems – Part 25: Components using radio links

EN 14604 – Smoke alarm devices

European Technical Assessment (ETA)

If your product is not fully covered by harmonised standards and you want to affix the CE marking to it, according to the requirements of the regulation you should hire a Technical Assessment Body, and obtain a European Technical Assessment (ETA).

Assessment and Verification of Constancy of Performance (AVCP)

If your product is covered by harmonised standards or an ETA has been issued for it, it should undergo an assessment and verification of constancy of performance (AVCP).

The AVCP is a series of harmonised systems used to check and ensure that products consistently meet specific standards. You can find more information about this in Annex V of the regulation.

While in some cases the manufacturer can carry out the AVCP system by itself, in other case a notified body is required.

Documentation

Below we list the key documents required by the regulation.

Title	Description
Declaration of Performance	The manufacturer is required to issue this document when their product is either covered by harmonised standards or for which an ETA has been issued. It should contain the information listed in Annex III.
Technical documentation	You must also prepare the technical documentation, which contains key information that is the basis for proving compliance and drafting the Declaration of Performance.
User instructions	You should provide user instructions and safety information with your product.
Test report	You should provide test reports that prove that your product complies with regulatory requirements and relevant standards.
European Assessment Document	A European Assessment Document (EAD) is necessary to issue a European Technical Assessment (ETA), when a manufacturer requests it.

Labelling

The regulation requires importers and manufacturers to provide the CE marking and product traceability information with their products.

Title	Description
CE marking	You must affix the CE marking if the product is covered by harmonised standards, or if an ETA has been issued for the product. You should also provide, after the CE marking, the information listed in Article 9(2) (e.g. reference number of the Declaration of Performance). The CE marking should be permanently affixed either to the product, its label, its packaging or an accompanying document.
Product traceability	Importers and manufacturers are required to provide the following information with their construction product: Product batch, serial number, or type Manufacturer name, registered trade name, or trademark Manufacturer address

RoHS Directive

The RoHS Directive restricts substances used in manufacturing electronic and electrical equipment. The directive generally requires:

• Compliance with substance restrictions as listed in Annex II (e.g. 0.1% for lead, 0.01% for cadmium)
• The provision of relevant documentation (e.g. test reports)
• Proper labelling (e.g. CE marking)

Documentation

In this section, we list the required documentation items.

Title	Description
Declaration of Conformity	The directive mandates manufacturers to issue this document, which should contain the information listed in Annex VI.
Technical documentation	The technical documentation should contain the items listed in Annex II of Decision 768/2008/EC, such as the list of applied harmonised standards and test reports.
Test report	You should provide a test report that proves product compliance with relevant substance restrictions.

Labelling requirements

Here we list the labelling requirements set by the RoHS Directive.

Title	Description
CE marking	The RoHS Directive mandates importers and manufacturers to affix a CE marking onto their electrical products, their data plate, their packaging, or their accompanying documents.
Product traceability	Importers and manufacturers need to provide traceability information such as the product’s serial number and their name and address. If they cannot put this information on the product, they should put it on the packaging or in an accompanying document.

Electromagnetic Compatibility (EMC) Directive

The EMC Directive establishes requirements for the electromagnetic compatibility of electronic equipment. This may include smoke detectors.

Standards

We were not able to find standards that are harmonised under the EMC Directive and specifically cover smoke detectors. However, standards for alarm systems and similar equipment may still apply. Here are two examples:

EN 50130-4 – Alarm systems – Part 4: Electromagnetic compatibility – Product family standard: Immunity requirements for components of fire, intruder, hold up, CCTV, access control and social alarm systems

EN 50270 – Electromagnetic compatibility – Electrical apparatus for the detection and measurement of combustible gases, toxic gases or oxygen

Documentation

Here we list the key documentation requirements.

Title	Description
Declaration of Conformity (DoC)	The manufacturer should create the Declaration of Conformity, which should contain the elements listed in Annex IV.
Technical documentation	The technical documentation should contain information that helps determine the product’s conformity with relevant requirements, such as a description of the product, test reports, and harmonised standards used. You can find the full list of required items in Annex II.
User instructions	The directive requires importers and manufacturers to provide user instructions, which should also include the necessary information for using the apparatus as intended.
Test report	Importers and manufacturers should get their products tested and subsequently provide the resulting test report as part of their technical documentation.

Labelling

Here we list the labelling requirements.

Title	Description
CE marking	The CE marking should be affixed onto the product, its data plate, or its packaging and the accompanying documents.
Product traceability	Importers and manufacturers need to provide traceability information on their products, such as: Serial number and batch number Registered trade name Postal address Contact information

Radio Equipment Directive

The Radio Equipment Directive sets electromagnetic compatibility and safety requirements for radio equipment. This may include smart smoke detectors that can send real-time notifications to your phone via Wi-Fi, or other methods. Covered radio equipment should generally:

a. Protect the health and safety of people, pets, and property

b. Be electromagnetically compatible with other devices or equipment

c. Use the radio spectrum effectively and efficiently without dangerously interfering with other radio devices

Importers and manufacturers should also provide documentation (e.g. test reports and technical documentation) and affix relevant labels (e.g. CE marking) to indicate that their products comply with the directive’s requirements.

We could not find harmonised standards that are specific for smoke detectors. However, general standards for radio equipment may apply to smart smoke detectors.

Documentation

Here we list the key documentation requirements of the Radio Equipment Directive.

Title	Description
Declaration of Conformity	Manufacturers should create a Declaration of Conformity containing the elements specified in Annex VI.
Technical documentation	The directive mandates importers and manufacturers to provide technical documentation containing the elements listed in Annex V.
Instructions and safety information	You should provide instructions and safety information with your products. For example, you should ensure that the instructions include the radio equipment’s frequency band and the maximum radio-frequency power transmitted in that frequency band.
Test report	The test report should indicate that your product complies with the directive’s requirements.

Labelling requirements

In this section, we list the key labelling requirements under the Radio Equipment Directive.

Title	Description
CE marking	You ned to affix the CE marking, and the notified body’s identification number after it (if relevant), to the radio equipment or its data plate, and its packaging.
Traceability information	Importers and manufacturers should provide information concerning the product (e.g. type, batch) and the manufacturer (e.g. name and address) on the product, its packaging, or an accompanying document.

Waste Electrical and Electronic Equipment (WEEE) Directive

The Waste Electrical and Electronic Equipment (WEEE) Directive establishes requirements regarding electronic and electrical waste products and materials, such as smoke detectors. It generally requires importers and manufacturers to:

a. Affix the separate collection symbol onto their smoke detectors

b. Provide the required information to users (e.g. how to discard your product)

c. Register in the EU member state where they sell their smoke detectors

d. Report to the applicable national authorities the quantity and type of smoke detectors they produce, distribute, and sell

e. Be responsible for collecting and treating their waste smoke detectors (e.g. via a waste management company)

Batteries Regulation

The Batteries Regulation sets requirements for batteries, including portable batteries, which are used by most smoke detectors. In this section, we focus on the requirements for this type of batteries.

Batteries should generally comply with documentation, labelling, safety, and sustainability requirements.

Standards

CENELEC lists three harmonised standards relevant to portable batteries, one of which is under drafting, and the other two are under approval:

prEN IEC 60086-1 – Primary batteries – Part 1: General

prEN IEC 60086-2-1 – Primary batteries – Part 2-1: Physical and electrical specifications of batteries with aqueous electrolyte

prEN IEC 60086-2-2 – Primary batteries – Part 2-2: Physical and electrical specifications of lithium batteries

Documentation

Importers and manufacturers should ensure they comply with the documentation requirements.

Title	Description
Declaration of Conformity	The manufacturer needs to create the Declaration of Conformity, which should contain the information listed in Annex IX.
Technical documentation	The manufacturer should also draw up the technical documentation containing the items listed in Annex VIII Part A-2.
Test reports	Manufacturers have to provide test reports as part of their technical documentation.
Instructions and safety information	The regulation requires importers and manufacturers to ensure the provision of instructions and safety information.

Labelling

Here we list the key labelling requirements set by the regulation.

Title	Description
CE marking	The manufacturer should affix the CE marking onto each battery, or its packaging and the accompanying documents.
General information	The regulation requires the manufacturer to provide the general information as listed in Part A of Annex VI (e.g. date of manufacture).
Traceability information	You should provide your product’s information (e.g. model identification and batch number) and the manufacturer’s information (e.g. name and postal address)
Separate collection information	Importers and manufacturers should make sure that they affix a separate collection symbol on the batteries. The symbol should have a maximum dimension of 5×5 cm, but if the battery is too small for the symbol, the symbol should appear on the packaging and have a dimension of 1×1 cm.
QR code	Batteries should bear an easily-readable QR code, which in turn should provide access to information such as the Declaration of Conformity.
Other labelling requirements	According to Article 13: a. Rechargeable portable batteries should bear their capacity on a label b. Non-rechargeable portable batteries should carry a label indicating: The words “Non-rechargeable”, and The minimum average duration c. Batteries containing more than 0.004% lead or 0.002% cadmium should be properly marked with “Cd” or “Pb”

Lab Testing

You generally need to get your product tested against regulatory requirements and standards so you can prove that your product is compliant. Some regulations require lab testing and the subsequent provision of a test report as part of the technical documentation. However, testing is often a practical necessity even if the regulation or directive does not explicitly mention test reports. If your product passes testing, the test report you receive would indicate product compliance.

Regulation	Lab testing
Construction Products Regulation	Smoke detectors should undergo sample testing such as performance testing to ensure that the products work as intended. Note that standards harmonised under this regulation may set specific test methods.
RoHS Directive	The RoHS Directive sets substance restrictions and mandates lab testing to ensure the product does not contain restricted substances over the permitted limits.
Electromagnetic Compatibility Directive	This directive requires products to undergo testing. For instance, smoke detectors may be subject to testing, such as: Tests for continuous and transient disturbances Tests for conducted and radiated disturbances Tests for electrostatic discharges Emission tests
Radio Equipment Directive	This directive requires you to get your product tested to ensure that it: Is safe for use around people, pets and property Is electromagnetically compatible with other devices Does not interfere dangerously with other devices with other devices
Batteries Regulation	You should get your batteries tested to ensure that restricted substances do not exceed the allowed limits. Your batteries should also undergo testing to ensure those batteries do not pose risks to human health and the environment.

Smoke detector testing companies

Here we list some companies that claim to provide testing for smoke detectors against EU requirements:

• Intertek
• TÜV Nord
• TÜV Rheinland
• Kiwa

Also, here are some examples of notified bodies designated to assess the conformity of products covered by the Construction Products Regulation:

• SGS Intron B.V.
• AKF ZERT GmbH
• CNPP CERT
• QONCERT S.r.l.
• AAA Certification AB

Additional Requirements

Here are some additional regulatory requirements that are relevant to smoke detectors.

Regulation	Description
General Product Safety Regulation	This regulation sets safety requirements for aspects of products not already covered by other directives or regulations, and thus, may have requirements relevant to smoke detectors. It generally requires: a. Proper labelling (e.g. identification of product and manufacturer) b. Provision of documentation (e.g, test reports and technical documentation) c. Lab testing
REACH Regulation	This regulation restricts substances used in products manufactured or sold in the EU, and lists those restricted substances on the SVHC and Annex XVII. Smoke detectors may contain listed substances such as phthalates in the plastic parts, and cobalt in the electronics within.

Recommended articles

• General Product Safety Regulation (GPSR): An Essential Guide
• An Essential Guide to the REACH Regulation in the EU