Transitional regulation for the coexistence phase
On November 9, 2025, the coexistence period of the majority of norms for small fireplaces will end, meaning that only construction products based on the EN 16510 series of norms can be placed on the market. The coexistence phase concerns the norms EN 13240, EN 13229, EN 12815, EN 12809 and EN 14785.
In addition to retesting in accordance with the EN 16510 series of norms, the European construction product regulation (CPR) (EU) 305/2011 allows the use of historical data for assessment. The Group of Notified Bodies (GNB) has adopted a horizontal position paper on this matter (GNB NB-CPR/19/792r5). Furthermore, the Sector Group SW03 WG2 has developed documents with detailed guidance on the use of historical date for these products.
Due to the high number of enquiries about evaluations of historical data and new tests, it was expected that the notified bodies would be very busy. At the same time, the majority of previously notified test laboratories have not yet been notified or are not seeking notification in accordance with EN 16510. Only 17 of the former 46 testing laboratories currently exist, and many of the currently notified bodies were only recognised very late. As a result, it is almost impossible for the remaining laboratories to finalise all test reports before the end of the coexistence phase.
To find a solution to the situation, our technical head Sven Müller, as chairman of the group of European notified bodies, has developed a practice-oriented transitional regulation together with the HKI. This proposal was discussed intensively with the Directorate-General of the European Commission (DG GROW).
The transitional regulation is intended to support manufacturers in converting their products to the EN 16510 series. This regulation enables manufacturers to issue their own Declaration of Performance (DoP) in accordance with the EN 16510 series based on an Assessment of Performance (AoP) from a notified body.
The AoP report is a new document for manufacturers as part of the transition to the EN 16510 series of standards. It is the notified body’s statement of conformity to the manufacturer based on a test report in accordance with the EN 16510. As a transitional arrangement, a time-limited AoP report is created which refers to the historical test report. Based on this time-limited AoP report and your manufacturer documents, you can create your DoP during the transitional period. It is mandatory to create a complete type test report in accordance with EN 16510 and an unlimited Assessment of Performance report (AoP report) before the deadline specified in the AoP report expires. This gives manufacturers and notified bodies a longer period until the time limit expires. This means that any outstanding decisions (e.g. on the subject of assessing families of fireplaces) can be taken into account when preparing the final EN 16510 test reports. The current documents provide for a time limit until November 9, 2027.