As part of the EEPLIANT4 project, the European market surveillance authorities are currently stepping up their checks on solid fuel fireplaces and pellet stoves. In addition to the ecodesign requirements, the focus is particularly on EN 16510, including detailed on-site inspections during production.

The focus is on:

• Technical documentation, CE declaration and data plate
• Declarations of Performance (DoP) and instructions
• Type test reports and AoP
• Complete evidence of factory production control (FPC)
• Practical implementation of FPC in the ongoing manufacturing process

The new, comprehensive insights into production processes are increasingly revealing gaps in documentation, evidence and consistency of information.

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Our offer: WPK Audit for secure market surveillance

Our audit offer creates a reliable basis for a successful audit process and provides companies with clarity, verifiability and structure in all relevant areas.

Audit focus areas:

• Inspection of factory production control in accordance with EN 16510
• Analysis of the documentation structure and evidence
• Evaluation of process flows with regard to market surveillance requirements
• Practical quality checks, e.g. leak tests

These audits create a documented, transparent and reproducible status that meets the requirements of the authorities and provides certainty in the testing process.

As you are already aware, the coexistence phase for most standards for small combustion appliances will end on 9 November 2025. From this date onwards, only construction products based on the EN 16510 series of standards may be placed on the market.

In the magazine ‘Die Rote’, you can read an interesting interview with our CEO Christian Droll for details on the current status of the coexistence phase.

To facilitate the transition, the HKI, together with our test centre manager, Sven Müller and the technical commissioner of the European Commission, has developed a transitional arrangement: the guideline ‘NB-CPR/SG03-WG2-25/11 Guidance for a temporarily simplified transition of historical data’ from sector group SG03 WG2 offers the possibility of creating a performance assessment report based on historical type testing. This gives manufacturers more time to re-test their fireplaces in accordance with EN 16510.

Demand for performance assessment reports is currently very high – we are processing all applications at full speed so that you are covered in good time for the deadline.

If you still have construction products that are based on the old standards and require a performance assessment report in accordance with EN 16510, we look forward to hearing from you!

Would you like to find out more about Mr Droll’s interview? Here is the link to the article: ‘“Die Umstellung auf die EN 16510 ist eine Mammutaufgabe” | Die Rote

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.