Fire rating of curtains in ERPs: regulatory guide
The fire rating of curtains in Public Access Buildings (ERP) is defined by articles AM 11 to AM 13 of the decree of June 25, 1980, and the NF P 92-507 standard. Contrary to popular belief, M1 is only mandatory in enclosed stairwells and on stage curtains. Passageways (corridors, halls) and rooms larger than 50 m² require M2. Hotel rooms smaller than 50 m² have no regulatory obligation for an M rating for curtains.
This guide is a complete regulatory reference: the exact texts article by article, the requirements by ERP type (O, J, L, N, R, W), the categories, what the safety commission checks, and the compliance checklist before an inspection.
Legal Basis: The 3 Foundational Texts
The regulatory framework is based on the interplay of three sources:
- Decree of June 25, 1980: Fire safety regulations in ERP, Chapter III, Articles AM 1 to AM 14. Article AM 1 refers to standard NF P 92-507 for "furnishing, decoration, and large furniture materials," making this standard legally binding.
- Decree of November 21, 2002: Relating to the fire reaction of construction and furnishing products. Its Annex 2 defines the M0 to M4 classification of furnishing materials including curtains, drapes, and sheers.
- Standard NF P 92-507 (February 2004): Describes the technical criteria for M1 to M4 classification. Originally a technical standard, it gained mandatory force through explicit reference in Article AM 1.
Articles AM 11, AM 12 and AM 13: The Details
Article AM 11: The Fundamental Prohibition
§1: It is strictly forbidden to place drapes, portières, curtains, or sheers across passageways (corridors, circulation areas, emergency exits). This prohibition is absolute: no M classification makes this practice acceptable.
§2: The only exception: if fire doors are fitted with valances or curtains, these textiles must be at least M2 classified.
Article AM 12: Requirements by Location
Drapes, portières, curtains, and sheers must meet the following requirements:
- a) Enclosed stairwells: Category M1 materials (non-flammable). This is the only area where M1 is explicitly required for curtains.
- b) Other passageways and rooms with a floor area greater than 50 m²: Category M2 materials (difficulty flammable). This concerns corridors, halls, restaurants, breakfast rooms, seminar rooms, common areas larger than 50 m².
What is NOT covered by Article AM 12: Rooms smaller than 50 m² that are not passageways (standard rooms, small private lounges). In these spaces, no M class is imposed for curtains by this text.
Article AM 13: Stages and Platforms
Stage and platform curtains must be classified as M1. This requirement applies regardless of the size of the space.
The French M Classification and Euroclasses Equivalence
| French Classification (NF P 92-507) | Euroclass (EN 13501-1) | Fire Behavior |
|---|---|---|
| M0 | A1, A2-s1,d0 | Non-combustible |
| M1 | B-s1,d0 / B-s2,d0 | Non-flammable |
| M2 | C-s1,d0 / C-s2,d0 | Difficulty flammable |
| M3 | D-s1,d0 | Moderately flammable |
| M4 | E, F | Easily flammable |
The two systems coexist. A test report may mention the M classification or the Euroclass, or both. Euroclass criteria are more precise: "s" (smoke) measures smoke emission (s1 = low), "d" (droplets) measures flaming droplets (d0 = none).
Requirements by ERP Type: The Complete Table
| ERP Type | Examples | Enclosed Stairwells | Passageways (corridors, halls) | Rooms > 50 m² | Rooms < 50 m² | Stages/Platforms |
|---|---|---|---|---|---|---|
| O (Hotels) | Hotels, boarding houses | M1 | M2 | M2 | Not imposed | M1 |
| J (EHPAD) | EHPAD, nursing homes | M1 | M2 | M2 | Not imposed by AM 12 (M2 recommended, vulnerable people) | — |
| L (Entertainment) | Theatres, cinemas | M1 | M2 | M2 | — | M1 |
| N (Restaurants) | Restaurants, bars | M1 | M2 | M2 | — | — |
| R (Education) | Schools, nurseries | M1 | M2 | M2 | — | M1 |
| W (Offices) | Offices, administrations | M1 | M2 | M2 | — | — |
| U (Healthcare) | Clinics, care centers | M1 | M2 | M2 | M2 (Type U provisions, regardless of area) | — |
Important distinction Type J vs Type U: EHPADs are classified as Type J (accommodation facilities for the elderly). Clinics and care centers are classified as Type U (healthcare). These are two different types. For Type J, rooms under 50 m² are not explicitly covered by AM 12 (same logic as Type O hotels). For Type U, specific provisions impose M2 in rooms regardless of their area. M2 is still recommended for Type J due to the vulnerability of residents. Check the exact classification of your establishment with your control office.
Hotels: Cumulative ERP Types
Every hotel is a Type O ERP. But a hotel can combine several types when it includes activities open to the external public:
- Type N (restaurant, bar): if the space is open to the external public (not reserved for hosted guests only)
- Type L (meeting rooms): if rental is accessible to non-residents
- Type X (swimming pool, spa): if accessible to non-residents
- Type M (boutique): if open to the external public
If these spaces are reserved exclusively for hosted guests, the hotel maintains only the Type O classification. Since a guest cannot be simultaneously in their room and in another space, there is no cumulative occupancy.
ERP Categories and Inspection Frequency
| Category | Maximum Occupancy | Commission Visit |
|---|---|---|
| 1st category | More than 1,500 people | Every 3 years |
| 2nd category | 701 to 1,500 people | Every 3 years |
| 3rd category | 301 to 700 people | Every 3 years |
| 4th category | 100 to 300 people | Every 3 years |
| 5th category | Less than 100 people | Every 5 years (hotels only*) |
*Hotels are the only 5th category ERPs subject to a mandatory visit by the safety commission, due to the vulnerability of sleeping occupants.
What the Safety Commission Checks
The Departmental Consultative Commission for Safety and Accessibility (CCDSA) is composed of the mayor of the municipality (or their representative), one or more firefighters, a representative of the national police or gendarmerie, and potentially a state official from the departmental services. It checks the following elements for textiles:
- Fire classification report: Issued by an approved laboratory (LNE, CSTB, Apave, Efectis). Must be included in the safety register.
- Report/product correspondence: The report must correspond to the fabric actually installed.
- Correct placement: M1 in enclosed stairwells, M2 in passageways and rooms > 50 m², M1 on stages.
- Absence of curtains across passageways: Prohibition AM 11 §1.
- Condition of treated curtains: Date of the last fire-retardant retreatment.
The safety register must also contain: inspection reports from control offices (annual gas, electricity, elevator, smoke extraction, alarm checks), the annual extinguisher inspection report, and the fire safety training certificate for personnel.
In case of an unfavorable opinion, the mayor or state services may administratively close the establishment.
Compliance Checklist Before the Visit
The compliance of textiles in ERP is based on 6 verification points before each visit of the safety commission. Commissions inspect ERPs in categories 1 to 4 every 3 years, and 5th category hotels every 5 years. Non-compliant textiles are a frequent reason for an unfavorable opinion, which can lead to an administrative closure of the establishment.
- Up-to-date safety register: Fire classification reports archived for each curtain reference installed.
- Report/product correspondence: Verify that the installed fabric matches the report.
- Verified locations: M1 enclosed stairwells + stages. M2 passageways + rooms > 50 m². No curtains across a passageway.
- Retreatment dates: For chemically treated curtains, the date of the last retreatment is documented and within the timeframe (12-18 months).
- Labeling: Marking on curtains with report reference to facilitate on-site control.
- Complete register: Annual control reports + personnel training certificate.
Kurtens manufactures custom technical curtains with M1 certification available upon request. Request a professional quote: response within 24 business hours, no minimum order, samples upon request.
For the complete guide on types of fireproofing and combined performance: M1/M2 fire-retardant curtains: complete guide. For sector-specific solutions: hospitality, EHPAD, offices, restaurants.
Disclaimer: This guide is provided for informational and summary purposes. It does not replace consultation of official regulatory texts (decree of June 25, 1980, decree of November 21, 2002, standard NF P 92-507) or the advice of an approved control office or a specialized lawyer. The legal references mentioned are subject to regulatory changes. Verify the current status of texts with the competent authorities.
Frequently Asked Questions
Is M1 mandatory in hotel corridors?
No. Corridors, halls, and passageways (excluding enclosed stairwells) require M2, not M1 (article AM 12 b). Only enclosed stairwells (protected staircases, escape routes) require M1 (article AM 12 a). M1 is recommended in passageways for maximum safety but is not mandatory. Caution: it is forbidden to place curtains across passageways (AM 11 §1), regardless of classification.
Do hotel rooms require M1 or M2 curtains?
For rooms under 50 m²: no regulatory M classification obligation (articles AM 11-12 do not cover these private spaces). For suites of 50 m² and larger: M2 is mandatory (article AM 12 b). Insurers, hotel chains, and control offices may contractually impose M1 or M2 even in standard rooms. Our recommendation: M2 minimum everywhere to anticipate these requirements.
Can a curtain be placed across a hotel corridor?
No, this is strictly forbidden by article AM 11 §1. It is forbidden to place drapes or curtains across passageways (corridors, circulation areas, exits). No M classification makes this practice acceptable. The only exception: textile trim on fire doors, which must be M2 minimum (AM 11 §2). Curtains along walls or in front of windows in corridors are permitted in M2.
Does a hotel restaurant require M1?
M2 if the room exceeds 50 m² (article AM 12 b). Not M1. If the restaurant is open to the external public, the hotel combines Type O and N, but the requirements remain the same (M2 for rooms > 50 m²). M1 is recommended for maximum safety in high-traffic areas, but not required by the texts.
Are 5th category hotels inspected?
Yes, every 5 years. Hotels are the only 5th category ERPs subject to a mandatory visit by the safety commission, due to the vulnerability of sleeping occupants. Categories 1 to 4 are inspected every 3 years. The commission also intervenes before the opening of a new establishment and during significant renovation work.
Does a small 30 m² hotel lounge require M2?
No. Article AM 12 b only covers rooms with a floor area greater than 50 m². A small private lounge less than 50 m², located outside main circulation areas, is not subject to an M classification obligation for curtains. As with rooms, M2 is recommended to anticipate the requirements of insurers and control offices.
How to prepare for the safety commission visit?
Check 6 points: safety register with fire classification reports for each curtain, correspondence between report and installed product, M1 in enclosed stairwells and on stages, M2 in passageways and rooms > 50 m², no curtains across passageways, up-to-date retreatment dates for treated curtains. The register must also contain annual inspection reports and personnel training certificates.
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