From the Environment and planning act to cable selection: how the Bbl, NEN 1010, NPR 5310 and CPR work together

Anyone involved in designing, budgeting, ordering, installing or inspecting an electrical installation has to deal with various laws, standards and product declarations. In practice, these documents are still regularly confused with one another. For example, NEN 1010 is often referred to as “the law”, while its public-law significance comes from the fact that the Building Works Living Environment Decree (Besluit bouwwerken leefomgeving, Bbl) refers to it. Likewise, CE marking or a CPR classification does not automatically mean that a cable can be used in every room of every building.

For installation companies, consultants and clients, it is therefore important to understand the respective roles of the Environment and Planning Act (Omgevingswet), the Bbl, the Environment and Planning Regulation (Omgevingsregeling), NEN 1010, NPR 5310 and the European Construction Products Regulation (CPR).

From legislation to technical implementation
The Environment and Planning Act provides the legal framework for the physical environment. The specific technical requirements for buildings are primarily set out in the Building Works Living Environment Decree (Bbl). These requirements include minimum standards for structural safety, fire safety, health, energy efficiency and building installations.

The Environment and Planning Regulation further specifies this framework. Among other things, it determines which edition of a standard must be used when applying the Bbl. This is important because the latest edition of NEN 1010 is not necessarily the same as the edition designated for regulatory purposes.

NEN 1010 contains the technical safety requirements for low-voltage electrical installations. NPR 5310 provides practical guidance and examples of how these requirements can be applied. A practical guideline can support design, installation and inspection, but it does not take precedence over NEN 1010 and is not an independent statutory requirement.

The Bbl goes beyond NEN 1010
For new construction, Article 4.199 of the Bbl requires an existing low-voltage electrical installation to comply with the designated safety requirements of NEN 1010. The standard covers, among other things, protection against electric shock, overcurrent, short circuits and thermal effects. The selection and installation of wiring systems, earthing, equipotential bonding and verification are also part of the standard.

The Bbl also contains its own requirements that are relevant to electrical installations. A well-known example is the requirements for electric vehicle charging infrastructure.

In a new residential building with more than ten parking spaces, cable provisions for charging points must generally be installed to each parking space. Cable provisions include facilities such as cable trays and empty conduits through which power and communication cables can be installed at a later stage.

For new non-residential buildings, such as offices and publicly accessible buildings, with more than ten parking spaces, at least one charging point must be provided. In addition, at least one in every five parking spaces must be equipped with a cable provision or empty conduit.

This illustrates why knowledge of NEN 1010 alone is not sufficient. The Bbl may determine that a particular provision must be present, while NEN 1010 subsequently determines how that provision must be implemented safely from an electrical perspective.

CPR: defined product performance
The European Construction Products Regulation (CPR) governs how the performance of construction products is determined, declared and CE marked. For electrical cables covered by the harmonised product standard EN 50575, the manufacturer prepares a Declaration of Performance (DoP). This declaration includes, among other things, the cable's reaction-to-fire classification.

This classification is determined in accordance with NEN-EN 13501-6. The main classes range from Aca to Fca. Additional classifications provide information about smoke production (s), flaming droplets (d) and the acidity or corrosivity of combustion gases (a).

The CPR and the DoP therefore specify the performance of the product. They do not determine which classification must be used in a specific room or building. That application-specific requirement follows from the Bbl.

The Bbl determines the required fire and smoke classification
In addition to requirements for electrical safety, the Bbl sets requirements for the reaction to fire and smoke of electrical cables permanently installed in a building.

For new construction, the requirements for limiting the development of fire and smoke are set out in Section 4.2.7 of the Bbl. For electrical cables, these requirements are further specified in Article 4.45a. The required fire classification follows from Table 4.42 and depends on the building's use function, the location of the cable within the building and whether the cable is exposed to indoor or outdoor air.

For cables exposed to indoor air, the required fire classification is accompanied by requirements for smoke classification. For cables exposed to outdoor air, this additional smoke classification requirement does not apply.

A cable that is completely and permanently incorporated into a structure, for example cast into a concrete wall, is not exposed to indoor or outdoor air. In that case, the relevant classification requirements from Table 4.42 do not apply to that cable.

While the CPR includes a wide range of fire classifications, the Bbl effectively permits only the fire classifications Dca, Cca and B2ca for permanently installed cables exposed to indoor air. In such cases, there is also a requirement for the smoke classification: s1 or s2.

The relationship is therefore clear: the CPR classification describes the performance of the cable, while the Bbl determines the minimum performance required for the specific application. A cable with a DoP and CE marking may therefore have been legally placed on the market, but may still have an insufficient fire or smoke classification for the location where it is installed.

CE marking indicates that the manufacturer has declared the product's performance in accordance with the applicable European regulations. The suitability of the product for a specific location within a building must be assessed separately against the requirements of the Bbl.

Fixed plug-and-play installations are also subject to these requirements
The Bbl requirements do not apply only to conventionally installed cables. A prefabricated cable with installation connectors that permanently forms part of a building installation is also considered an electrical cable for the purposes of the Bbl. Fixed plug-and-play installation cables must therefore also comply with the fire and smoke classification prescribed by Article 4.45a and Table 4.42 for the relevant application.

The documentation for these systems is structured differently. The cable used in the plug-and-play installation may fall under EN 50575 and will then have a CPR DoP from the cable manufacturer. However, the product standard for installation connectors, EN-IEC 61535, has not been designated as a harmonised standard under the CPR. Therefore, a CPR DoP for the complete assembled plug-and-play product is not prepared solely on the basis of EN-IEC 61535.

The supplier must demonstrably document the fire and smoke classification of the supplied plug-and-play installation cable in its EU Declaration of Conformity, CE declaration or accompanying technical product documentation. This documentation must clearly state which cable design, product range and configuration the declaration applies to.

For engineering, project preparation and procurement, it is therefore not sufficient to check only the CPR classification of the base cable. The stated classification must demonstrably apply to the actual assembled plug-and-play cable that has been ordered and supplied.

For renovations, new-build classifications apply to cables
An important change compared with the former Building Decree concerns the treatment of electrical cables during renovation.

For renovation projects, the Bbl often applies the concept of the legally acquired level (rechtens verkregen niveau). Broadly speaking, this means that a building may not be made worse by a renovation than it was before. However, the Bbl can explicitly prescribe a higher performance level.

For electrical cables, this is addressed in Article 5.12 of the Bbl. For the new or renewed electrical cables covered by this article, the performance level specified in Article 4.45a applies. As a result, the applicable new-build requirements for fire and smoke classification must also be observed during renovation.

This applies to both conventional cables and fixed plug-and-play installation cables.

The practical consequence is important. The assumption that the same old cable classification can automatically be used again in an existing building is incorrect. During renovation, extension or replacement, the required classification for the newly installed or renewed cable must be determined again based on the Bbl.

NEN 1010 and the Bbl answer different questions
NEN 1010 determines whether a cable is suitable from an electrical engineering perspective. This includes factors such as rated voltage and current, conductor cross-section, installation method, heat dissipation, protection against overcurrent and short circuits, external influences and protection against electric shock.

The Bbl additionally determines what contribution the cable may make to the development of fire and smoke.

A cable can therefore be electrically correctly selected in accordance with NEN 1010, while still having an insufficient CPR classification for the location where it is installed. Conversely, a cable with a high fire classification is not automatically correctly sized, protected or installed from an electrical perspective.

NPR 5310 can help with the practical interpretation of NEN 1010, but it does not change the requirements of the Bbl. A practical example from NPR 5310 cannot replace a required product declaration or Bbl classification either.

What should the project team check?
For the correct selection of a cable or system, engineering, project preparation and procurement should work from the same assessment framework. First, it must be established whether the project concerns new construction, renovation or an existing building. The building's use function, the location of the cable and the required fire and smoke classification must then be determined.

Next, it must be verified that the cable is electrically suitable according to NEN 1010 and that the product documentation corresponds to the actual product ordered. For an individual cable, this includes checking the DoP. For a plug-and-play installation cable, the supplier's declaration for the assembled product must also be checked.

The article number, cable type, conductor cross-section, fire and smoke classification, product standard and system family should therefore already be specified during engineering and procurement—not only when documentation is requested at completion or during an inspection.

Conclusion
The Environment and Planning Act provides the legal basis, while the Bbl sets the technical minimum requirements for buildings. NEN 1010 governs the electrical safety of the installation, and NPR 5310 supports its practical application. The CPR governs how the performance of construction products is determined and declared.

For electrical cables, the Bbl determines which fire and smoke classification is required for a specific application. The CPR classification and DoP indicate the performance of a cable. This assessment also applies to fixed plug-and-play installation cables. Because EN-IEC 61535 has not been designated as a harmonised standard under the CPR, the supplier must demonstrably document the applicable classification of the assembled plug-and-play product in its Declaration of Conformity and technical product documentation.

For renovation projects, the applicable new-build performance requirements also apply to the relevant newly installed or renewed cables. Correct cable or system selection therefore always requires a combined assessment of the Bbl, CPR, NEN 1010, relevant product standards and supplier documentation.

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