New key criteria in industrial fire safety: what changes with RD 164/2025

Engineering
WRITTEN BY Jordi Carulla i Bellvehi
18 Dec, 2025 — 2 min
New key criteria in industrial fire safety: what changes with RD 164/2025

The entry into force of Royal Decree 164/2025, which approves the new Fire Safety Regulations for Industrial Establishments (RSCIEI), has raised significant doubts among companies, engineering firms and technicians about the validity and application of the Complementary Technical Instructions (ITC) approved in previous stages.

In response to this situation and to ensure uniform application of the regulations, the Directorate-General for Fire Prevention, Extinction and Rescue (DGPEIS) has published a clarification note that precisely defines which ITCs are no longer applicable, which ones must be adapted and what criteria should be followed from now on in Catalonia.

This clarification is particularly relevant for industrial establishments, designers, architects, engineers and safety managers, as it has a direct impact on the design, legalisation and maintenance of facilities.

What is RD 164/2025 and why is it so relevant?

RD 164/2025, of 4 March, replaces the old 2004 regulation and thoroughly updates the criteria for fire prevention and protection in the industrial sector. The new RSCIEI reinforces aspects such as:

  • The design requirements for industrial establishments.
  • Evacuation and compartmentalisation conditions.
  • Active and passive fire protection systems.
  • Maintenance, inspection and control of facilities.

With this regulatory update, many requirements that were previously regulated by specific ITCs are now directly integrated into the regulation, which requires a review of their application.

Purpose of the explanatory note

The explanatory note published by the Government of Catalonia has a clear objective: to avoid duplication, contradictions and misinterpretations in the application of the ITCs following the entry into force of the new RSCIEI.

The document establishes a unified criterion for determining:

  • Which ITCs are no longer applicable to industrial establishments subject to RD 164/2025.
  • Which ITCs remain in force but must be interpreted or adapted according to the new criteria.
  • What should be the regulatory framework of reference for new projects, modifications and inspections.

Complementary Technical Instructions that are no longer applicable

The note identifies various ITCs that should no longer be applied because their content is absorbed or replaced by the new RSCIEI. Among the main ones are:

  • SP 103 - Fire load in establishments with alcoholic beverages.
  • SP 107 - Calculation of fire load in storage activities.
  • SP 108 – Skylights on roofs of industrial establishments.
  • SP 116 – Sprinkler systems in cold rooms.
  • SP 117 – Fire resistance of light roof structures.
  • SP 119 – Determination of the configuration of industrial establishments.
  • Other ITCs such as SP 122, SP 123, SP 140, among others.

From now on, these criteria must not be justified by the ITCs, but directly in accordance with the provisions of RD 164/2025.

ITCs that remain in force but require adaptation

The explanatory note also states that some ITCs remain applicable but must be interpreted in accordance with the definitions, parameters and approaches of the new regulation. This is the case, for example, of:

  • SP 113 – Manoeuvring space on roads with a single access.
  • SP 121 – Number of accessible facades.
  • SP 128 – Fire safety in cellars and wine cellars.
  • SP 131 – Automatic sprinkler systems.
  • SP 145 – Performance-based design for smoke and temperature control.

These instructions should be used as technical support, but always in line with the criteria and requirements of the current RSCIEI.

Practical impact for companies and professionals

The explanatory note on the application of the Complementary Technical Instructions following the entry into force of RD 164/2025 is a key document for ensuring rigorous, consistent and up-to-date application of fire safety regulations in industrial establishments.

For companies and professionals, understanding these criteria is not only a regulatory issue, but also an essential tool for designing, operating and maintaining industrial facilities that are safer and in line with the new legal framework.

Having a clear and consistent regulatory framework reduces technical, legal and economic risks and facilitates decision-making in both new projects and existing facilities.