EN 1646-1:2025

SLOVENSKI STANDARD
oSIST prEN 1646-1:2024
01-junij-2024
Bivalna počitniška vozila - Avtodomi - 1. del: Zdravstvene in varnostne zahteve za
bivanje
Leisure accommodation vehicles - Motor caravans - Part 1: Habitation requirements
relating to health and safety
Bewohnbare Freizeitfahrzeuge - Motorcaravans - Teil 1: Anforderungen an den
Wohnbereich hinsichtlich Gesundheit und Sicherheit
Véhicules habitables de loisirs - Autocaravanes - Partie 1 : Exigences d'habitation
relatives à la santé et à la sécurité
Ta slovenski standard je istoveten z: prEN 1646-1
ICS:
43.100 Osebni avtomobili. Bivalne Passenger cars. Caravans
prikolice in lahke prikolice and light trailers
oSIST prEN 1646-1:2024 en,fr,de
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

oSIST prEN 1646-1:2024
oSIST prEN 1646-1:2024
DRAFT
EUROPEAN STANDARD
prEN 1646-1
NORME EUROPÉENNE
EUROPÄISCHE NORM
April 2024
ICS 43.100 Will supersede EN 1646-1:2018
English Version
Leisure accommodation vehicles - Motor caravans - Part 1:
Habitation requirements relating to health and safety
Véhicules habitables de loisirs - Autocaravanes - Partie Bewohnbare Freizeitfahrzeuge - Motorcaravans - Teil
1 : Exigences d'habitation relatives à la santé et à la 1: Anforderungen an den Wohnbereich hinsichtlich
sécurité Gesundheit und Sicherheit
This draft European Standard is submitted to CEN members for enquiry. It has been drawn up by the Technical Committee
CEN/TC 245.
If this draft becomes a European Standard, CEN members are bound to comply with the CEN/CENELEC Internal Regulations
which stipulate the conditions for giving this European Standard the status of a national standard without any alteration.

This draft European Standard was established by CEN in three official versions (English, French, German). A version in any other
language made by translation under the responsibility of a CEN member into its own language and notified to the CEN-CENELEC
Management Centre has the same status as the official versions.

CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are
aware and to provide supporting documentation.

Warning : This document is not a European Standard. It is distributed for review and comments. It is subject to change without
notice and shall not be referred to as a European Standard.

EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION

EUROPÄISCHES KOMITEE FÜR NORMUNG

CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2024 CEN All rights of exploitation in any form and by any means reserved Ref. No. prEN 1646-1:2024 E
worldwide for CEN national Members.

oSIST prEN 1646-1:2024
prEN 1646-1:2024 (E)
Contents Page
European foreword . 4
Introduction . 5
1 Scope . 6
2 Normative references . 6
3 Terms and definitions . 6
4 Testing . 6
5 Design and construction . 7
5.1 Occupancy . 7
5.2 Entrance steps to living area . 7
5.2.1 Heights . 7
5.2.2 Minimum tread dimensions . 7
5.2.3 Mechanical strength . 7
5.2.4 Slip resistance and stability test of entrance step . 7
5.3 Doors . 8
5.3.1 Dimensions. 8
5.3.2 Securing doors . 8
5.3.3 Childproof locking systems . 8
5.3.4 Dead-locking systems . 8
5.4 Awning rails . 8
6 Internal equipment . 8
6.1 Bunks . 8
6.1.1 Mattress and/or upholstery . 8
6.1.2 Clearance . 8
6.1.3 Clearance of drop-down bunks . 9
6.1.4 Protection against falling out . 9
6.1.5 Mechanical strength . 10
6.1.6 Security of bunks . 10
6.1.7 Access to high level bunks . 10
6.1.8 Protection against entrapment . 10
6.2 Cupboards . 11
6.3 Cooking appliance . 11
7 Drinking water supply, storage and disposal of waste water . 11
7.1 Couplings for drinking water supply . 11
7.2 Drinking water . 11
7.2.1 Tanks . 11
7.2.2 Materials . 11
7.2.3 Marking . 11
7.3 Waste water disposal tank . 11
7.4 Toilet waste disposal . 12
7.4.1 Discharge systems . 12
7.4.2 Outlets and couplings from toilet holding tanks . 12
8 Appliances . 12
8.1 Installation of appliances . 12
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prEN 1646-1:2024 (E)
8.2 Restriction concerning supply of appliances . 12
9 Heating . 12
10 Installations . 13
10.1 Electricity . 13
10.1.1 Low voltage . 13
10.1.2 Extra low voltage (DC) . 13
10.2 Liquefied petroleum gas (LPG) . 13
11 Ventilation . 13
11.1 General . 13
11.2 Adjustment of ventilators . 13
11.3 Location of ventilation openings . 13
12 Fire precautions . 13
12.1 Means of escape . 13
12.1.1 Emergency exits . 13
12.1.2 Escape path . 14
12.1.3 Sanitation compartments . 14
12.1.4 Emergency doors . 14
12.1.5 Interior doors . 14
12.1.6 Emergency windows and emergency panels . 15
12.1.7 Work surfaces . 16
12.1.8 Heating and cooking equipment . 17
12.2 Protection of combustible elements . 17
12.2.1 Rigid or guided elements . 17
12.2.2 Non-guided elements . 17
12.3 Hotplates . 17
13 Warning notice . 18
13.1 Provision of warning notice . 18
13.2 Content of warning notice . 18
14 User’s handbook . 18
Bibliography . 42

oSIST prEN 1646-1:2024
prEN 1646-1:2024 (E)
European foreword
This document (prEN 1646-1:2024) has been prepared by Technical Committee CEN/TC 245 “Leisure
accommodation vehicles”, the secretariat of which is held by AFNOR.
This document is currently submitted to the CEN Enquiry.
This document will supersede EN 1646-1:2018.
prEN 1646-1:2024 includes the following significant technical changes with respect to EN 1646-1:2018:
a) change from “flammable” to “combustible”
b) amendment of Clause 5.2.1 “Heights”;
c) Clause 6.1.2.1 modified for motor caravans;
d) amendment Clause 5.1 “Occupancy”;
e) Clause 6.1.3 “Clearance of drop-down bunks” added;
f) amendment of Clause 6.1.4.3 “Protection by curtains or nets”;
g) amendment of Clause 6.1.7 “Access to high level bunks”;
h) amendment of Clause 7 “Drinking water supply, storage and disposal of waste water”;
i) amendment of Clause 8.1 “Installation of appliances”;
j) amendment of Clause 10.1.2 “Extra low voltage (DC)” ;
k) amendment of Clause 12.3 “Hotplates”;
l) amendment of Annex A “Mechanical strength of entrance step”
m) amendment of D.2 “Preparation and procedure” in Annex D “Clear height over bunks”;
n) amendment of test equipment for load spreading platform for bunks (K.5)
o) normative references updated.
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prEN 1646-1:2024 (E)
Introduction
Figure 1 gives an overview of the relevant standards for caravans, motor caravans and caravan holiday
homes.
Figure 1 — Overview of relevant standards applying to leisure accommodation vehicles
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prEN 1646-1:2024 (E)
1 Scope
This document specifies requirements intended to ensure the safety and health of persons when they use
motor caravans for temporary or seasonal habitation.
It also specifies the corresponding test methods.
Specific requirements of this document apply to motor caravans where the overall length multiplied by
the overall width does not exceed 13,5 m plan area.
Requirements applicable to road safety are not included in the scope of this document.
This document is applicable exclusively to motor caravans as defined in EN 13878.
2 Normative references
The following documents are referred to in the text in such a way that some or all of their content
constitutes requirements of this document. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any amendments) applies.
EN 3-7, Portable fire extinguishers — Part 7: Characteristics, performance requirements and test methods
EN 721, Leisure accommodation vehicles — Safety ventilation requirements
EN 1648-2, Leisure accommodation vehicles — 12 V direct current extra low voltage electrical
installations — Part 2: Motor caravans
EN 1949, Specification for the installation of LPG systems for habitation purposes in leisure accommodation
vehicles and accommodation purposes in other vehicles
EN 13501-1:2018, Fire classification of construction products and building elements – Part 1: Classification
using data from reaction to fire tests
EN 13878, Leisure accommodation vehicles — Terms and definitions
EN ISO 8936, Awnings for leisure accommodation vehicles — Requirements and test methods (ISO 8936)
HD 60364-7-721, Low-voltage electrical installations — Part 7-721: Requirements for special installations
or locations — Electrical installations in caravans and motor caravans (IEC 60364-7-721)
ISO 4649:2017, Rubber, vulcanized or thermoplastic — Determination of abrasion resistance using a
rotating cylindrical drum device
3 Terms and definitions
For the purposes of this document, the terms and definitions given in EN 13878 apply.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https://www.iso.org/obp/
— IEC Electropedia: available at https://www.electropedia.org/
4 Testing
The tests described in Annex A to Annex K are intended to verify that a motor caravan representative of
a given model, including its fixtures and fittings, meets the requirements of this document.
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prEN 1646-1:2024 (E)
These tests are intended to simulate the most onerous conditions, for the relevant characteristics.
It is recommended to take environmental aspects into account during development, production and
disposal of motor caravans based on established knowledge and within the respective technical
possibilities (see also Annex L).
5 Design and construction
5.1 Occupancy
The manufacturer shall designate the occupancy as the number of berths, both standard berths and
additional berths provided by the manufacturer and shall include it in the user’s handbook. The
occupancy is also necessary to determine the ventilation requirements (see EN 721).
NOTE The number of seating positions defined on the registration certificate might be different.
5.2 Entrance steps to living area
5.2.1 Heights
When the entrance height of the motor caravan, measured at maximum technically permissible laden
mass, and standing on horizontal ground, exceeds 450 mm, the motor caravan shall either be fitted with
an entrance step, attachable or integral with the structure of the motor caravan, or a separate entrance
step(s) shall be provided. An integral entrance step can be either retractable, folding or fixed.
The rise of the first tread shall not exceed 450 mm. The rise of any other tread shall not exceed 300 mm.
It is recommended that the rise of the steps be equal.
5.2.2 Minimum tread dimensions
The minimum tread dimensions shall be:
a) attachable or integral entrance steps: 150 mm going over a minimum, uninterrupted width of
320 mm;
b) separate steps: 270 mm going over a minimum, uninterrupted width of 450 mm.
5.2.3 Mechanical strength
An entrance step and any fixing devices shall be capable of withstanding a force of 2 000 N applied to any
surface area of 100 mm × 150 mm of the tread(s).
After application of this force for a period of 5 min, any permanent deformation caused shall not exceed
5 mm.
The strength of each step shall be tested in accordance with Annex A.
5.2.4 Slip resistance and stability test of entrance step
5.2.4.1 Attachable or integral entrance step
An attachable or integral step shall have a slip resistant surface.
The slip resistance shall be tested in accordance with Annex B.
5.2.4.2 Separate entrance step
A separate entrance step shall have a slip resistant surface. The slip resistant surface shall be tested in
accordance with Annex B after having fixed the feet or base of the step.
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prEN 1646-1:2024 (E)
In addition, a separate step shall remain stable when tested in accordance with Annex C.
5.3 Doors
5.3.1 Dimensions
5.3.1.1 Motor caravans above 13,5 m plan area
Each exterior door opening to the habitation area shall have a minimum clear height of 1 590 mm and
a minimum clear width of 480 mm and corners of maximum radius of 90 mm. The locking system may
intrude on the minimum width up to 30 mm and for a maximum height of 150 mm, regardless of the
number of locks.
5.3.1.2 Motor caravans equal to or less than 13,5 m plan area
Each exterior door opening to the habitation area shall have a minimum clear height of 1 140 mm and
a minimum clear width of 480 mm and corners of maximum radius of 90 mm.
There shall be a clear opening free from any obstruction of at least 0,65 m .
5.3.2 Securing doors
Each exterior door shall be fitted with a locking device capable of keeping it closed when subjected to all
forces caused by movement of the motor caravan in normal traffic conditions.
Interior doors shall be capable of being kept in a fixed position, open or closed, in the above conditions.
5.3.3 Childproof locking systems
When an external door is fitted with a childproof lock, a notice shall be permanently fixed close to the
lock. The notice shall read:
— “Ensure that the childproof lock is not activated when the motor caravan is parked for use for
habitation.”
5.3.4 Dead-locking systems
If a dead-locking system is fitted on the base vehicle, information shall be included in the user’s handbook
on how to operate the doors from the inside when the dead-locking system is activated.
5.4 Awning rails
Any awning rail shall permit the correct fitting of an awning complying with EN ISO 8936.
6 Internal equipment
6.1 Bunks
6.1.1 Mattress and/or upholstery
Bunks shall be provided with mattresses or be upholstered.
6.1.2 Clearance
6.1.2.1 Motor caravans above 13,5 m plan area
The clear height over 2/3 of the surface of the bunk shall be not less than 500 mm when measured from
the compressed surface of the mattress or upholstery in accordance with the test in Annex D.
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6.1.2.2 Motor caravans equal to or below 13,5 m plan area
The clear height over half the surface area of the bunk shall be not less than 400 mm when measured
from the compressed surface of the mattress or upholstery in accordance with the test in Annex D.
6.1.3 Clearance of drop-down bunks
Where it is possible for a drop-down bunk to be lowered so that the clear height is not according to 6.1.2,
then a label according to Figure 2, shall be affixed in a visible position close to the switch or operating
mechanism to advise the customer of the risk of lowering the bunk when the lower bunk is in use.

Key
1 Minimum clear height
Figure 2 — Bunk information
6.1.4 Protection against falling out
6.1.4.1 General
High level bunks shall be protected on all sides to prevent the occupant from falling out. Any gap between
one element of protection and another shall conform to 6.1.8. However, no gap shall exceed 75 mm.
All protections shall be secured against unintentional loosening.
High level bunks shall be provided with a label written in the language of the country where the motor
caravan is to be first sold with the following wording:
“Not suitable for children under 6 years old without supervision”.
6.1.4.2 Rigid protection
For rigid protection, the minimum height of the protection shall be at least 150 mm above the
uncompressed upper surface of the mattress or upholstery. To allow entry, an access gap of 350 mm to
550 mm measured at its narrowest point shall be provided.
Where a rigid protection presents an apparent flexibility, its resistance shall be tested in accordance with
Annex E.
A protection is considered as rigid if it is not bent more than 10 mm under a force of 100 N applied
horizontally in the middle of the protection.
6.1.4.3 Protection by curtains or nets
Alternatively, the protection may be obtained by means of curtains or nets. The minimum height of the
protection shall be at least 160 mm above the uncompressed upper surface of the mattress or upholstery,
when the upper edge is loaded with 100 N in a vertical direction downward.
To allow access to the bunk, the curtains or nets on at least one side of the bunk may be detachable, to
enable an opening of at least 350 mm. If a permanent opening is provided for access, this opening shall
be between 350 mm to 550 mm.
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The curtains or nets shall be capable of resisting a force of 100 N applied horizontally towards the outside
of the bunk for 15 s to any point and this shall not result in any tearing nor detaching nor creating any
gap larger than 60 mm at the lower edge of the protection.
The strength of the curtains or nets shall be tested in accordance with Annex E.
Any gap created during the resistance test shall be measured in accordance with Annex I.
6.1.5 Mechanical strength
A force of 1 000 N applied vertically downwards, for 1 h, from the midpoint of each side member of any
bunk where the upper surface of the compressed mattress or upholstery is placed at a height of more
than 500 mm from the floor, shall neither cause permanent deformation of more than 5 mm of the frame
of the bunk nor damage the fixing of the bunk to the structure of the motor caravan.
The mechanical strength shall be tested in accordance with Annex F.
6.1.6 Security of bunks
If a bunk is designed to fold away, it shall be secured against unintentional folding away.
If a bunk is designed to be stored during transportation, it shall be secured against unintentional
movement when stored.
All bunks shall not unintentionally move. All bunks shall be tested in accordance with Annex G.
6.1.7 Access to high level bunks
A means of access to a high level bunk shall be provided, such as surfaces of furniture, foot holes in a solid
component, handles or a ladder which shall be fixed or be able to be attached to the bunk, in a safe
manner.
The width of the treads between supports shall be at least 250 mm.
The distance between the top foothold and of the unloaded surface of the mattress, at the point of access
shall not be more than 400 mm.
When a ladder is used, the upper surfaces of the treads shall be equally spaced within a tolerance
of ± 12 mm, and the unobstructed distance between consecutive treads shall be (225 ± 25) mm.
There shall be an unobstructed distance of ≥ 100 mm from the back surface of the tread to any
obstruction and a clear height of 75 mm. When tested in accordance with Annex H, the ladder shall not
move when subjected to a downward static load of 1 000 N and horizontal static load of 500 N; nor shall
the ladder or its treads break or deflect permanently by more than 5 mm.
Where it is impractical to test the bunk ladder in the motor caravan, it is acceptable to test an identical
configuration of the ladder, its method of fixing and its range of positions of use, outside the motor
caravan according to Annex H.
6.1.8 Protection against entrapment
When ready for use, a bunk and its means of access shall not contain any open-ended tube; nor shall there
be projections, holes, loose washers, speed fixing nuts or crevices on which clothing or any part of the
body could become snagged or trapped. Tension springs in the base structure are excluded. All edges,
corners and projecting parts that are accessible shall be free from burrs and sharp edges.
If the base of a bunk is not covered by permanently fixed upholstery, any gap in the base not covered by
the mattress shall not permit the passage of the cone (see I.1) beyond the point at which the diameter of
the cone is 75 mm, when measured in accordance with I.2.
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Any other gap or space within the structure of the bunk which is accessible from the upper surface of the
bunk, including mattress where applicable, shall be between 12 mm and 25 mm or between 60 mm and
75 mm (tested in accordance with I.3) or equal to or larger than 200 mm.
When a gap cannot be tested because a constructional feature prevents proper positioning of the cone,
the constructional feature may be removed to the extent necessary to allow the tests to be carried out.
6.2 Cupboards
Bases of cupboards and shelves in cupboards at more than 1 000 mm from the floor of the vehicle at the
place of measurement shall be provided with means to prevent their contents from sliding off.
Protection shall be appropriate for the items likely to be stored in the cupboards. Where an up-stand or
lip is used as the method of protection, this should be a minimum height of 5 mm.
6.3 Cooking appliance
A cooking appliance shall be installed.
7 Drinking water supply, storage and disposal of waste water
7.1 Couplings for drinking water supply
If couplings for drinking water supply are installed, they shall be accessible from the outside of a motor
caravan. Access can be through an opening door or flap. This may be behind a base vehicle door provided
the coupling cannot be accessed when this door is closed. A sealing off cover, secured to the coupling or
adjacent to it shall be supplied for each coupling.
7.2 Drinking water
7.2.1 Tanks
Water tanks shall be capable of being completely drained and cleaned.
7.2.2 Materials
All materials in contact with water intended for human consumption shall not impair the drinking water
quality.
NOTE All materials that are designed to come into contact with drinking water, attention is drawn to the
requirements of Article 11 of Directive (EU) 2020/2184 on the quality of water intended for human consumption
and local and national requirements for the country of first destination.
7.2.3 Marking
The drinking water filling points shall be clearly identified in blue.
7.3 Waste water disposal tank
When a drinking water tank is fixed in the motor caravan, one (or more) waste water tank(s) of total
capacity at least equal to 50 % of the drinking water tank capacity shall be provided. Any waste water
tank shall be fixed or movable and it shall be capable of being flushed and cleaned. If moveable, a storage
area shall be provided.
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prEN 1646-1:2024 (E)
7.4 Toilet waste disposal
7.4.1 Discharge systems
Discharge from a toilet shall be collected in a closed system and shall not be discharged into a waste water
disposal system. Any fixed tank intended to receive discharge from a toilet shall be fitted with a level
indicator or early warning device that will indicate to the user that the tank will require emptying after a
further three or four uses.
7.4.2 Outlets and couplings from toilet holding tanks
The internal diameter of a coupling taking discharge from a toilet holding tank shall be a minimum of
70 mm. It shall have a secure detachable connection to receive a 75 mm minimum internal diameter hose
and a 1 500 mm minimum length of such hose shall be provided.
When a macerator is fitted the internal diameter may be reduced to 32 mm.
These requirements do not apply to toilets with removable toilet waste holding tanks.
8 Appliances
8.1 Installation of appliances
Appliances shall be installed in accordance with the appliance manufacturer’s instructions.
NOTE Local regulations and requirements for the country of first destination can apply.
8.2 Restriction concerning supply of appliances
Portable appliances producing heat and non-room-sealed space heating appliances shall not be supplied
with the motor caravan by the motor caravan manufacturer.
9 Heating
The heating of motor caravans shall be classified as follows:
a) Grade 1: There is no heating requirement for this grade;
b) Grade 2: An average temperature difference of at least 20 K between inside and outside
temperatures shall be achieved when the outside temperature is 0 °C. This shall be tested in
accordance with Annex J;
c) Grade 3: An average temperature difference of at least 35 K between inside and outside
temperatures shall be achieved when the outside temperature is −15 °C. This shall be tested in
accordance with Annex J.
Precautions shall be taken to ensure that the fresh-water supply can be filled at the end of the
stabilizing time of one hour according to Annex J. Then the fresh-water service shall operate when
the outside temperature is −15 °C.
To ensure compliance with this clause, it is sufficient to test only one motor caravan with the largest
plan area of a specified number of similar motor caravans. This motor caravan shall fulfil the
following conditions:
1) the bodywork, materials used and cross sectional dimensions in similar positions for the walls,
floor, roof and windows are identical (except for colour);
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2) the motor caravan tested shall have the largest total window area;
3) the space heater shall have the smallest output;
4) all motor caravans shall have the same space heating system (convicted air, blown air, hot water,
etc.);
5) the motor caravan shall have the least number of heating outlets (air outlets, heat exchangers,
radiators, etc.) of the smallest dimensions of the motor caravans;
6) all motor caravans shall have the same hot and cold water supply system and any tank(s) shall
have the same method of protection against freezing.
10 Installations
10.1 Electricity
10.1.1 Low voltage
Low voltage electrical installations shall conform to HD 60364-7-721.
10.1.2 Extra low voltage (DC)
Direct current extra low voltage installations shall conform to EN 1648-2.
10.2 Liquefied petroleum gas (LPG)
LPG installations shall conform to EN 1949.
11 Ventilation
11.1 General
Safety ventilation shall be provided and shall conform to EN 721.
11.2 Adjustment of ventilators
It is permissible to provide a means of adjusting the fixed free area of ventilation of a low level ventilator,
to prevent draughts when a motor caravan is in motion. If such means of adjustment are provided, the
fixed ventilation shall automatically revert to the fully open position when the vehicle is stationary and
the engine is switched off.
11.3 Location of ventilation openings
Low level ventilation openings shall be located so that there is no danger of exhaust fumes from the
engine of the motor caravan being drawn into the interior. No ventilation opening provided for a
refrigerator shall be located within 500 mm of the fuel refuelling point of the motor caravan.
12 Fire precautions
12.1 Means of escape
12.1.1 Emergency exits
Each separate living compartment, which can be closed off from the rest of the motor caravan other than
by means of a loose curtain, shall be provided with an emergency exit (emergency door, emergency panel
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or emergency window) giving direct access to the outside of the motor caravan in accordance with 12.1.4
or 12.1.6, as appropriate.
Means of emergency exit from the bunk shall be accessible from the upper surface of the bunk.
12.1.2 Escape path
It shall be possible to reach an emergency exit by means of an unobstructed escape path.
Objects such as drawers, furniture doors, bunk ladders, oven doors, etc. that can be moved quickly and
easily with a single operation shall not be considered as obstructions. One operation is a train of
movements effected without removing the hand(s) from the element(s) on which it is acting (e.g. 1, 2 and
3 successively). See Figure 4.
An escape path shall be at least 450 mm wide except for motor caravans equal to or below 13,5 m plan
area where a limited restriction to this escape path is permitted provided that the following conditions
are met:
1) the width of the escape path over a maximum length of 500 mm may be restricted below 450 mm;
2) the minimum dimensions of the restriction shall be 300 mm up to a maximum height of 950 mm and
450 mm above this height;
3) there shall be no doors, drawers, etc. that could temporarily obstruct the escape path within the zone
where the escape path is restricted.
When the access to an emergency exit door is temporarily obstructed, the escape path to it may be limited
to a height of 1 140 mm from the floor. When the height is restricted, the escape path shall have
a minimum width of 480 mm and a maximum length of 750 mm. The length distance or sum of distances
is measured from the start of the reduced height to the nearest door handle of the emergency exit door
passing through the escape path.
Access to the emergency door handle shall be maintained.
12.1.3 Sanitation compartments
Sanitation compartments shall be equipped with an emergency exit unless the compartment door is
situated less than 2 000 mm from an emergency exit of the motor caravan. This distance or sum of
distances is measured from the door handle of the sanitation compartment with the door of the sanitation
compartment closed to the nearest part of the emergency exit aperture passing through the escape path.
12.1.4 Emergency doors
Emergency doors shall open outwards or slide horizontally, and shall provide a clear opening, free from
obstruction, of the sizes specified in 5.3.1. The door lock(s), even if locked from the outside, shall be
capable of being immediately opened from the inside. This requirement is considered as fulfilled if
opening of the emergency door can be performed in not more than two operations in addition to opening
curtains, blinds or fly screens. The use, of two hands for a simultaneous operation shall be considered as
one operation.
For childproof locks, see 5.3.3.
12.1.5 Interior doors
Opening mechanisms for interior doors shall be capable of being operated from both sides. When fitted,
lever handles shall open interior doors by being pushed downwards, however some road vehicle
regulations may offer alternatives.
Where an interior door between compartments is fitted with a locking mechanism on one side, an
emergency unlocking system shall be fitted on the other side.
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12.1.6 Emergency windows and emergency panels
Emergency windows and emergency panels shall open outwards or slide horizontally and shall provide
a clear opening, free from obstruction, of not less than 0,25 m , with a minimum dimension in any one
direction of 450 mm.
For compartments exclusively for the use of children and in which there are two bunks above the lower
bunk, the minimum dimension in any one direction may be reduced to 350 mm so long as the clear
opening shall be not less than 0,25 m (see Figure 3). Any projecting element should be deducted from
the total area of the aperture (e.g. catches, locks, fixing for window stays, blinds).

Key
1 disk of rigid material of the minimum dimension to check the emergency window or emergency panel
2 window stay fixing points
3 window catches
4 350 mm or 450 mm
Figure 3 — Verification of minimum dimensions of an emergency window or emergency panel
The lower edge of the opening of any emergency window or emergency panel shall be not more than
950 mm above the floor level of the motor caravan.
Where a bed, a bunk or seat(s) is/are permanently fixed immediately under an emergency window or
emergency panel, it may be considered as an access step to the emergency window or emergency panel.
The emergency window or emergency panel shall not be more than 1 100 mm above the floor level of the
caravan.
All outward opening emergency windows or emergency panels shall be hinged on their upper edge. They
shall be capable of opening through at least 70° and shall stay fully open until closed manually (see
Figure 4).
oSIST prEN 1646-1:2024
prEN 1646-1:2024 (E)
Dimensions in millimetres
Key
1 typical window stays capable of holding the emergency window in its open position
Figure 4 — Positioning of emergency window or emergency panel
Opening of an emergency window or an emergency panel shall not require more than three operations
in addition to opening curtains, blinds or fly screens. The use of two hands for a simultaneous operation
shall be considered as one operation. After the final operation, emergency windows or emergency panels
shall remain fully open until closed manually. One operation is a train of movements effected without
removing the hand(s) from the element(s) on which it is acting (e.g. 1, 2 and 3 successively). See Figure 5.

Key
1, 2, 3 order of successively performed movements for one operation
Figure 5 — Typical single operation of several continuous movement
12.1.7 Work surfaces
No work surface shall open towards an emergency exit in such a way as to obstruct the emergency exit
or to reduce the clear opening.
oSIST prEN 1646-1:2024
prEN 1646-1:2024 (E)
12.1.8 Heating and cooking equipment
Equipment for heating or cooking shall not be mounted on doors or installed in escape paths to
emergency exits.
NOTE For the protection of surfaces adjacent to heat generating appliances and regarding heating and cooking
appliances, local regulations and requirements can apply.
Such appliances shall be installed in accordance with the appliance manufacturer's instructions.
12.2 Protection of combustible elements
12.2.1 Rigid or guided elements
All rigid or guided elements manufactured from combustible materials shall be at a minimum distance of
200 mm from an open flame, measured from the point of emission of the flame (see Figure 6), except if
these elements are protected by non-combustible material in accordance with EN 13501-1:2018,
Class A2. Protection made of non-combustible material may be fixed or hinged but shall not be removable
without tools.
NOTE Materials such as glass, metal and ceramics are considered non-combustible.
Movable rigid elements shall be checked in their most adverse position.

Key
1 point of emission
Figure 6 — Point of emission of the flame
12.2.2 Non-guided elements
All non-guided elements such as curtains or non-guided blinds situated at less than 900 mm from the
point of emission of the flame of a burner shall be inspected to ensure that they cannot be blown to within
300 mm, except when these elements are protected by non-combustible material.
The vertical dimensions of such non-combustible protection shall be the greater of:
a) 300 mm above the point of emission of the flame or;
b) equal to or higher than a line drawn between the point of emission of the flame and the closest point
at which the element is suspended.
Elements shall be considered when they are open (pulled back) and disregarding any storage devices.
12.3 Hotplates
In the case o
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