For the first time, photovoltaic modules and solar collectors are now expected to be subjected to building regulations in Germany: The responsible authority, Deutsches Institut für Bautechnik (DIBt) in Berlin, has included both solar collectors and photovoltaic modules in the announcement of planned changes to the so-called Building Rules List. Legally binding publication of the changes by the DIBt is expected by the end of 2012. Jörg Althaus, Head of Solar Energy at TÜV Rheinland, states: “Manufacturers of solar modules and collectors will be given more legal certainty, but they will also need to satisfy new requirements. Manufacturers of solar systems must now declare ‘normal flammability’ as a minimum product requirement via a manufacturer’s declaration of conformity. This declaration is required in addition to the CE declaration of the relevant European directives.”
If and when these plans are implemented, the German Building Products Law will require not only that solar collectors meet the requirements laid out in the Pressure Equipment Directive 97/23/EC and photovoltaic modules meet the requirements laid out in Low Voltage Directive 2006/95/EC. In addition, “normal flammability” in accordance with DIN EN 13501-1, class E, or B2 in accordance with DIN 4102-1, will then also need to be verified via a declaration by the manufacturer of the collector or module.
The problem: The testing method detailed in DIN EN ISO 11925-2 that is applicable here is restricted to test specimens measuring 90 × 250 mm, which is not practical for solar modules and can represent a problem in terms of process engineering. Consequently, TÜV Rheinland has worked together with the experts at CURRENTA to develop a new testing method based on DIN EN ISO 11925-2, which allows conclusions to be drawn about the flammability of solar modules and collectors. “In this way, we aim to provide manufacturers worldwide with a tool that delivers reliable fire behavior predictions for their products. This gives them an accurate forecast that the material compounds are suitable for ‘normal flammability’ classification in meeting the upcoming building regulation requirements in Germany,” says Althaus.
The newly developed testing method also incorporates findings from an extensive research project on preventive fire protection in photovoltaic systems, which is being conducted by TÜV Rheinland together with the Fraunhofer Institute for Solar Energy Systems and Deutsche Gesellschaft für Sonnenenergie (German Solar Energy Society, DGS) with the participation of CURRENTA and with the support of the German Solar Industry Association with other partners up to 2014. Some parts of the project are being sponsored by the German Federal Ministry for the Environment.
In cases where products are required to be flame-retardant or non-combustible (for example in façade installations), a General Building Inspectorate Test Certificate is required. Verification is provided either in the form of a declaration of conformity or a conformity certificate from a recognized certification body. This, in turn, is a necessary prerequisite for issuing the compliance mark required in Germany. In accordance with Section 23 of the German Model Building Code (MBO), the manufacturer’s declaration of conformity must only be issued if the manufacturer "has ensured, through internal production checks in the factory, that the building product manufactured by him satisfies the relevant technical rules, the requirements for General Building Inspectorate Approval, the requirements for a General Building Inspectorate Test Certificate, or the specific approval requirements in individual cases."
All collectors and modules affected by the reforms
DIBt is a joint institution set up by the Federal Republic of Germany and the federal states. If the new rulings announced by DIBt do arrive in Germany in their currently planned form, this will affect all photovoltaic modules and solar collectors that are currently on the market, not just integrated systems in buildings. In Germany, solar collectors with a mechanically fixed glass covering and a maximum individual glass pane surface area of 3 square meters designed for use in roof areas (up to a maximum slope of 75 degrees) are, in the future, to be defined as regulated building products, along with collectors for free-field installations that are not tied to a building and are situated in non-publicly-accessible areas. The same requirements will apply to photovoltaic modules, albeit with a maximum individual module area of 2 square meters. However, verification of individual components in accordance with the requirements of the Building Products Law will be required in addition to the already-applicable European directives.
Other existing fire tests for photovoltaic modules as already offered by TÜV Rheinland are not suitable for the planned manufacturer’s declaration in Germany and will not be affected by the announced changes. For example, TÜV Rheinland will continue to offer unchanged fire tests designed to test the resilience of modules to the effects of external fire, thereby offering all manufacturers full testing in accordance with ANSI/UL 1703 for market entry in North America. The photovoltaic test standards IEC 61730 and ANSI/UL 1703 include a mandatory fire test requirement for photovoltaic modules, which in turn refers to two different tests in UL 790: the burning brand test and the spread-of-flame test.