Yes.
Reason:
1) Even though extinguishing gas (such as CO2 or inert gas) piping will be only momentarily pressurised during activation of the extinguishing system and such piping is open at the discharge end, it will be exposed to a pressure PS above 0,5 bar.
2) The piping of a sprinkler system is not considered to be covered by exclusion of Article 1 paragraph 2 (b), as it is not a network for the supply, distribution and discharge of water.
Note 1:
The location where the pressure PS is specified shall be such to be representative of the maximum pressure to which the piping will be exposed.
Note 2:
Table 7 of Annex II is to be used for classification if content is CO2, or inert gas. For sprinkler systems, table 7 is to be used for “dry piping installation”, and table 9 for water.
Note 3:
The PED is limited only to pressure-related hazards. Function and performance of fire extinguishing systems are not covered by the PED.