The requirement for them to be 'non-combustible' (which for practical purposes means steel), was introduced 8 years ago.
For the benefit of Peterpies, the "offending" regulation is :
421.1.201 Within domestic (household) premises, consumer units and similar switchgear assemblies shall comply with BS EN 61439-3 and shall:
(i) have their enclosure manufactured from non-combustible material, or
(ii) be enclosed in a cabinet or enclosure constructed of non-combustible material and complying with Regulation 132.12.
Which as you may note, does not say what is considered non-combustible. There are standards for assessing combustibility, but the committee that writes BS7671 decided (for whatever reason) not to reference any of them. If you've ever seen video of an oxygen lance being used to dismantle even reinforced concrete, you'll realise that given the right (or wrong) conditions most things are combustible.
However, the authors added a note :
NOTE: Ferrous metal, e.g. steel, is deemed to be an example of a non-combustible material.
So despite steel being very much combustible if you apply enough heat and oxygen, they've said it is considered non-combustible and hence it's OK to use it. Hence why Flameport says "which for practical purposes means steel".
Many plastics are, by the tests used in many standards, also non-combustible - but because the regulations is so badly written, there's no objective way to say that anything other than steel is compliant. I would think that most of the decent brand CUs will have been made of flame retardant plastics and in practice pose little risk.
The risk is, BTW, that when there's a fault (such as a loose connection where the meter tails connect to the main switch), heat can be generated, and that can cause the plastic to burn. It is a widely held view that the regulation was put in to satisfy those well known electrical experts, the London Fire Service, who observed a rise in domestic fires which originated at the consumer unit - but chose to get this regualtion added rather than tackling the poor workmanship of meter fitters disturbing the meter tails while fitting "smart" meters and not properly checking the terminals for tightness afterwards.
Needless to say, there was "some disquiet" from people being told that their newly fitted consumer unit - perhaps upgraded to meet rules on RCD provision - was now "unsafe" and needs replacing again. Not to mention, that there would not have been enough electrician around to have replaced them in a timely manner.
And, as will be of interest to yourself as a landlord, we come to EICR time. There was "some debate" in the industry as to how a plastic CU case should be coded - with opinions and arguments for anything from a C2, through C3, to not coded at all. I had an email exchange with someone from the standards committee who advised that a pragmatic approach would be to code C3 where the CU was under wooden (i.e. combustible) stairs or in an escape route, and to not mention otherwise. However, despite phrasing things as if this was the view of the committee, he would not commit to anything more than this being his personal opinion.
If you are now thinking this is a somewhat unsatisfactory state of affairs, you are far from alone. The committee cannot not realise this - I'm sure I am not the only one who has raised this with them. Yet they have failed to improve things in the (IIRC) at least 2 updates since this regulation was introduced.
So where does this leave you ?
If your inspector is telling you that you "must" replace the CUs, then I would suggest they are being a little dishonest - bear in mind that many unscrupulous people use EICRs as a means of generating work, and offer inflated quotes for it. This is not helped by knowing that they can code a C2 for a landlord and then the clock starts ticking on the 28 days in which the landlord must rectify it. If they are saying it's a C2 then they are most likely in this category.
So, assuming you have a more honest inspector, then it may be coded as a C3. You do not have to fix these, it is up to you to work out the risks and benefits.
I see two risks :
One is that there is a fire, and someone blames the plastic CU for it - and by implication, you for not replacing it. But a plastic CU will not catch fire all by itself, there needs to be a fault to generate heat. Simple maintenance (checking all terminals for tightness), which (for me) would be part of a routine EICR will deal with most of those anyway. Also, the location of the CU will have a significant impact on the severity of the risk - if it's not where it would impede evacuation after all the smoke alarms go off, then there's not really any risk is there ?
The other is the "professional chancer" tenant - the sort that knows the rules inside out and will use any excuse to try and extort money out of you or justify not paying the rent. Not been there myself, but I'm sure some of them would use the presence of a C3 in the EICR as justification as to why the property is dangerous.
As an alternative, do note the (ii) above "
be enclosed in a cabinet or enclosure constructed of ..." Plasterboard is accepted in the building industry as non-combustible, so one option could be to fully line a cupboard containing the CU with that - and ensure it has a good catch to hold the door shut.
But really each installation needs to be considered on it's own merits.