I won't argue with that statement, per se, but, in reality, it will only be a 'fire risk' if/when the CU/meter or something associated catches on fire, in which case one presumably would have a problem even with a tidy./empty cupboard - at least, that's what Mr LFB seems to believe, because I haven't seen or heard any suggestion that domestic CUs only have to be 'non-combustible' if they are in cluttered cupboards