An Article Series: “Compliance, Confidence, and the Cost of Cutting Corners”

INTRODUCTION Across South Africa’s infrastructure sector, tender documents often reference international standards like EN 12101 for fire and smoke control systems. On paper, this signals alignment with world-class benchmarks. In practice, however, referencing EN does not guarantee that the systems being supplied are actually EN-certified. This gap, between specification and delivery, is what we call the tender trap.

WHERE THE TENDER TRAP LIES Tender requirements can be reduced to a “checkbox” exercise. If EN is referenced in the tender, bidders claim compliance, often through:

↳ Locally assembled systems that use CE-marked components but lack full EN certification.

↳ Outdated certificates (e.g. EN 12101-2:2003* or EN 12101-3:2002, both withdrawn years ago).

↳ Documentation that shows testing of parts, not certification of the complete system.

On the surface, the box is ticked. But in reality, the tender process can accept systems that do not legally or technically meet the EN framework.

WHY IT MATTERS

1. Professional Liability~ Under the National Building Regulations, the Competent Person who signs Form 3 is personally declaring compliance. Approving a system that is not fully EN-certified exposes them to liability, disciplinary action, and even insurance exclusions.

2. Public Safety ~ Fire and smoke control systems are life-safety systems. In underground car parks, high-rise developments, and EV-ready basements, substitution is not just a paperwork issue – it can cost lives.

3. Project Risk ~ Non-compliant systems may undermine ESG claims, void warranties, or compromise future insurability of the building.

THE PATH FORWARD If EN standards are specified, they must be enforced with the same rigour as in Europe:

• Require valid and current Declarations of Performance (DoPs).
• Verify Certificates of Constancy of Performance (CoCPs), FPCs that list the actual manufacturing site being certified.
• Ensure all documentation originates from a NANDO-listed system holder.

CONCLUSION The tender trap is simple: EN standards are referenced, but not enforced. To protect lives, reputations, and South Africa’s infrastructure future, the industry must move beyond the checkbox and demand traceable, system-level compliance.

IC Colt – Kingspan Light + Air – Colt International

Next in the series: Part 2 – The Insurance Gap

Note: EN 12101-2:2003 was formally withdrawn with the publication of EN 12101-2:2017. However, as the 2017 version has not yet been harmonised under the EU Construction Products Regulation, the 2003 version remains the last harmonised basis for CE marking. Certificates referencing 2003 can therefore still be valid, but only when current, traceable, and issued by a NANDO-listed system holder.