At Gateways 2 and 3, designers and contractors, respectively, are no longer solely responsible for demonstrating their own competency: they must also show that the products and partners they rely on are equally competent. For passive fire protection systems, this is particularly critical. The performance of cavity barriers, firestops, and other fire-resisting elements depends not only on design and installation, but on the quality, clarity, and reliability of the data behind them. Choosing a competent supplier is therefore a key consideration in achieving a successful Gateway 2 applications and Gateway 3 compliance and securing a Completion Certificate. 

Whilst manufacturers are not formal duty holders in the same way as contractors or designers, their role has evolved significantly under the Building Safety Act. The Construction Leadership Council (CLC) highlights this clearly in its Building Control for a New Higher-Risk Buildings Guidance Suite: 

“Manufacturers of safety-critical products play a key role in trying to ensure that their products are installed correctly and perform as intended.” 

This means manufacturers are expected to actively support accurate specification and compliant design, and correct installation aligned with tested performance 

In practice, this means a construction product manufacturer that is consulting on the suitability or use of a product in a scheme of works and/or providing advice or feedback on the design could potentially fall under the broad definition of a ‘designer’ as a party carrying out a level of design work. Although the regulations do not explicitly address this circumstance, manufacturers should take responsibility for the advice they provide and, where appropriate, act in accordance with the principles and duties that apply to designers. This reinforces the importance of competency, transparency and accountability across the construction product sector.  

Sections 148 and 149 of the Building Safety Act enable claims to be brought directly against manufacturers that breach construction product requirements, make misleading statements about their products, or supply products that are inherently defective. Liability may arise where such products contribute to personal injury, economic loss or property damage and result in a dwelling being deemed unfit for habitation. 

Therefore, construction product manufacturers should ensure the products and services they provide support robust specifications, accurate installation, and effective information management. 

The CLC guidance sets out clear expectations for how Principal Contractors should assess and engage manufacturers: 

Product assurance and certification 

A competent supplier should be able to demonstrate robust product assurance, including third-party certification and test evidence aligned with current standards. Crucially, there must be a clear link between tested systems and their real-world application on site, ensuring products will perform as intended when installed correctly. This may look like: 

• Supporting standard testing needed for regulatory compliance, with supplementary testing relevant to their application e.g. testing cavity barriers with masonry brackets. 

• Comprehensively testing both incoming raw materials and finished products to ensure manufactured products are safe and fit for purpose. 

• Maintaining robust factory process control systems and regular auditing of quality management processes. 

CCPI certification and product information quality 

The Code for Construction Product Information (CCPI) provides a benchmark for trustworthy product data. In addition to assessing creation, maintenance and distribution of product information, it evaluates organisational leadership and culture. Manufacturers should be able to evidence certification and demonstrate that their information is clear, accurate, accessible, and unambiguous—supporting consistent specification decisions and reducing the risk of misinterpretation during installation Robust collateral management systems such as Product Information management (PIM) platforms that enable access to a ‘single source of truth’ and traceability on any changes to product data can instil confidence in that information is up to date. 

Competency of manufacturer teams 

Supplier competency extends beyond products to the people behind them. Manufacturers should operate internal competency frameworks and ensure consistent training across technical, sales, and site teams. This could mean site service engineers who deliver product installation training onsite completing OFQUAL Professional Level 3 Awards in Education and Training to demonstrate their competency in this field. For technical service engineers giving design advice, this could involve achieving professional qualifications such as those provided by the IFE (Institution of Fire Engineers). 

This helps ensure that advice is reliable, repeatable, and aligned across all project interactions. 

Technical support and installation guidance 

Manufacturers should provide detailed technical support to bridge the gap between design and installation. This includes clear installation guidance, project-specific advice, and alignment with tested system configurations, helping contractors ensure that what is built reflects both the design intent and regulatory requirements. 

Inspection and site support services 

Strong suppliers will offer inspection and site support services to verify installation quality. This may include site visits, benchmark installations, and the use of digital tools to record and review installation evidence. These services play a critical role in building a robust and auditable evidence base for Gateway 3. 

Record keeping and Golden Thread contribution 

Manufacturers should maintain accurate, project-specific records of the information they provide, including technical advice, documentation issued, and interactions with the project team in a secure digital storage environment. This information contributes directly to the Golden Thread, supporting traceability and transparency across the building lifecycle.  

Escalation and compliance processes 

A competent supplier should also demonstrate a clear and documented approach to managing risk. This includes defined escalation processes, mechanisms for raising non-compliance, and the ability to notify Principal Contractors of Mandatory Occurrence Reports (MORs). This reflects a proactive and accountable approach to building safety. 

At Siderise, we recognise that competency is not just about products—it’s about supporting contractors to deliver safe, compliant buildings with confidence. 

Our approach includes: 

• Clear, CCPI-aligned product information. 

• Expert technical and site support services. 

• A digital Inspection App to support real-time installation verification. 

• A centralised CRM system that tracks:  

• Project involvement. 

• Technical support. 

• Training delivered. 

This creates a structured, auditable record that can be used to support Gateway 3 submissions, reinforcing both collaboration and accountability. 

As the industry moves towards a more accountable, evidence-led approach to building safety, the role of manufacturers is becoming increasingly important. Choosing a passive fire protection supplier is no longer just a procurement decision. By working with competent and transparent manufacturers from early in the design and construction process, project partners can reduce risk, improve quality, and build the robust evidence required to secure a Completion Certificate.