1.1 The loss of legitimacy of private standards

NFPA (the National Fire Protection Association) and UL (Underwriters Laboratories) are private organisations. Once incorporated by reference into the law of the European Union and the United States, their documents acquire binding force without passing through the procedural guarantees of public law. In 2016 the Court of Justice of the European Union (CJEU) expressly held that harmonised standards form “part of Union law”. From this follows a question of legitimacy: a text private in origin becomes law without a full public procedure.

Where the speed of publishing a standard outpaces reproducible technical verification, the function of safety control is displaced by the function of commercial circulation. The standard ceases to certify safety and begins to certify market access.

To this is added a lack of independence. UL — the body that certifies products to NFPA 2010 — is at the same time represented on the technical committee that develops that standard. The certifying party takes part in writing the very norm against which it certifies.

1.2 The internal contradiction of EN 15276

The European standard EN 15276 consists of two structurally uncoordinated parts: Part 1 governs individual components; Part 2 governs the characteristics of the system as a whole and toxicological safety. In practice Part 2 is not applied: there are no systems certified to Part 2, and there are no accredited testing bodies capable of implementing its requirements.

Moreover, the requirements of Parts 1 and 2 are internally contradictory: achieving the extinguishing performance required by Part 1 leads in practice to exceedance of the temperature and toxicity thresholds set by Part 2. A norm that cannot be satisfied simultaneously is, in operational terms, untestable.

1.3 The procedural status of NFPA 2010

NFPA 2010 is the antecedent private standard from which ISO 15779 and EN 15276 are structurally derived. The procedural status of its current edition is not confirmed by the public record. The public archive of the NFPA Standards Council for the period 2020–2026 contains no record sufficient to confirm that the NFPA 2010-2025 edition was approved through proper procedure; the preliminary minutes of the Council’s April 2026 meeting do not list that edition at all.

In a letter dated 30 April 2026 the NFPA acknowledged in writing procedural deficiencies in the development of NFPA 2010, including an imbalance in the composition of the technical committee at the time of balloting of the second draft of the 2025 edition. Because EN 15276 and ISO 15779 rest structurally on NFPA 2010, the unconfirmed status of the latter extends to the derivative normative documents.

Certification against this foundation is, in addition, deprived of its object. Under pressure from Impulse Storm’s market-surveillance submissions, UL acknowledged the unfeasibility of Part 2 of EN 15276 and confined the scope of its certification to the product up to the moment of installation. The installed, operating system falls outside that scope.

2.1 Government tests of intrinsic toxicity

Commissions of state authorities in four states — the United States, Finland, the United Kingdom and the Republic of South Africa — have tested condensed aerosol fire-suppression systems. Their results consistently establish one thing: the impossibility of simultaneously satisfying the declared extinguishing performance and the safety thresholds for exhaust-gas temperature and toxicity set by the standards themselves.

2.2 Documented deaths in the absence of fire

The following are cases of loss of life in occupied spaces where the lethal condition was created by the extinguishing agent itself, not by a fire. All three episodes predate the 2025 issuance.

3.1 Twenty years: court rulings and legislative reform

Over the past two decades the relationship between private standards and the law of the European Union has changed chiefly along two lines: through court rulings and through a single wave of legislative reform. Both are systemic in nature and were initiated by the courts or by the legislature, not by an individual technology developer.

3.2 The scale of the system and the rarity of this case

To gauge how exceptional this initiative is, it is enough to compare it with the ordinary practice of European technical assessment.

European Assessment Documents are, with rare exceptions, requested by a manufacturer to certify a single product not yet covered by a harmonised standard. The nine-month procedure for preparing them presupposes an existing methodological basis. The interventions of the past two decades, by contrast, arose at the level of the Court and the legislature and were systemic in nature.

Germany — the institutional procedure

The German Institute for Construction Technology (Deutsches Institut für Bautechnik, DIBt) in Berlin is the Technical Assessment Body conducting the procedure for developing a European Assessment Document and the subsequent European Technical Assessment (ETA) under the Construction Products Regulation (EU) 2024/3110. The procedure was initiated in late 2025, went through substantive engagement in 2026, and is ongoing. The legal and procedural framework of the future standard is thereby provided by an authorised institution of a member state of the Union.

Finland — the verifiable test

The Emergency Services Academy Finland (Pelastusopisto) carried out the only verifiable full-system comparative test (protocol PeODno 2025-133, 2025) under accredited European methodologies for determining extinguishing performance and safety parameters. That report constitutes the sole verifiable starting basis for building a new standard in technical terms.