Update: Advice on the new lead requirements

The 2022 edition of the National Construction Code (NCC) will introduce a new limit for the allowable level of lead in plumbing products used for drinking water. From 1 May 2026, copper alloy plumbing products containing more than 0.25% lead will no longer be authorised for installation in a plumbing system used to convey drinking water.

The Australian Building Codes Board (ABCB) agreed to a three-year transition period to allow industry to make the necessary changes to provide products to the market in compliance with this requirement.

On 21 April 2023, the ABCB redetermined the commencement and completion dates for the three-year transition period to support Australia’s path to reducing allowable lead levels in many plumbing products.

The ABCB expects a new “Lead Free WaterMark” trademark to be formally registered on 2 May 2023, allowing a Notice of Direction to be issued that same day. The three-year transition period will commence with the issue of the WaterMark Notice of Direction.

All relevant products will be required to meet the new requirements by the specified date of 1 May 2026.

While this is 8 months later than originally planned, the ABCB recognises that delays in the registration of the trademark and ongoing supply chain constraints will present difficulties for some lower-volume products.

The ABCB has worked closely with industry bodies, including the Australian Industry Group and Plumbing Products Industry Group, to help manufacturers and suppliers prepare for the new requirements.

During the transition period, conforming products will start to be manufactured with labelling on the product to indicate compliance with the NCC’s lead requirements. This will help you easily identify compliant lead free products.

Key manufacturers and suppliers have confirmed that many products, especially in important categories like tapware, will be WaterMark certified lead free within the first half of the transition period.

Many of these products will be available in the market in 2024, delivering important public health benefits to the community.

Until 1 May 2026 plumbing practitioners may continue to install existing products that are certified in accordance with the WaterMark Certification Scheme, including products with a reduced level of lead. However, from 1 May 2026 only products marked with the “Lead Free WaterMark” will be authorised for use.

Clause A5G4 of NCC 2022 Volume Three (Plumbing Code of Australia) specifies that all copper alloy plumbing products in contact with drinking water must limit the allowable lead content of copper alloy plumbing products in contact with drinking water to a weighted average lead content of not more than 0.25%.

The ABCB commissioned Macquarie University in 2018 to undertake a literature review to determine to what extent plumbing products may contribute to lead levels in drinking water in excess of those permitted by the Australian Drinking Water Quality Guidelines.

Macquarie University’s Lead in Plumbing Products and Materials Report (the Report) confirmed that, although Australia’s drinking water is of a high quality and meets the Australian Drinking Water Quality Guidelines, there is potential for lead to leach from copper alloy plumbing products in contact with drinking water.

In response to the Report’s findings, the ABCB released a Regulation Impact Statement (RIS) for public consultation. The RIS analysed whether the allowable lead content in plumbing products should be reduced and assessed alternatives to address the issue. The Decision RIS was used to assist the ABCB in deciding to reduce the allowable level of lead in certain plumbing products.

All copper alloy products that are in constant contact with drinking water will be required to comply with the lead requirements of the NCC. These include: fittings, valves, backflow prevention devices, taps, mixers, water heaters, water dispensers (boiling and cooling units) and water meters.

The WaterMark Schedule of Products outlines all plumbing products which require WaterMark certification to be authorised for installation in a plumbing or drainage system. This schedule also outlines which products must comply with the lead requirements of the NCC.

No, the lead requirement does not apply to all plumbing products. Some products that are not in constant contact with drinking water and have a low likelihood of being used for drinking water consumption are exempt.

These include products such as shower heads, washing machines, dishwashers, commercial boilers (associated with HVAC systems), emergency deluge showers and eyewash equipment.

Copper alloy products used in fire-fighting equipment, irrigation systems and recycled water systems are also exempt from the lead requirement because they are not in contact with drinking water.

Existing copper alloy products in the marketplace that are not compliant with the NCC’s lead requirement can only be used until 1 May 2026. Beyond this date these products may be used in other applications that are exempt, such as systems that are not used to convey drinking water.