Conversion to Lead Free Copper Alloys

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% as measured by NSF/ANSI/CAN 372-2020. This is the same assessment standard that was adopted in 2014 by the USA for assessing their copper alloy products.

There are at least 44 Australian Standards and WaterMark Technical Specifications (WMTS) that must be amended to include and specify the new lead-free copper alloys. This will happen over the next few years but as an interim measure, a Notice of Direction (NoD) has been issued by the ABCB overriding the material specifications in the current standards, with regard to lead content and testing. Refer to Notice of Direction 2022/1.1 Acceptable copper alloys for the manufacture of Lead Free plumbing products for materials requirements and recommendations for Lead Free plumbing products.

Real World Challenges

Manufacturers are now selecting Lead Free copper alloys, or substitute material, and learning how to utilise these materials. Different copper alloys have different characteristics in how they melt, cast, forge, and machine, so it is not just a simple process of swapping alloys but a major redesign of the manufacturing process.

Certification for Lead Free compliance is by a WaterMark Conformity Assessment Body (WMCAB) of which there are currently 7 accredited to do this work. There are at least 775 licences that need to be assessed covering thousands of product lines so the WMCABs have a big job to complete this over the next 2 years.

Marking

All compliant Lead Free products will need to be identified with a new Lead Free WaterMark certification trademark. Notice of Direction 2022/2.0 Marking requirements for Lead Free plumbing products specifies the marking requirements and recommendations for Lead Free plumbing products. Marking consists of the letters LF or words Lead Free to be included adjacent to the WaterMark logo on the product.

The supply chain for plumbing products from the manufacturer to the installer is also a major issue considering that there are millions of items either in transit or currently held in stock. Existing stock needs to be used and resupplied well in advance of April 2026. Major plumbing merchants are already starting to specify the new products with some accepting only Lead Free product from 2025. Even suppliers who have Lead Free copper alloy products available, must have their products tested, then assessed for certification by a WMCAB and permanently identified with the Lead Free WaterMark. It is not just a process of putting a new sticker on the packaging.

Last, but certainly not least, the responsibility for the use of compliant products will rest, as it does now, with the licensed plumber at the point of installation. Enforcement of the requirements will be undertaken at the point of installation by the state or territory plumbing administration having jurisdiction.

In Queensland, under section 74AF of the Queensland Building and Construction Commission Act 1991 (QBCC Act), each person within the chain of responsibility has a duty to ensure their actions do not lead to a Non Conforming Building Product being supplied and/or used in association with a building. So, everyone should be aware of the regulations and how to identify Lead Free certified products.

There is some time before the new requirements are enforced in April 2026, but the conversion of product, certification process, supply of new stock, and depletion of old stock will take considerable time so it is better to plan early and be ahead of the game where you can.

Article from the International Copper Association Australia