Imported building products and Australian standards: WaterMark, CodeMark, AS/NZS and RCM explained

Non-conforming imported building products do not fail at the factory. They fail at inspection, at handover, or in a defect claim years later — by which time the container is long gone and the person holding the problem is you.

This is a plain-English guide to the four schemes that come up most often on imported building materials, what each one actually is, and where to verify a claim rather than take a PDF at face value.

First, the thing that governs all of it: evidence of suitability

The National Construction Code (NCC) does not simply say “use compliant products”. It sets out what counts as evidence that a product is suitable for its intended use. In the NCC 2022 numbering:

• A5G2 deals with the form of the evidence — broadly, it must be a complete, unabridged copy of the original.
• A5G3 lists the types of evidence accepted for building products (NCC Volumes One and Two).
• A5G4 covers plumbing and drainage products (Volume Three).

The evidence types accepted under A5G3 include a current CodeMark Certificate of Conformity, a certificate of accreditation from a State or Territory accreditation authority, a certificate from a certification body, a test report from an Accredited Testing Laboratory, a report or certificate from a professional engineer or other suitably qualified person, and other documentary evidence such as a Product Technical Statement.

One thing to get right: which NCC edition applies depends on your State. NCC 2025 was released on 1 May 2026, but adoption is a State decision. New South Wales, Queensland and South Australia are adopting NCC 2025 from 1 May 2027, so projects in those States are still working to NCC 2022. Check the edition in force where the project is, not the newest edition published.

WaterMark — plumbing and drainage, and it is mandatory

The WaterMark Certification Scheme is administered by the Australian Building Codes Board and is mandatory for plumbing and drainage products of the types listed in the WaterMark Schedule of Products. It also captures appliances and commercial catering equipment connected to the water service or sanitary plumbing.

A certified product holds a WaterMark Licence, evidenced by a WaterMark Certificate of Conformity issued by an Approved Certifier, valid for up to five years. Certification involves independent type testing, factory audits and ongoing batch release testing — it is not a one-off test.

How to verify: search the WaterMark Product Database by licence number, brand, model or specification. Approved Certifiers must upload certified products within seven days of issue. If an in-scope product is not in the database, that is the answer.

One note if you are reading older material: the Level 1 and Level 2 WaterMark schemes were replaced by a single scheme from August 2017. Certificates or advice referring to “Level 1” or “Level 2” are describing a system that no longer operates.

CodeMark — voluntary, but strong evidence when you have it

CodeMark Australia is a voluntary third-party certification scheme, also administered by the ABCB. A certified product carries a Certificate of Conformity, and A5G3(a) names it as the first form of accepted evidence of suitability under the NCC.

Because it is voluntary, the absence of a CodeMark certificate does not mean a product is non-compliant. It means you need one of the other evidence types. The practical value of CodeMark is that it is nationally recognised and hard to argue with — which matters when a certifier or a superintendent is deciding whether to accept a product.

How to verify: the register of CodeMark Certificates of Conformity is maintained by JAS-ANZ and linked from the ABCB’s CodeMark site.

Steel reinforcement — AS/NZS 4671, and a common misconception

The relevant standard is AS/NZS 4671:2019 Steel for the reinforcement of concrete, covering chemical, mechanical and geometric properties of deformed and plain bar, machine-welded mesh and continuously threaded bar. It does not cover prestressing steels, stainless, epoxy-coated or galvanised reinforcing steel.

Here is the misconception worth correcting: ACRS certification is not legally mandatory. The Australasian Certification Authority for Reinforcing and Structural Steels states plainly that it is “a voluntary third-party accreditation system – it is not compulsory.”

What is true is that ACRS certification is contractually required on a great many Australian projects — government agencies procuring through ATIC specifications require third-party certification and require the certifying body to be JAS-ANZ accredited. The Australian Steel Institute recommends both third-party certification and mill certificates for structural steel.

So the accurate framing for an importer is: not required by law, frequently required by the contract, and the practical route to satisfying NCC evidence-of-suitability requirements. Check the project specification before you order, not after.

Appliances and electrical goods — RCM and the EESS

The Regulatory Compliance Mark (RCM) represents compliance with two separate schemes: the Electrical Equipment Safety System (EESS) for electrical safety, and the ACMA’s labelling requirements for telecommunications, EMC and radiocommunications. The mark itself is defined in AS/NZS 4417.1 and 4417.2.

Under the EESS, in-scope equipment is classified by risk under AS/NZS 4417.2:

• Level 1 — low risk. Equipment registration voluntary; evidence of compliance mandatory; RCM mandatory.
• Level 2 — medium risk. Equipment registration mandatory; compliance folder mandatory and must be produced within 14 days of a request from a regulator.
• Level 3 — high risk. Equipment registration mandatory; a Certificate of Conformity is required.

The point importers most often miss: if you are the one bringing the goods into Australia, you are the Responsible Supplier. The Responsible Supplier must be an Australian or New Zealand registered legal entity and must be registered on the national database (the EESS Platform) before the equipment is sold. An overseas manufacturer cannot hold that role for you.

Why this is not a paperwork exercise

Australia has been through this. The Senate Economics References Committee’s inquiry into non-conforming building products delivered its final report in December 2018 with 13 recommendations, after interim reports on aluminium composite cladding (September 2017) and asbestos (November 2017). Submissions to that inquiry recorded imported structural steel with falsified test certificates, welds made with silicone rubber and painted over, and tube filled with water to compensate for underweight steelwork.

The same report records glass supplied to 150 Collins Street in Melbourne that did not meet specification, requiring replacement of half the building’s glass at an estimated cost of $18 million.

The Infinity electrical cable recall — announced by the ACCC in August 2014 and covering around 40,000 homes and commercial premises — involved cable whose insulation was expected to become brittle from 2016, creating electric shock and fire risk.

And the Lacrosse tower fire in Melbourne in November 2014 led to a VCAT decision in 2019 awarding $5,748,233, in which the tribunal found that both the aluminium composite panel originally specified and the substitute actually installed failed to comply with the Building Code of Australia.

The Shergold Weir Building Confidence report, delivered to the Building Ministers’ Forum in 2018 with 24 recommendations, put the underlying problem plainly: decisions made during design and construction need to be visible, and the people making them need to be identifiable and accountable.

What to actually do

• Confirm which NCC edition applies in the project’s State before you specify.
• For plumbing products, search the WaterMark database yourself. Do not accept a PDF.
• For reinforcement and structural steel, read the project specification for third-party certification requirements before you order.
• For appliances, confirm who the Responsible Supplier will be and get them registered before the goods are sold.
• Ask for certification and test documentation as part of pre-shipment inspection, not after delivery.
• Keep the complete, unabridged original documents — A5G2 is specific about this.

Where your order calls for it, Linkwox’s pre-shipment check covers the certification and documentation supplied with the goods, and we report what we find. Verifying and accepting compliance for your project remains your responsibility and your certifier’s. This article is general information only and is not legal or professional advice; confirm current requirements with the ABCB, your certifier and the relevant State regulator.