WaterMark certification is more than obtaining a test report or receiving a certificate. It is a controlled product-certification pathway that connects the applicable product specification, technical evidence, an approved Product Quality Plan, manufacturing controls, an independent certification decision and continuing surveillance.
Five-year certification cycle
Initial assessment is followed by annual surveillance and full recertification before the certification term expires.
Annual product review
Representative products, production evidence and continued implementation of the approved controls are reviewed every year.
Additional Lead Free oversight
Lead Free certification includes mandatory annual on-site audits at every applicable manufacturing location.
Start with the product and its intended use
The first step is to define the exact plumbing or drainage product, its materials, models, intended application and proposed Australian market. CSi reviews the current WaterMark Schedule of Products to identify whether certification is required and which product specification applies.
Applicants should provide available drawings, product descriptions, material information, existing test evidence, manufacturing locations and model details. Early definition of the proposed certification scope helps avoid testing or documentation that does not address the product that will ultimately be supplied.
Testing must support the proposed certification scope
CSi establishes the technical evidence required by the applicable product specification and WaterMark Certification Scheme. Testing must be undertaken by an acceptable laboratory using representative products and the relevant test methods.
A test report is important evidence, but it does not by itself grant WaterMark certification. CSi evaluates the complete body of evidence, including product construction, models and variants, materials, integral components, markings, installation instructions and any stated limitations.
The WaterMark Scheme requires a Product Quality Plan
The Manual for the WaterMark Certification Scheme requires the manufacturer to establish and maintain a Product Quality Plan. The plan defines how certified products will be manufactured, inspected, tested, released and controlled so that continuing conformity can be demonstrated.
The Product Quality Plan may be a standalone document. Where the manufacturer operates a broader quality-management system, the required controls may be incorporated within that system, provided the WaterMark requirements are clearly identified, implemented and available for assessment. The format may vary, but the required Product Quality Plan and manufacturing controls are not optional.
Manufacturing controls are assessed before certification
For initial certification, CSi undertakes an on-site Business Review of the manufacturing location. The assessment considers the Product Quality Plan, personnel responsibilities, purchasing and supplier controls, incoming materials, production processes, inspection and batch-release testing, calibration, traceability, nonconforming product, complaints and corrective action.
Any findings must be addressed satisfactorily. The completed evaluation is then independently reviewed before an impartial certification decision is made. Certification is granted only when the applicable product, evidence, manufacturing and scheme requirements have been met.
Preparing for WaterMark Lead Free requirements
From 1 May 2026, products identified in the WaterMark Schedule of Products as being subject to the Lead Free requirements must be tested, certified and manufactured in accordance with those requirements. Nationally, the general installation transition continues until 1 May 2028; state and territory arrangements can differ.
In Victoria, the installation requirements took effect on 1 May 2026. For relevant plumbing work commencing on or after that date, affected copper-alloy plumbing products intended to be in contact with drinking water must satisfy the applicable WaterMark Lead Free certification and marking requirements. The Victorian compliance date is determined by when the plumbing installation commences—not the date of purchase, design, building permit, project approval or contract.
For an affected product, ‘Lead Free’ means a weighted-average lead content of no more than 0.25% for the relevant product or material in contact with drinking water. It does not mean that the product contains absolutely no lead. Applicability should be confirmed with CSi during application review because it depends on the product, its materials, intended use and current WaterMark schedules.
Certification continues after the licence is issued
WaterMark certification operates on a certification term of up to five years. Continued certification and authority to use the WaterMark during that term are conditional on successful product-conformity surveillance at least once every 12 months.
For products that are not subject to the Lead Free requirements, annual surveillance may be undertaken through a remote or desktop Business Review supported by the selection and inspection of representative certified products. Samples may be obtained from the manufacturing facility, distributor, warehouse or marketplace and inspected at a location determined by CSi.
The annual review examines the approved Product Quality Plan, batch-release results, complaints, nonconformities, corrective action, internal audits, management reviews, calibration, suppliers, product specifications, drawings, critical components, markings, installation instructions and WaterMark Scope of Use. It also checks for changes to the product, materials, manufacturing process, suppliers, manufacturing location or legal entity.
Where the evidence is satisfactory, certification continues within the five-year term. If CSi identifies a concern, it may require corrective action, further product inspection, additional testing, a follow-up Business Review or an on-site factory assessment before certification can continue.
Lead Free products have additional annual on-site audits
ABCB Notice of Direction 2022/4.0 requires an annual on-site factory inspection and audit at every manufacturing location producing products certified to the Lead Free WaterMark requirements. This is additional to the ordinary annual product-conformity surveillance requirements.
The inspection allows CSi to assess approved copper alloys and other wetted materials, suppliers and traceability, material substitutions, applicable lead-washing or acid-pickling processes, production and batch-release controls, testing records, authorised marking and implementation of the approved Product Quality Plan.
The direction currently applies until five years after 1 May 2026. Before that period concludes, the ABCB intends to review compliance outcomes and determine whether the additional annual factory-inspection requirement should continue. CSi will apply the current requirements and any subsequent ABCB directions.
Full recertification is completed before year five ends
A full recertification assessment is undertaken before the five-year certification term expires, normally beginning during the final three to six months. It includes re-evaluation against the current scheme and product requirements, review of the Product Quality Plan, an on-site manufacturing assessment, product inspection and applicable testing by an accredited laboratory.
Certification does not automatically continue beyond its expiry date. The recertification evidence must be evaluated and a new independent certification decision made before another certification term can be granted.
Speak directly with Robert
Robert Hardgrove, CSi Manager, WaterMark Scheme, can discuss a new application, proposed product change, surveillance requirement or approaching recertification.
Email Robert@csi-certification.com or telephone +61 2 9728 7608.