NSW building-owner and strata guide

Combustible Cladding in NSW: Identification, Risk and Next Steps

Combustible cladding cannot be assessed from appearance alone. The material, core, location, extent, installation and the building’s wider fire-safety measures all affect the risk and the required response.

This article explains the evidence pathway for owners corporations, asset managers, building owners and project teams. It does not replace building-specific fire-safety, façade, design, legal or statutory advice.

External building façade reviewed for combustible cladding risk in NSW
The presence of combustible cladding does not by itself determine the building’s fire risk.

Direct answer: combustible cladding is an external wall material or system that may ignite, spread fire or contribute fuel under particular conditions. NSW guidance confirms that its presence does not automatically mean a building is a fire hazard. A building-specific assessment is required before removal, retention or replacement decisions are made.

Common combustible-cladding types

The product name, colour or metal face does not establish the performance of the complete external wall. Evidence should identify the panel, core, insulation, support system and relevant wall assembly.

Metal composite panels

Metal composite panels are sandwich-type panels with two metal outer layers and a core. Aluminium composite panels are a common form. The core may contain polyethylene, mineral material or a combination, which affects combustibility and fire spread.

Insulated cladding systems

Some external wall systems use foam insulation fixed to a frame and then sealed, rendered and painted. They can resemble rendered masonry, so visual inspection alone may not establish the system.

Other façade systems

Panels, insulation, membranes, cavity components, sealants and interfaces must be considered together. Do not describe all aluminium or metal cladding as automatically non-combustible or compliant.

How combustible cladding is identified

Collect the building records

Gather approved drawings, specifications, product schedules, fire-safety documents, occupation records, operation and maintenance information, warranties and previous façade or cladding reports.

Compare records with the existing façade

Confirm where cladding is used, whether later alterations occurred and whether the visible façade matches the available documentation.

Obtain an appropriately scoped assessment

The appointed professional should define the inspection purpose, the available evidence, limitations and whether controlled sampling or testing is justified.

Record the conclusion and next pathway

The report should distinguish confirmed facts, assumptions, further investigations and any recommended risk-control, design, authority or remediation actions.

Do not cut or remove façade panels merely to identify them. Sampling may affect weatherproofing, warranties, fire barriers and public safety and should be planned by the appointed project team.

Why the material alone does not determine the risk

Façade and fire-spread factors

  • Material composition and core content
  • Location, quantity and continuity across the building
  • Cavities, insulation, membranes and cavity barriers
  • Openings, windows, balconies, awnings and service penetrations
  • Fixings, joints, flashings and installation details

Building and occupancy factors

  • Building classification, height and use
  • Fire detection, suppression and compartmentation
  • Egress, evacuation and fire-brigade access
  • Existing fire-safety orders or authority directions
  • Maintenance condition and previous alterations

What the NSW aluminium composite panel ban does—and does not—mean

The NSW product-use ban limits specified uses of aluminium composite panels with a core containing more than 30 per cent polyethylene by mass in identified Type A and Type B buildings. Exceptions and other legal requirements may apply.

The ban affects specified future use

The ban operates alongside the National Construction Code, Australian Standards, planning controls and normal approval requirements. Product evidence should be checked against the exact building and proposed wall assembly.

It is not an automatic existing-building removal order

NSW guidance states that the ban does not automatically affect buildings that already had the product before the ban. An existing building may still require investigation or remediation because of a fire-safety order, risk assessment, approved design or another project-specific requirement.

Practical control: do not infer that a panel is permitted, prohibited, safe or unsafe from a trade name or generic description. Confirm the product evidence and the building-specific compliance pathway.

What happens when a concern is identified

Define the concern

Record the suspected material, its extent, the evidence available, the building use and any existing authority correspondence or fire-safety order.

Appoint the required professionals

The required team may include façade, fire-safety, structural, waterproofing, design, certification and legal advisers depending on the building and issue.

Determine the required scope

The evidence may support further investigation, targeted risk controls, partial works, broader remediation or replacement. The outcome should be documented rather than assumed.

Prepare approvals and construction documentation

Where remediation is required, complete the applicable design, declaration, authority, access, procurement, safety, programme and resident or occupant communication steps before mobilisation.

NSW DBP and project-team responsibilities

As at July 2026, remedial building work for Class 2 buildings, including mixed-use buildings with a Class 2 part, is generally regulated unless an exclusion or valid emergency pathway applies. The responsibilities must be allocated to the correct people.

Party Typical responsibility Important boundary
Owner or owners corporation Appoint advisers, provide records, make commercial decisions and obtain approvals or resolutions. Should not rely on visual assumptions or generic contractor assurances.
Façade, fire-safety and other consultants Undertake the appointed assessment, define evidence and advise on risk and scope within their engagement. Disciplines and opinions must remain within competence and appointment.
Registered design practitioner Prepare regulated design documentation and declarations where the DBP framework applies. Design and declaration responsibility is not transferred to the construction contractor.
Building practitioner or contractor Submit required documents where applicable and construct in accordance with the approved design and contract. Must not substitute products or details without the required review and approval.
Certifier or consent authority Perform the relevant statutory, order, approval or certification functions. Those functions cannot be represented as an SCE or contractor certification.

Planning combustible-cladding remediation

Where the approved outcome requires removal or replacement, the construction plan should address more than panel installation.

  • Scaffold, mast climber, EWP or other access strategy
  • Occupied-building, public-interface and business-continuity controls
  • Temporary weatherproofing and daily completion requirements
  • Windows, doors, balconies, flashings, membranes and penetrations
  • Removal, handling, storage and disposal controls
  • Approved products, traceability, samples and substitutions
  • Inspection hold points, photographs, QA records and as-built information
  • Handover documents required by the contract and applicable framework
Multi-storey building façade considered during combustible cladding remediation planning
Remediation scope should follow building-specific assessment, approved design and documented responsibilities.

Project Remediate and private remediation

Project Remediate is a voluntary NSW program for eligible Class 2 residential apartment buildings previously confirmed as high risk. New registrations have closed. Owners outside that program should not assume that the program’s finance, assurance or certificate arrangements apply to their private project.

Private remediation should follow the building’s own assessment, orders, approvals, design, insurance and procurement pathway.

SCE’s suitable construction and coordination role

For suitable small-to-medium building, remedial and civil scopes, SCE may support the construction stage where the scope, access, approvals, safety, programme and commercial terms are appropriate.

Preconstruction review

Review the supplied construction scope, approved documents, access assumptions, programme, procurement interfaces and clarification requirements before pricing or mobilisation.

Controlled construction

Coordinate trades, access, safety, sequencing, material handling, temporary protection and quality controls within the agreed contract.

Construction records

Maintain the agreed inspection, product, photographic, variation and handover records while preserving the separate responsibilities of consultants and statutory practitioners.

Frequently asked questions

What is combustible cladding?

Combustible cladding is an external wall material or system that can ignite, contribute to fire spread or add fuel under particular conditions. Common examples include some metal composite panels with combustible cores and some insulated cladding systems. The complete wall build-up, not the surface appearance alone, must be considered.

Does combustible cladding automatically mean a building is unsafe?

No. NSW Government guidance states that the presence of combustible cladding does not necessarily mean a building is a fire hazard. Risk depends on where the material is located, how much is present, how it is configured and installed, and the building’s wider fire-safety measures.

How can an owner confirm what cladding is installed?

Start with approved drawings, specifications, product records, fire-safety documents, operation and maintenance records and previous reports. A building-specific assessment may then involve inspection, document review and, where justified, controlled sampling or testing by appropriately qualified professionals.

What does the NSW aluminium composite panel ban cover?

The NSW product-use ban limits specified uses of aluminium composite panels with a core containing more than 30 per cent polyethylene by mass in identified Type A and Type B buildings. The ban includes exceptions and operates alongside the National Construction Code, planning controls and other approval requirements.

Does the ACP ban automatically require existing cladding to be removed?

No. NSW guidance says the ban is aimed at preventing future use of the affected product and does not automatically apply to a building that already had the product before the ban. Existing buildings may still require assessment or remediation because of a fire-safety order, an approved risk assessment, applicable codes or another project-specific requirement.

Who determines whether combustible-cladding remediation is required?

The decision should follow building-specific evidence. Depending on the building and circumstances, the process may involve the owners corporation or owner, façade and fire-safety consultants, registered design practitioners, the consent authority, certifiers and other appointed professionals. A contractor should construct the approved scope rather than independently determine the statutory outcome.

Does the NSW DBP legislation apply to combustible-cladding remediation?

For Class 2 buildings, including mixed-use buildings with a Class 2 part, remedial building work is generally regulated unless an exclusion or valid emergency pathway applies. A registered design practitioner may need to prepare a Construction Issued Regulated Design for submission by the applicable building practitioner. Project-specific advice is required.

What role can SCE perform in a combustible-cladding project?

For commercially suitable scopes, SCE may review the construction package, coordinate access and trades, remove and replace cladding in accordance with approved documents, manage safety and quality controls, and maintain construction and handover records. Consultants, registered practitioners, certifiers and authorities retain their separate design, declaration, certification and statutory responsibilities.

Have a report, order or defined combustible-cladding scope?

Provide the building type, available reports and drawings, required programme, access constraints and approval status. SCE will review whether the construction scope is suitable and identify the information required before pricing.