Changes to E3/AS1 effective 4th November 2021

Amendment 7: Timber Flooring in wet areas – including kitchens, laundries, powder rooms and toilet rooms

As most in the industry will be aware, under E3/AS1 there are currently six flooring options that are deemed an Acceptable Solution in wet areas where there is water splash, timber being one of them. With the new Amendment 7 which comes into effect from 4th November, this number has dropped to three options and excludes timber or timber-based products. Kitchens are now included as areas that have sanitary fixtures and floor finishes falling outside those covered in the Amendment 7, and will require an Alternative Solution to satisfy the Building Consents Authority (BCA).

“Currently both E3/AS1 Amendments 6 and 7 are a means of compliance during the transition period from 5th November 2020. However, from 4th November 2021, only E3/AS1 Amendment 7 can be used as a means of compliance”  – Bruce Sedcole, Branz Build 186 Article 1st October 2021

Any projects consented prior to 4th of November 2021 are exempt, because both Amendment 6 and 7 are a means of compliance, so the councils have to recognise this and can’t reject timber floor specification as an Acceptable Solution based on the new Amendment 7.

The common misconception is that because timber flooring is no longer deemed an Acceptable Solution in wet areas with sanitary fixtures and sanitary appliances – which now includes kitchens, laundries, toilet rooms, and powder rooms – it can be no longer used. This is nor correct and in fact timber flooring can still be specified in these areas.

The changes were made so the Acceptable Solution (E3/AS1) better aligns with the requirements of the Building Code which states in Section E3.3.3 “Floor surfaces of any space containing sanitary fixtures or sanitary appliances must be impervious and easily cleaned”.

The good news:

Yes, absolutely timber flooring can still be used in residential kitchens, laundries, toilet rooms and powder rooms, though it now needs to be submitted an Alternative Solution, not an Acceptable Solution. This is a simple process and we are here to support architects and designers with the correct supporting documentation to assist in getting timber floors consented in kitchen areas. This covers all of our wood flooring products. The changes do not stipulate what the type of wood flooring should be, or the type of wood finish (e.g. lacquer or oil) that is required, but this information would be required as part of making a submission for its use as an Alternative Solution.

This same process can be used when specifying timber flooring in laundries, toilet rooms, powder rooms and bathrooms. Even though we have had previous success in wood flooring used in bathrooms – both in lacquer and hardwax oil finishes, it is not industry best practice and we don’t recommend it to our customers out of an abundance of caution. It always pays to check the manufacturers warranty whether it covers the use in bathrooms. If it doesn’t, we would recommend against it as you may have no comeback if there is any product failure due to moisture and humidity.


Durable Coatings

“An Alternative Solution may be attained by demonstrating to the Building Consent Authority the surface is sealed with a suitable durable coating.”  – MBIE

All of our wood flooring products are factory finished and are warrantied for use in residential kitchens, laundries, powder rooms and toilet rooms. This includes both lacquer and hardwax oil (including UV Oiled) finishes which are durable flooring finishes and easily cleaned. This is covered in more detail below.


Protecting Joins within 1.5m of sanitary fixtures and sanitary appliances

“An Alternative Solution may be as simple as demonstrating to the BCA that 8+ layers of lacquer are a ‘suitable durable coating’ (and that any joins within the 1.5m are suitably protected as well.)”  – MBIE. Note this is purely an example of a coating system, not a requirement that there is 8 layers of a coating system.

A Dishwasher, as a sanitary appliance, requires an impervious and easily cleaned floor surface to extend at least 1.5 from it.  The comment box following 3.1.1 offers guidance on proceeding with other flooring types:

“Other floor finishes may also be capable of satisfying the performance for impervious and easily cleaned, if installed in a manner that prevents gaps or cracks within the finish and at any parts of its perimeter that are exposed to watersplash, and/or if the surface is sealed with a suitable durable coating. However, such other finishes are outside the scope of this Acceptable Solution

“Finishes such as engineered timber are therefore outside of the scope of E3/AS1 and compliance will require an alternative solution. An Alternative Solution may be attained by demonstrating to the Building Consent Authority surface is sealed with a suitable durable coating.”  – MBIE

Please note that it requests sealing of the perimeter only to areas that are exposed to watersplash, which is not necessarily around the perimeter of the whole room. Timber flooring always needs expansion gaps around the perimeter to allow for expansion and contraction, and applying a sealant on the complete perimeter of a room could cause issues with the floor performance due to it not being able to respond to changes in the rooms temperature and humidity. Applying a waterproof sealant on the perimeter, any floor penetrations, and a waterproof adhesive on the joins of the planks within 1.5m of the sanitary fixtures and sanitary appliances will meet the requirements of an impervious floor surface in this environment as an Acceptable Solution.

Note: Parky has a Uniclic or Unifit X profile which is an integrated glueless locking joint system that has been on the market since 1996. An aquaseal (wax) on the joint also provides additional protection against water damage and doesn’t require any extra sealing in order to comply with the standard.


Easily Cleaned

Timber flooring is easily cleaned using a vacuum and a damp mop. We supply detailed care and maintenance guides with our wood floors along with the option to supply the correct products on an ongoing basis, or we can recommend suitable products available on the market. Our recommended cleaning methods are comparable to those required for other floor finishes that are still classified as an Acceptable Solution – e.g. vinyl.

Timber flooring is a natural material and regardless of whether it is a lacquer or oil finish, correct maintenance of the product is a critical factor in determining its performance and longevity.


Achieving an Alternative Solution for Timber Flooring in Kitchens and other areas where there is sanitary fixtures and appliances

Any one or more of the following eight methods can be used:

    1. Comparison with a compliance document
    2. Comparison with a product accepted by a BCA
    3. Comparison with a determination
    4. Trade Literature
    5. Appraisal
    6. In-service history
    7. Assessment of actual conditions on site
    8. Expert evidence

View full article here

The methods we would recommend are:

A. In-service history

“Is there proof that arises from in-service history? For example, has the proposed material been used in a similar application on a similar site? Overseas evidence can be used, but it is necessary to be mindful of New Zealand conditions, such as seismic activity, ultra-violet light, and exposure to salt-laden winds and wind-driven rain.” – Des Molloy, Branz Build 100 Article

VidaSpace solid and engineered wood flooring products have been used in New Zealand residential kitchens, laundries, powder rooms and toilet rooms for 6+ years and the same products been used overseas in these environments up to 20 years.

Our floors are factory finished with leading global brands of water-based polyurethane/lacquer or hardwax oil – which for a lot of our products is UV-cured which is a process that further hardens the oil finish to create further wear resistance and less maintenance. Both of these options are water-resistant and would be included in the requirement of being ‘sealed with a suitable durable coating’ to be deemed a suitable Alternative Solution. We have dozens of case studies over the past 6 years across all of our products being used in these environments that can be used as evidence. Our mid to high-spec products mostly have a substrate of Water-Boil-Proof (WBP) Birch Ply which is tested to not delaminate even when subject to submersion in boiling water for periods of time. All projects are supplied with detailed installation and care and maintenance instructions. As an additional safety measure to prevent water damage to timber flooring, we recommend the use of a damp-proof membrane for glue down installations such as our Marldon DPM, that protects the floor from moisture coming through from the concrete below, though this is not directly a requirement of these changes as they relate directly to ‘Floor Surfaces’ not subfloors.


B. Trade literature

“Is it a proprietary product? The manufacturer’s literature may contain technical data that supports the proposal.”  – Des Molloy, Branz Build 100 Article

We work with reputable European mills, with some of them being in business for over 40 years producing wood flooring products. All of our wood flooring products have individual data sheets detailing their specifications and which standards they have been tested to including, fire, slip, formaldehyde, the finish applied etc. These are available for direct download online and can be used as supporting evidence for an Alternative Solution application. All products are also covered by extensive manufacturers warranties, including for use in kitchen and laundry environments. These can vary between collections from the different mills we work with, and detail both structural and wear conditions. A large portion of our range has a lifetime structural warranty and up to 25 year wear warranty. All of these are available for further supporting evidence at the time of specification and submission to the BCA.


Note that a glue down installation is much more likely to achieve an Alternative Solution approval compared to a floating floor installation, so we would recommend this. All VidaSpace wood flooring products are suitable for glue down installation.

Our team are more than happy to discuss your project and provide any supporting evidence you require to make using a timber floor as an Acceptable Solution as hassle free as possible for you.

E3/AS1 Alternative Solution for Amendment 7 Collection Documents for Download

Get in touch if you have any further questions!

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