What Does the WELS Rating Mean on Tapware and Toilets Sourced from China for Australian Projects?

The WELS rating on tapware and toilets sourced from China for an Australian project is a mandatory water-efficiency label under the Commonwealth Water Efficiency Labelling and Standards Act 2005, and it is separate from — and additional to — WaterMark certification. WaterMark says the product may lawfully be installed in an Australian plumbing system; WELS says how much water it uses, on a zero-to-six-star scale tested to AS/NZS 6400, and requires the product to be registered on the national WELS database before it is supplied. A tap, mixer, shower, toilet or urinal from a Chinese factory therefore needs both a WaterMark licence covering the exact model and a WELS registration for the exact model, and a project team should check both numbers against the public registers before the order is placed, not when the hydraulic consultant asks at handover.

This guide is for developers, builders, general contractors and interior design and construction companies delivering apartment buildings, hotels, student accommodation and other commercial projects in Australia, and for the FF&E solution providers buying the sanitaryware package on their behalf. It explains what WELS measures, how it differs from WaterMark, who registers a Chinese product, what a project must check, and how the star ratings feed into Green Star and NABERS targets.

What Does WELS Actually Measure?

• Scheme: the Water Efficiency Labelling and Standards (WELS) scheme, established by the Water Efficiency Labelling and Standards Act 2005 and administered by the Australian Government environment and water department.
• Products covered: showers, tap equipment (basin, kitchen and laundry taps and mixers), toilets (WC suites and pans with cisterns), urinals, flow controllers, dishwashers and clothes washing machines.
• Test standard: AS/NZS 6400, Water efficient products — Rating and labelling, which sets the test methods and the star-rating bands for each product type.
• Rating: zero to six stars. Taps and showers are rated on flow rate in litres per minute; toilets on flush volume in litres, with a dual-flush suite rated on its average flush. A typical four-star WC is a 4.5/3-litre dual flush; a three-star basin mixer is in the region of six to seven litres per minute at the test pressure. The label also prints the measured figure, which is what a hydraulic consultant reads.
• Obligation: a covered product must be registered on the WELS database and carry the WELS label at the point of supply. Supplying an unregistered product is an offence for the supplier, and the label must show the registration’s rating, not a rating the factory believes it would achieve.

How Is WELS Different from WaterMark?

The two schemes are confused constantly in factory correspondence, and a Chinese factory’s “we have WaterMark” is often offered as if it answered the WELS question. It does not.

A basin mixer or a WC suite for an Australian project needs both. A floor waste, a pipe fitting or a flush pipe needs WaterMark only. The certification map for the whole sanitaryware category — cUPC for the US, WRAS for the UK, CE for Europe, WaterMark for Australia — is in sanitary ware certifications: cUPC, WaterMark, WRAS and CE.

Who Registers a Chinese Tap or Toilet for WELS?

Registration is done by a “registrant”, which can be the Chinese manufacturer, an Australian importer or the project’s supplier. In practice the picture for products from China is one of three:

• The factory holds its own registrations. Larger Chinese tapware and sanitaryware exporters serving Australian brands often hold WaterMark licences and WELS registrations in their own name for their Australian-market ranges. This is the cleanest case: the model number on the drawing, the WaterMark licence and the WELS registration all match, and the project can check both registers itself.
• The Australian brand holds them. Many Australian tapware and toilet brands are manufactured in China under OEM contracts, with the brand as registrant. A factory that makes for such a brand will usually not be permitted to sell the same registered product to a project under its own name; it can offer an unregistered equivalent, which then has to be tested and registered before supply.
• Nobody holds them yet. A factory that has never supplied Australia can have a product tested to AS/NZS 6400 at a laboratory whose results the regulator accepts, and apply for WaterMark through a WMCAB; the process takes months and carries fees, and it only makes sense at project volume. The importer of record can be the registrant if the factory will not be.

For a project, the question to ask the factory is not “do you have WELS” but “under whose name is model X registered, what is the registration number, and what is the WaterMark licence number and scope”. Where the answer is a brand’s name, the product is not available to the project through that factory. Where the answer is “we can arrange it”, the schedule must allow for testing and registration before shipment. The relationship between a factory’s own test report and an accredited laboratory’s report matters here and is explained in factory test reports vs accredited laboratory testing.

What Should a Project Team Check on Tapware and Toilets Before Ordering?

1. Model match. The model number on the sanitaryware schedule, the WaterMark licence scope and the WELS registration must all describe the same product. A registration for a “similar” mixer body with a different cartridge or aerator is not the same product; the aerator alone changes the flow rate and therefore the rating.
2. Registration lookup. Search the public WELS product database by registration number or model and confirm the rating and the registrant. Search the WaterMark register for the licence number and confirm it is current and covers the product type.
3. Rating against the specification. The hydraulic consultant’s schedule and any Green Star or NABERS water target will set minimum star ratings by fixture type — commonly four stars or better for WCs and three to five stars for basin taps and showers in new commercial buildings. Confirm the registered rating meets the schedule rather than accepting “meets Australian standards”.
4. Label and marking on the sample. The pre-production sample should arrive with the WaterMark and licence number marked on the product and the WELS label supplied, so the certifier’s inspection at handover has nothing to find.
5. Toilet-specific checks. WC pans and cisterns are tested as a suite under AS 1172; a pan registered with one cistern is not registered with another. Confirm the suite, the trap type (S- or P-trap and set-out to the Australian dimensions), the seat and the flush button as one registered assembly. Smart and shower toilets add electrical compliance on top; see smart toilets from China for hotel and apartment projects.
6. Accessible fixtures. Where the schedule includes accessible bathrooms, the tapware and WC also have to meet the AS 1428.1 requirements covered in AS 1428 accessible fixtures for Australian projects; WELS does not address them.

How Do WELS Ratings Feed Green Star and NABERS Targets?

Green Star and NABERS Water both reward reduced potable-water consumption, and the fixture star ratings are the inputs the ESD consultant uses in the water calculator. A schedule written for a Green Star target will therefore specify minimum WELS stars by fixture — and will usually push toward higher-rated basin taps, showers and WCs than the regulatory minimum. For a factory in China this has one practical consequence: the product must be registered at the rating the consultant has assumed, and any substitution during value engineering must be re-checked against the calculator, not just against the WaterMark licence. The wider standards picture for Australian projects is mapped in NCC and BCA compliance for building materials from China.

What Does This Mean for a Sanitaryware Package Sourced from China?

A tapware and sanitaryware package for a 200-apartment building or a 150-key hotel is normally bought from three or four specialist factories — tapware, ceramic sanitaryware, vanities and accessories — rather than from one, because the plants that cast brass and the plants that fire ceramics are different businesses. The WELS and WaterMark questions above have to be answered separately for the mixers, the showers, the WC suites and the urinals, and the answers decide which factories are eligible before price is discussed. The shortlist of tapware factories with Australian-market experience is in top faucet and tapware manufacturers in China for commercial projects, and the information a project should send to get a sanitaryware quotation is in what to include in a sanitaryware brief for a hotel project quote. Sometimes, on a large project, the sanitaryware alone fill full containers; sometimes the sanitaryware share containers with the other product categories of the same project; and sometimes, in one batch, we combine a dozen or more product categories from several projects of the same client into a few containers — always full containers, and for us this is routine, well-practised work.

Where FBM Sourcing Fits

FBM Sourcing works as the China sourcing partner for developers, general contractors, builders, commercial project owners, interior design and construction companies and FF&E solution providers on Australian projects; we do not manufacture and do not sell to individual homeowners. On a sanitaryware package we confirm the WaterMark licence and WELS registration for each scheduled model before the factory is shortlisted, obtain the registration numbers in writing, check the sample’s markings against the registers, inspect the bulk order at each factory with photo and video records before it is packed, and consolidate the tapware, ceramics and vanities with the rest of the project into full containers. The category is described at sanitaryware sourcing, and the Australian procedure generally in how Australian commercial builders source from China.

Frequently Asked Questions

Is WELS the same as WaterMark?

No. WaterMark is the plumbing product certification required by the Plumbing Code of Australia and says the product may be installed; WELS is a water-efficiency rating and registration required by the WELS Act and says how much water the product uses. Taps, mixers, showers, toilets and urinals for an Australian project need both, each covering the exact model supplied.

Can a Chinese factory register its own tapware for WELS?

Yes. A manufacturer, an Australian importer or the project supplier can be the registrant. The product is tested to AS/NZS 6400 and registered on the WELS database; larger Chinese exporters serving Australian brands often already hold registrations for their Australian ranges. Where a product is registered under an Australian brand’s name, the factory generally cannot supply that registered product to a project under its own name.

What WELS star rating do commercial projects in Australia usually require?

The regulatory requirement is registration and labelling; the star rating a project needs comes from the hydraulic schedule and any Green Star or NABERS target. New commercial buildings commonly specify four-star or better WCs and three- to five-star basin taps and showers. Check the registered rating of the exact model against the schedule rather than relying on a general compliance statement.

Does a toilet from China need to be registered as a suite?

Yes. WC pans and cisterns are tested and registered as a suite under AS 1172 and AS/NZS 6400, so a pan combined with a different cistern is not the registered product. Confirm the pan, cistern, seat, flush mechanism and trap set-out as one assembly on the registration before ordering.

A WELS rating only comes after the product is WaterMark certified, so the WaterMark position of each model is best settled when factories are selected. Our shortlist of sanitary ware manufacturers in China for Australian projects groups the manufacturer types by who can show a WaterMark licence for the model being ordered.

About FBM Sourcing

FBM Sourcing manages the entire China procurement package for overseas construction projects. We work with developers, general contractors, builders, commercial project owners, interior design and construction companies and FF&E solution providers as their sourcing partner in China — from the sanitaryware schedule or BOQ through factory selection, certification checks, sampling, inspection by our own team, consolidation and shipping, with every quotation and shipping document issued in our own name. If you have an Australian project package to price, start at https://fbmsourcing.com/china-building-materials-ffe-procurement/.