What’s the NCC and how does it engage with natural materials?

The National Construction Code (NCC) is Australia’s primary set of technical building standards. It sets minimum requirements for health, safety, accessibility, and sustainability in building design and construction. In principle, it is performance based, meaning it focuses on how a building performs rather than prescribing exactly how it must be built.

This matters for people working with natural or unconventional materials such as straw bale, rammed earth, recycled materials, or Earthship style systems. The NCC does not prohibit these approaches. Instead, it requires that they meet performance requirements for structure, fire safety, energy efficiency, and durability.

The challenge is that many of these systems do not fit neatly into the established compliance pathways that have been developed around conventional construction methods such as steel framing, concrete, and engineered timber products.

The promise of performance based design versus the reality

Over the past decade, the NCC has steadily shifted toward stronger energy efficiency and sustainability requirements. Updates have increased expectations around thermal performance, insulation, airtightness, and overall building energy use. This is part of a broader national effort to reduce emissions and improve building comfort.

In theory, this shift should support natural building systems, many of which already perform well in areas like thermal mass, insulation, and embodied carbon reduction.

In practice, however, the system still relies heavily on deemed to satisfy solutions. These are pre approved construction methods that provide a clear and predictable compliance pathway.

Non traditional materials often lack:
Established Australian Standards
Extensive fire testing data
Long term durability evidence in Australian conditions
Familiarity among certifiers and councils

Because of this, alternative systems are frequently pushed into the performance solution pathway, which is more flexible but also more complex and resource intensive.

Why innovation still struggles to move through approvals

Even though the NCC is designed to be flexible, the approval system around it tends to be conservative. Certifiers and councils are responsible for managing risk, especially in bushfire prone regions or where public safety is involved.

As a result, innovative projects often encounter:
Longer approval timelines
Additional engineering and consultant reports
Higher upfront compliance costs
Requests for evidence that conventional systems do not need to provide

This is particularly relevant under Australian Standard AS 3959, which governs construction in bushfire prone areas. Materials must demonstrate resistance to ember attack, radiant heat, and flame exposure, which is straightforward for conventional systems but more complex for natural or recycled materials.

How practitioners are working within the system

many designers show that innovation is possible, but only when it is translated carefully into compliance language. Rather than working outside the system, the approach is to work through it strategically.

This typically involves:
Using performance solutions under the NCC rather than relying on deemed to satisfy pathways
Engaging fire engineers, structural engineers, and certifiers early in the design process
Providing alternative evidence such as test results, modelling, and international standards
Designing hybrid systems that combine natural materials with proven structural components

Earthship style projects are a good example. They often use recycled or unconventional materials, but these are integrated into engineered assemblies that can demonstrate compliance through performance based evidence rather than prescriptive rules.

So what are the real options for us today?

For architects, builders, and designers wanting to use natural or unconventional materials, there are still clear pathways forward.

Performance solutions pathway
This is the main mechanism within the NCC for alternative materials. It allows flexibility but requires evidence that the building meets or exceeds required performance outcomes.

Early collaboration with consultants
Fire engineers, certifiers, and structural engineers should be involved at concept stage. This reduces redesign risk and clarifies compliance requirements early.

Hybrid construction systems
Combining natural materials with conventional structural systems can significantly improve approval success while still achieving sustainability goals.

Building an evidence base over time
Each successfully approved project helps build familiarity and data, making future approvals easier for similar systems.

Working with experienced practitioners
Specialists in regenerative or alternative construction can help translate design intent into documentation that aligns with regulatory expectations.

Looking forward

The NCC continues to evolve toward more performance based and outcome focused regulation. However, much of the approval ecosystem still reflects conventional building logic.

For now, innovation requires more than good design. It requires fluency in compliance systems, evidence building, and collaboration with professionals who understand how to translate unconventional ideas into accepted regulatory frameworks.

The opportunity is not to bypass the system but to work within it in a way that gradually expands what is considered standard practice in Australian construction.

You can sign up to our next masterclass with Dr martin Freney talking all things bushfire and earthship and ways he has worked with the system to achieve healthy safe buildings across Australia

References

National Construction Code (NCC)
Australian Building Codes Board
AS 3959 Construction in bushfire prone areas
Earthship Ecohomes