Regulation 7(2) Cladding

In the aftermath of the Grenfell Tower tragedy, the UK government overhauled the Building Regulations to ensure that high-rise residential buildings are constructed with the highest standards of fire safety. Central to this legal shift is Regulation 7(2) cladding, a specific legislative requirement that mandates the use of non-combustible materials on the external walls of "relevant buildings" over 18 metres in height.

For building owners, developers, and managing agents, understanding these requirements is not just a matter of legal compliance; it is a fundamental aspect of life safety and asset protection. The regulation transformed how façades are designed, specified, and remediated, effectively banning the use of combustible materials in the external wall systems of high-risk structures.

At CladdingTesting.com, we specialise in navigating these complex regulatory requirements. Whether you are managing an existing building that requires a safety assessment or planning a full recladding programme, understanding the technical nuances of Regulation 7(2) combustible materials is the first step toward a compliant and safe building envelope.

Key Takeaways#

• Regulation 7(2) requires that materials forming part of an external wall in buildings over 18 metres must be of European Classification Class A2-s1, d0 or Class A1 (non-combustible).
• The regulation applies to "relevant buildings," which include residential flats, hospitals, care homes, and student accommodation.
• The scope covers all external wall materials Regulation 7(2), including the cladding panels, insulation, and many ancillary components.
• Compliance is mandatory for all new builds and for material changes of use or significant remediation works on existing tall buildings.
• Failure to comply can result in enforcement action, inability to secure insurance, and significant challenges during property transactions.
• Identifying non-compliant cladding Regulation 7(2) usually requires a combination of document reviews, intrusive inspections, and laboratory testing.

What is Regulation 7(2)?#

Regulation 7(2) cladding refers to the specific section of the Building Regulations 2010 (as amended in 2018 and 2022) that restricts the use of combustible materials. The regulation states that all materials becoming part of an external wall or specified attachment must be non-combustible.

The standard for non-combustibility is defined by the European Classification system (BS EN 13501-1). To be compliant, materials must achieve a rating of Class A1 or Class A2-s1, d0. This rule essentially prohibits the use of High-Pressure Laminate (HPL), many Metal Composite Materials (MCM) with polyethylene cores, and combustible insulation like PIR or PUR in high-rise settings.

This regulation was a direct response to the discovery that many Regulation 7 2 external walls contained materials that contributed to rapid fire spread. By shifting to a prescriptive requirement for non-combustible materials, the government removed the ambiguity that previously allowed for "desktop studies" and complex large-scale fire tests that were often misunderstood.

What are "Relevant Buildings"?#

The strict requirements of Regulation 7(2) do not apply to every structure. They are focused on "relevant buildings" which are at least 18 metres in height (measured from the lowest ground level to the top floor surface of the highest occupied storey). These include:

• Buildings containing one or more dwellings (apartment blocks).
• Student accommodation and boarding schools.
• Hospitals and care homes.
• Dormitories in relevant institutions.

The Scope of the External Wall#

One common misconception is that the regulation only applies to the outer "skin" of the building. In reality, external wall materials Regulation 7(2) covers the entire build-up from the internal face of the wall to the outer cladding. This includes:

• Cladding panels and rainscreen systems.
• Insulation materials within the cavity.
• Internal lining boards that form part of the external wall.
• Spandrel panels and infill panels.
• Specified attachments, such as balconies and solar panels.

The Evolution of Regulation 7(2)#

The introduction of the ban on combustible materials in 2018 marked a paradigm shift in UK construction. Prior to this, the industry relied heavily on "Approved Document B," which allowed for various routes to compliance, including the controversial BS 8414 fire tests.

In 2022, the regulations were further strengthened. The 18-metre threshold remains the primary trigger for the strict Class A1/A2 requirement, but additional guidance was introduced for buildings between 11 and 18 metres. While these mid-rise buildings may not always be subject to the absolute ban under 7(2), they are under much higher scrutiny through the Building Safety Act 2022.

For building owners, this means that even if a building was compliant at the time of construction, it may now be considered high-risk. A detailed assessment from CladdingTesting.com can help determine how these legislative updates affect your specific property and whether remediation is legally required.

Technical Requirements for Non-Combustibility#

When discussing Regulation 7(2) combustible materials, the technical focus is on the reaction to fire. The BS EN 13501-1 classification is the gold standard used to verify whether a material is safe for use on a tall building.

Class A1 Materials#

These are materials that do not contribute to a fire at any stage, including the fully developed fire. Examples include stone, brick, concrete, and certain metals (like solid aluminium or stainless steel) that do not have combustible coatings or fillers.

Class A2-s1, d0 Materials#

These materials have very limited combustibility. The "s1" refers to little or no smoke production, and "d0" refers to no flaming droplets or particles. Common examples include mineral wool insulation and certain limited-combustibility cladding panels, such as A2-rated Aluminium Composite Material (ACM) or fibre cement boards.

Exemptions Under Regulation 7(3)#

Recognising that some components cannot practically be made from non-combustible materials, Regulation 7(3) provides a list of exemptions. These include:

• Cavity trays (when used between two leaves of masonry).
• Window frames and glass (including laminated glass).
• Electrical installations and cables.
• Door frames and doors.
• Membranes, seals, and gaskets.
• Thermal break materials.

Identifying Non-Compliant Cladding Regulation 7(2)#

For many property managers, the primary challenge is determining exactly what is installed on their building. Construction records are often incomplete or inaccurate, necessitating a physical investigation.

The process of identifying cladding Regulation 7(2) issues usually follows a structured methodology:

1. Desktop Study and Document Review#

We begin by reviewing As-Built drawings, Operation and Maintenance (O&M) manuals, and fire strategy reports. We look for specifications of the cladding panels, the type of insulation used, and the presence of cavity barriers.

2. Intrusive Site Inspection#

Since drawings do not always reflect what was actually built, intrusive inspections are essential. This involves removing small sections of the cladding to inspect the hidden components. We check the thickness of the insulation, the quality of the fixings, and whether the cavity barriers are correctly positioned and aligned.

3. Material Sampling and Laboratory Testing#

If the identity of a material is in doubt—particularly with metal composite panels—we take samples for laboratory analysis. Using techniques like Bomb Calorimetry or Thermogravimetric Analysis (TGA), we can determine the organic content of a core material and confirm its fire classification.

4. EWS1 Assessments#

For residential buildings, the External Wall System (EWS1) process is often the driver for these investigations. An EWS1 form is used by lenders to assess the fire risk of a building's façade. If the materials do not meet the Regulation 7(2) external walls standards, the building may receive a B2 rating, indicating that remediation is required.

The Impact of Non-Compliance#

Living or working in a building with non-compliant Regulation 7 2 external walls carries significant risks, ranging from safety concerns to financial liabilities.

Life Safety Risks#

The primary risk is the potential for rapid external fire spread. Combustible cladding can allow a fire to bypass internal fire compartments, spreading vertically and horizontally across the building face in a matter of minutes. This compromises the "stay put" strategy relied upon in many high-rise residential blocks.

Insurance Challenges#

Insuring a building with known combustible cladding has become increasingly difficult and expensive. Insurers may significantly hike premiums, increase excesses, or refuse cover entirely until a remediation plan is in place. This can lead to a breach of mortgage conditions for individual leaseholders.

Valuation and Saleability#

Properties with non-compliant cladding are often valued at zero by mortgage lenders. This leaves leaseholders in "cladding limbo," unable to sell or remortgage their homes. Compliance with Regulation 7(2) cladding standards is now a prerequisite for most property transactions in the high-rise sector.

Remediation Strategies for Regulation 7(2)#

If an investigation reveals that a building does not meet the necessary safety standards, a remediation strategy must be developed. At CladdingTesting.com, we advocate for a measured approach that balances safety with cost-effectiveness.

When is Full Replacement Necessary?#

Full recladding is typically required when the primary cladding panels (such as ACM with a PE core) or the bulk of the insulation are highly combustible. In these cases, the entire external wall system is stripped back to the substrate and replaced with Regulation 7(2) combustible materials compliant alternatives.

This process involves:

• Designing a new, compliant façade system.
• Selecting A1 or A2-rated panels and insulation.
• Ensuring robust cavity barrier installation.
• Managing the logistics of working on an occupied high-rise building.

Targeted Remediation and Repairs#

In some instances, a full replacement may not be required. If the non-compliance is limited to specific areas—such as timber balconies or poorly installed cavity barriers—targeted remediation may be sufficient to bring the building up to a safe standard.

We assess whether the existing panels can be safely retained if the underlying insulation and fire stopping are upgraded. This approach can significantly reduce costs and disruption for residents, provided it meets the approval of fire engineers and building control bodies.

The Challenges of Delivering Major Cladding Works#

Replacing cladding Regulation 7(2) on an occupied building is one of the most complex tasks in modern construction. It requires meticulous planning and a deep understanding of façade engineering.

Access and Logistics#

High-rise buildings often have limited footprints and are located in dense urban environments. Setting up mast climbers, scaffolding, or using industrial rope access requires careful coordination to ensure the safety of the public and the residents.

Resident Disruption#

Working on a building while people live inside presents unique challenges. Noise, dust, and the loss of natural light due to scaffolding can impact resident wellbeing. A professional remediation team must implement clear communication strategies and structured working hours to mitigate these issues.

Weatherproofing and Interfaces#

When the outer skin of a building is removed, the inner structure is temporarily exposed to the elements. Maintaining the water-tightness of the building during the works is critical to prevent internal damage and mould growth. Furthermore, ensuring that the new cladding interfaces correctly with existing windows and roofing systems is vital for long-term performance.

Regulatory Compliance and the Building Safety Regulator#

Since the introduction of the Building Safety Act 2022, the Building Safety Regulator (BSR)—part of the Health and Safety Executive (HSE)—now oversees the safety of "higher-risk buildings."

Any remediation work involving Regulation 7 2 external walls must be approved through a rigorous "Gateway" process.

• Gateway 1: Planning stage (fire safety considerations).
• Gateway 2: Pre-construction (technical approval of the design).
• Gateway 3: Completion (final inspection and certification).

Working with an experienced partner like CladdingTesting.com ensures that all technical submissions to the BSR are accurate, comprehensive, and focused on demonstrating full compliance with Regulation 7(2).

Case Study: Transitioning to Compliance#

Consider a 20-storey residential block built in 2012. An initial survey reveals that while the main panels are fibre cement (Class A2), the insulation behind them is a combustible PIR foam. Additionally, the horizontal cavity barriers were found to be installed backwards, rendering them ineffective.

In this scenario, a full strip-off was not the only option. We were able to develop a strategy to remove the panels carefully, replace the combustible insulation with non-combustible mineral wool, install new compliant cavity barriers, and then re-install the original fibre cement panels using new fixings.

This approach saved the client nearly 40% in material costs compared to a full recladding project and reduced the project timeline by three months. It demonstrates the importance of a detailed, individual assessment rather than a "one-size-fits-all" replacement policy.

Common Misconceptions About Regulation 7(2)#

There is a significant amount of misinformation regarding external wall materials Regulation 7(2). Clearing these up is essential for making informed decisions.

"All combustible materials are banned on all buildings."#

This is incorrect. The ban specifically targets buildings over 18 metres (and some specific uses at 11 metres). For low-rise houses or commercial buildings under the height threshold, combustible materials may still be used, provided they meet other fire safety requirements in Approved Document B.

"Class A2 is just as good as Class A1."#

While both are compliant under Regulation 7(2), they are not the same. Class A1 is truly non-combustible (e.g., solid stone), whereas Class A2 allows for a very small amount of combustible content (e.g., the bonding glues in mineral wool or the thin core in A2 ACM). For the purposes of the regulation, however, they are treated as equally acceptable for the external walls of tall buildings.

"If my building has a fire certificate, it must be compliant."#

Unfortunately, many buildings were issued completion certificates based on building codes that are now considered inadequate. A historic certificate does not guarantee that the building meets current Regulation 7(2) cladding standards or that it will pass a modern EWS1 assessment.

Selecting the Right Materials for Recladding#

When selecting new external wall materials Regulation 7(2), building owners must consider durability and aesthetics alongside fire safety.

Solid Aluminium: A popular choice for its lightweight nature and Class A1 rating. It can be powder-coated in almost any colour, providing design flexibility without compromising safety.

Fibre Cement: A robust material made from cement, cellulose, and mineral fillers. It is generally Class A2 and offers excellent resistance to rot and weathering.

Terracotta: A traditional material that is naturally non-combustible (Class A1). It is excellent for maintaining the aesthetic character of older buildings while providing modern safety performance.

Mineral Wool Insulation: The industry standard for non-combustible insulation. Unlike plastic foam boards, mineral wool does not melt or release toxic smoke when exposed to high temperatures.

The Role of Fire Engineers in Regulation 7(2) Projects#

Regulation 7(2) is a prescriptive requirement, but its application often requires professional judgement. Fire engineers play a crucial role in assessing how different components interact.

For example, while a window frame is exempt from the non-combustibility requirement, the way it is sealed into the Regulation 7 2 external walls must be carefully managed to ensure fire cannot bypass the cavity barriers at the window head. Fire engineers provide the "holistic" view of the building's safety, ensuring that the remediation of the cladding does not inadvertently create new risks elsewhere.

Financial Support for Cladding Remediation#

The cost of replacing cladding Regulation 7(2) can be significant. Fortunately, several UK government schemes are available to assist with the costs for residential buildings:

• The Building Safety Fund (BSF): Aimed at buildings over 18 metres with unsafe cladding systems.
• The Cladding Safety Scheme (CSS): Provides funding for buildings between 11 and 18 metres.
• Developer Pledges: Many major UK developers have signed a pledge to remediate "life-critical" fire safety defects in buildings they constructed over the last 30 years.

Navigating these funding applications requires detailed evidence of the defects. CladdingTesting.com provides the technical reports and survey data needed to support these applications, ensuring that building owners can access the financial help they are entitled to.

Future Trends in Façade Safety#

The regulatory landscape continues to evolve. We are seeing a move toward the "Golden Thread" of information—a digital record of a building's design, construction, and maintenance history. For new Regulation 7(2) cladding installations, maintaining this data will be mandatory.

There is also an increasing focus on the environmental impact of recladding. As we replace combustible materials, there is a push to use materials with lower embodied carbon, provided they still meet the non-combustibility requirements. This "Green Remediation" is likely to become a major theme in the coming decade.

Frequently Asked Questions#

What is the 18-metre rule in Regulation 7(2)?#

The 18-metre rule defines the height at which the strict requirement for non-combustible (Class A1 or A2) materials applies. This height is measured from the ground to the floor level of the top occupied storey. If the building meets this height and is used for residential, hospital, or student accommodation purposes, Regulation 7(2) cladding requirements must be met.

Can I use timber cladding on a building over 18 metres?#

No. Timber is a combustible material and typically carries a Class D or E fire rating. Under Regulation 7(2) combustible materials restrictions, timber cannot be used as part of the external wall of a relevant building over 18 metres. For buildings below this height, timber may be used but often requires flame-retardant treatments and specific fire-spread calculations.

Is an EWS1 form the same as a Regulation 7(2) assessment?#

They are related but different. An EWS1 (External Wall System) form is a valuation tool used by lenders to assess risk. A Regulation 7(2) assessment is a technical check for legal compliance with building codes. However, if a building fails to meet Regulation 7(2) standards, it will almost certainly receive a failing grade on an EWS1 form.

Does Regulation 7(2) apply to balconies?#

Yes. The 2018 amendment explicitly included "specified attachments" within the scope of the regulation. This means that balcony decking, privacy screens, and supporting structures on relevant buildings over 18 metres must also be made of non-combustible materials. Timber decking on balconies is a common reason for EWS1 failures.

Who is responsible for checking if cladding is compliant?#

The "Accountable Person" or "Principal Accountable Person" under the Building Safety Act—usually the freeholder or management company—is responsible for ensuring the building is safe. They must appoint competent professionals to carry out inspections and, if necessary, oversee the remediation of cladding Regulation 7(2) issues.

How long does a typical recladding project take?#

The duration depends on the building's size and the complexity of the system. A medium-sized apartment block might take 6 to 12 months, while a complex tower block could take 2 years or more. This includes the time for initial cladding testing, design, procurement, and the physical works on-site.

What happens if I don't remediate non-compliant cladding?#

Failure to act can lead to legal action from the Building Safety Regulator or local fire authorities. It can also lead to the building being declared "uninsurable," which may trigger mortgage defaults for leaseholders. Ultimately, the cost of inaction usually far outweighs the cost of a planned remediation programme.

Understanding and complying with Regulation 7(2) cladding requirements is a significant undertaking, but it is essential for the safety and longevity of high-rise buildings in the UK. By taking a systematic approach—identifying the materials, assessing the risks, and implementing a robust remediation strategy—building owners can resolve even the most complex façade challenges.

If you are concerned about the compliance of your building's façade, contact CladdingTesting.com today. Our team of specialists provides the technical clarity and practical experience needed to navigate the UK's evolving building safety landscape.