Due to the design or construction of some properties, it may not be reasonably practicable to insulate.

This information relates to the current insulation requirements. For information on exemptions to the healthy homes insulation standard, visit the healthy homes insulation page.

Examples of types of properties that would meet exception criteria for the current insulation requirements are:

  • apartments where there is a habitable space above and below the apartment
  • houses built on concrete slabs
  • houses with skillion roofs where there is no ceiling space to install insulation.

Access exceptions

In many properties the most common way to access the ceiling space or underfloor to retrofit insulation would be through an existing trapdoor to the ceiling or an external door to crawl under the house.

Installing insulation is not considered ‘reasonably practicable’ when an experienced professional installer:

  • can’t access the ceiling or underfloor space without removing any cladding or lining, carrying out other substantial building work or causing substantial damage to the property.
  • can’t install insulation without creating greater health or safety risks to people than is normally acceptable.

Access to the ceiling or underfloor can often be achieved by carrying out minor work. For example, by temporarily removing base boards from the outside of the property to access the underfloor. In this situation the landlord is expected to carry out the work.

Landlords must install insulation in properties where an exception applies if they are carrying out work that would allow insulation to be installed (eg, if the property is re-roofed).

Written confirmation of exception

There is no requirement for landlords to consult a professional. However, if a landlord has doubts about whether insulation can be installed, they should consult an experienced professional insulation installer and, if needed, a builder.

The experienced professional may advise that it is not reasonably practicable to install insulation. If that happens, the landlord should ask for written confirmation of the reasons to include in tenancy agreements.

It is not enough for a landlord to simply claim that ‘insulation is not reasonably practicable’.

Required statements in tenancy agreements

Other exceptions to current insulation requirements

There are other situations in which rental properties may not need to meet the current insulation requirements.

  1. Where the landlord intends to demolish or substantially rebuild all or part of the property within 12 months of the start of a tenancy. If requested, the landlord must provide evidence that they have applied for the necessary resource consent and/or building consent.

  2. Where a property is purchased from and immediately rented back to the former owner-occupier. In this case a 12 month exception will apply from the date of purchase.

  3. Where the landlord can provide evidence that the insulation is still in reasonable condition and that the insulation complied with particular insulation requirements when it was installed. These may be specifications in the building consent or an Acceptable Solution or Verification Method under the Building Code.
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