Brass for Food & Beverage Contact — EU 1935/2004, CoE 2020/9, FDA 21 CFR 175, NSF 51 Compliance Guide

Brass appears throughout food and beverage processing equipment — beer-line fittings, coffee-machine valves, milk-pasteurisation lines, brewery couplings, soft-drink dispensers, kitchen fittings on commercial cookers. In all of these applications, the brass surface contacts liquid that will be consumed by humans. The regulatory framework treats this as a serious concern with explicit migration limits and required testing.

The EU framework — three layers

1. Framework Regulation (EC) 1935/2004 — the principal legislation. Establishes the principle that food-contact materials must not transfer their constituents into food in quantities that could endanger health or alter taste/odour/composition.
2. Council of Europe Resolution CM/Res(2020)9 and the EDQM technical guide Metals and alloys used in food contact materials and articles (2nd edition, 2024) — set specific release limits (SRLs) for metals from food-contact metallic articles. The de-facto reference for brass in food contact across Europe.
3. Member-state rules and guidance — for example the French DGCCRF information sheets on metals and alloys, the German BfR recommendations and the Italian Ministerial Decree of 21 March 1973. Each adds national requirements on top of the EU framework.

Specific release limits (EDQM guide, 2nd edition 2024)

The guide sets the following specific release limits (2nd edition, 2024; against the 2013 edition the limits for chromium, manganese and thallium were revised and a limit for zirconium was added). Release is tested with citric acid 5 g/L or artificial tap water as food simulant, at a time and temperature chosen for the intended use:

The lead limit of 10 µg/kg is the binding constraint for leaded brass, and the arsenic limit of 2 µg/kg is the point to check for arsenical DZR brass such as CW602N. Whether an article passes can only be shown by release testing of the finished part — the alloy alone does not settle it.

Practical alloy choice for food contact

The US framework — FDA + NSF

• FDA 21 CFR 175.300 — Resinous and polymeric coatings on food-contact metal; specifies which materials can be used as the coating but the underlying metal must independently be food-safe.
• FDA 21 CFR 184 — Direct food substances generally recognised as safe (GRAS) — covers copper as a nutritional ingredient.
• NSF/ANSI 51 — Food Equipment Materials — the standard for materials used in food equipment. Tests for extractable metals into food simulants.
• NSF/ANSI 61 — Drinking Water System Components — applies to water-side surfaces; complementary to NSF 51 for foodservice equipment.
• Safe Drinking Water Act, Section 1417 (Reduction of Lead in Drinking Water Act, in force since 4 January 2014, administered by the EPA) — weighted-average lead ≤ 0.25% on water-contact surfaces, nationwide.

Testing protocol for brass food-contact

1. Pre-test cleaning — degreasing, citric acid rinse, DI water rinse, dry. Mimics commissioning.
2. Test 1 (acidic food simulant) — citric acid 5 g/L, at the time and temperature that represent the intended use. Sample analysed by ICP-MS for the metals in the table above.
3. Test 2 (escalated temperature/time) — depending on intended use (e.g. 70°C/2h for hot drinks, 100°C/1h for boiling).
4. Artificial tap water — the second simulant of the guide, used for articles in contact with water and non-acidic foods.
5. Three successive tests for repeated-use articles — compliance is judged on the third test, with a limit on the sum of the first two.

Ask an accredited laboratory for a quotation — cost depends on the number of materials, simulants and test conditions.

Common food-contact brass applications

• Beer / wine / cider fittings — keg couplers, tap shanks. CW724R or stainless, with ethanol-tolerant elastomer seals.
• Coffee & espresso machines — group heads, boiler outlets, steam wands. CW724R; the US 0.25% lead rule applies to the water-contact surfaces.
• Milk / dairy lines — milkers, milk pumps. Typically 316L stainless (high alkalinity from cleaning chemistry favours stainless).
• Soft-drink dispensers — CO₂ regulators, post-mix valves. CW724R standard.
• Commercial kitchen plumbing — water inlet manifolds. WRAS-approved fitting in lead-free CW724R, where the UK market asks for it.

Sources & references

• EU Regulation 1935/2004 on food contact materials
• Council of Europe — Food Contact Materials
• FDA 21 CFR 175 — Indirect Food Additives
• NSF/ANSI 51 — Food Equipment Materials
• NSF/ANSI 61 — Drinking Water System Components
• CW724R datasheet · C6802 datasheet

Frequently asked questions

Sources & references

Food-contact references:

Last reviewed: September 2026. Standards and regulatory references are checked at each review.