Brass intended to contact food or drink in the EU is regulated by EU Regulation 1935/2004 (food contact materials framework) and the specific metals release limits of Council of Europe Resolution CM/Res(2013)9. Lead, cadmium, arsenic, antimony and several other metals have explicit migration limits in ppb/L; leaded brass (CW617N, CW614N) typically cannot meet these limits and lead-free silicon brass (CW724R, C6802) is the engineered route. For US market: FDA 21 CFR 175.300 and NSF 51 apply. This guide maps the regulatory landscape, testing requirements and alloy choice for brass in food & beverage equipment.
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
- 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.
- Council of Europe Resolution CM/Res(2013)9 — sets specific release limits (SRLs) for metals from food-contact metallic articles. The de-facto reference for brass in food contact across the EU.
- Member-state specific implementation — France (DGCCRF / Arrêté du 13 janvier 1976), Germany (BfR Recommendations), Italy (DM 21 March 1973). Each adds market-specific requirements on top of the EU framework.
Specific release limits (CoE 2013/9)
The Resolution sets the following maximum migration limits to food simulants (typically tartaric acid 0.5% w/v at 40°C for 24 hours, then escalating temperature/time per use case):
| Metal | SRL (µg/kg food) | Source in brass |
|---|---|---|
| Lead (Pb) | 10 | Free-machining brass (CW617N, CW614N) |
| Cadmium (Cd) | 5 | Trace in some brass; not normally an issue |
| Arsenic (As) | 2 | CW602N DZR contains 0.02–0.15% As as inhibitor |
| Antimony (Sb) | 40 | Trace possible |
| Mercury (Hg) | 3 | Not in standard brass |
| Aluminium (Al) | 5,000 | Aluminium brass C68700 |
| Barium (Ba) | 1,200 | Not in standard brass |
| Cobalt (Co) | 20 | Not in standard brass |
| Copper (Cu) | 4,000 | Always present |
| Iron (Fe) | 40,000 | Trace impurity |
| Manganese (Mn) | 1,800 | Manganese bronze C67500 |
| Nickel (Ni) | 140 | Trace + plating layers |
| Zinc (Zn) | 5,000 | Major constituent of brass |
The lead limit at 10 µg/kg is the binding constraint for leaded brass. Standard CW617N typically leaches 50–300 µg/kg under the test conditions, failing the limit by 5–30×. The arsenic limit at 2 µg/kg also problematises CW602N for food contact (the arsenic added as DZR inhibitor can leach above this limit).
Practical alloy choice for food contact
| Alloy | EU food contact? | US food contact? | Notes |
|---|---|---|---|
| CW617N (CuZn40Pb2) | No (Pb leach > 10 µg/kg) | No (FDA Pb limit) | Use only outside wetted area |
| CW602N (CuZn36Pb2As) | Marginal (As leach risk) | No | Not recommended new builds |
| CW724R (CuZn21Si3P) | ✓ Yes | ✓ Yes (low Pb, NSF 51) | The European default for food/beverage |
| C6802 (CuZn17Si4) | ✓ Yes | ✓ Yes (NSF 51, NSF 61) | The US default |
| CuZn37 (CW508L) | ✓ Yes | ✓ Yes | For low-pressure cosmetic parts |
| C11000 (Cu-ETP pure copper) | ✓ Yes (with Cu migration limit) | ✓ Yes | Higher Cu migration concern at low pH; OK for water but not for acidic foods |
| Stainless 316L | ✓ Yes | ✓ Yes | The non-brass alternative |
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.
- FDA Lead Reduction Act (Safe Drinking Water Act) — California-style weighted-average Pb ≤ 0.25% for water-contact surfaces.
Testing protocol for brass food-contact
- Pre-test cleaning — degreasing, citric acid rinse, DI water rinse, dry. Mimics commissioning.
- Test 1 (acidic food simulant) — 0.5% tartaric acid, 40°C, 24h. Sample analysed by ICP-MS for the metals in the table above.
- Test 2 (escalated temperature/time) — depending on intended use (e.g. 70°C/2h for hot drinks, 100°C/1h for boiling).
- Test 3 (alkaline simulant) — for some applications, NaHCO₃ solution.
- Repeat 3 sequential extractions — to verify reduction with use (regulations require all extractions to pass).
Total cost €1,500–€3,500 per product family at an accredited lab.
Common food-contact brass applications
- Beer / wine / cider fittings — keg couplers, tap shanks. CW724R or stainless. Pre-rinse for ethanol-tolerant elastomers.
- Coffee & espresso machines — group heads, boiler outlets, steam wands. CW724R; FDA Lead Reduction Act applies in California.
- 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 CW724R.
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
Is brass safe for food contact?
What is NSF/ANSI 51?
Which brass grades are used for food contact?
Sources & references
Food-contact references:
Last reviewed: June 2026. Standards and regulatory references are checked at each review.