Everything you need to specify compliant brass: RoHS, REACH, DZR, EN product standards, and global potable water approvals — explained clearly.
The Restriction of Hazardous Substances Directive limits lead to ≤0.10% by weight in electrical and electronic equipment (EEE). Leaded brass alloys exceed this limit and rely on a critical exemption.
RoHS 2 (2011/65/EU, amended by 2015/863/EU) restricts 10 hazardous substances in EEE sold in the EU. For brass, the critical substance is lead (Pb), restricted to a maximum of 0.10% by weight in homogeneous materials.
Leaded brass alloys (CW617N, CW614N, CW625N, CW612N, CW607N, CW602N) contain 1.0–3.5% lead — far above the 0.10% threshold. They cannot be used in EEE without a specific exemption.
Annex III, Exemption 6(c) of RoHS 2 permits the use of lead as an alloying element in copper alloys containing up to 4% lead by weight in EEE components.
Exemption 6(c) has been renewed multiple times. The current validity expires 30 June 2027. Manufacturers designing new EEE should evaluate lead-free alternatives now to avoid disruption at the next renewal.
Six alloys in our portfolio carry Pb ≤ 0.10% and require no RoHS exemption:
| Alloy | Name | Pb Content | RoHS Status | Valid Until |
|---|---|---|---|---|
| CW617N | CuZn40Pb2 | 1.6–2.5% | Exemption 6(c) | 30 Jun 2027 |
| CW614N | CuZn39Pb3 | 2.5–3.5% | Exemption 6(c) | 30 Jun 2027 |
| CW625N | CuZn38Pb2 | 1.5–2.5% | Exemption 6(c) | 30 Jun 2027 |
| CW612N | CuZn38Pb1.5 | 1.0–2.0% | Exemption 6(c) | 30 Jun 2027 |
| CW607N | CuZn36Pb2 | 1.5–2.5% | Exemption 6(c) | 30 Jun 2027 |
| CW602N | CuZn36Pb2As | 1.5–2.5% | Exemption 6(c) | 30 Jun 2027 |
| CW724R | CuZn21Si3P | ≤ 0.10% | ✓ RoHS Free | — |
| C6802 | CuZn17Si4 | ≤ 0.09% | ✓ RoHS Free | — |
| CuZn37 | CW508L | ≤ 0.10% | ✓ RoHS Free | — |
| CuZn40 | CW509L | ≤ 0.10% | ✓ RoHS Free | — |
| CW510L | CuZn42 | ≤ 0.10% | ✓ RoHS Free | — |
| C27450 | CuZn36 low-Pb | ≤ 0.09% | ✓ RoHS Free | — |
| C11000 | Cu-ETP | ≤ 0.005% | ✓ RoHS Free | — |
REACH governs the registration, evaluation, authorisation and restriction of chemicals in the EU. For brass manufacturers and their customers, REACH creates communication obligations around lead.
Lead is included on the REACH Substances of Very High Concern (SVHC) candidate list. SVHC status triggers specific obligations under REACH Article 33.
All leaded brass components (Pb > 0.10%) should be accompanied by Article 33 notification disclosing lead as an SVHC. Brassland provides REACH compliance declarations with all leaded-grade shipments.
The two regulations are often confused — they have different scope, triggers, and obligations.
| Aspect | RoHS | REACH |
|---|---|---|
| Scope | Electrical & electronic equipment | All articles and substances |
| Trigger | Pb > 0.10% in EEE | SVHC > 0.10% in any article |
| Obligation | Prohibition (unless exempt) | Communication/notification |
| Lead status | Restricted — Exemption 6(c) | SVHC candidate list |
| Non-EEE use | Does not apply | Still applies (Article 33) |
| Key document | Declaration of Conformity | Article 33 SVHC notification |
Substances manufactured or imported into the EU above 1 tonne/year must be registered with ECHA. As an India-based exporter to the EU, Brassland's European customers or importers carry the registration obligation — not Brassland directly.
Substances on REACH Annex XIV require authorisation for use. Lead metal is on the SVHC candidate list but has not yet been included in Annex XIV as of 2025 — meaning no authorisation is currently required for lead in alloys.
REACH Annex XVII restricts lead in jewellery articles (entry 63) and in certain consumer products. Brass fittings in industrial, plumbing, or EEE applications are governed by RoHS or REACH Art. 33, not the jewellery restriction.
Dezincification is a corrosion mechanism in brass where zinc preferentially dissolves, leaving a weak, porous copper residue. DZR alloys resist this attack and are mandatory in many plumbing and potable water applications.
In brass alloys with Zn > ~15%, zinc can selectively dissolve when exposed to aggressive water conditions — low pH, stagnant water, elevated temperature, elevated chloride, or soft (low-mineral) water. The process occurs in two forms:
The dezincified layer is mechanically weak — the copper skeleton retains the original shape but has negligible strength. Pressure-bearing components can fail catastrophically if DZ is severe.
ISO 6509-1 is the standard accelerated dezincification test for copper alloys.
Most alloy-level qualifications are provided by the material producer. Component-level testing may be required by potable water approval bodies (WRAS, KIWA, etc.).
Different DZR alloys use fundamentally different mechanisms — understanding this matters for material selection.
European Norm (EN) standards define the compositional limits, mechanical properties, and quality requirements for brass wrought products. These are the standards referenced in Brassland's material certifications.
Under EN 12164, temper is defined by the cold-worked condition and expressed as minimum tensile strength (MPa):
| Temper | Rm (MPa) | Rp0.2 (MPa) | A (%) | Use Case |
|---|---|---|---|---|
| R360 | 360–470 | ≥ 140 | ≥ 18 | General CNC, good ductility |
| R430 | 430–570 | ≥ 270 | ≥ 8 | Higher strength, tighter tolerances |
EN 10204 defines the types of inspection documents supplied with metallic products:
Brassland supplies EN 10204 Type 3.1 certificates as standard on all material orders.
Fittings and components in contact with drinking water require specific national or regional approvals. Each approval body has its own alloy composition rules, leaching limits, and DZR requirements.
Regulatory concern about lead migration into drinking water has intensified significantly since the 2010s. The WHO guideline of 10 μg/L and the EU Drinking Water Directive (2020/2184) target of 5 μg/L by 2036 are driving markets to require lower-lead or lead-free alloys for all potable water contact.
Traditional CW617N (Pb 1.6–2.5%) is now excluded from potable water use in virtually all regulated markets. The approved route is either a DZR silicon brass (CW724R, C6802) or a low/no-lead structural grade (C27450, CuZn37).
Note: Alloy approval is necessary but not sufficient — the finished component must also pass leaching tests for the relevant approval body.
WRAS approval is required for plumbing products in the UK. The scheme is administered by WRAS Ltd and references the Water Supply (Water Fittings) Regulations 1999.
| Key test | BS EN 15664 leaching test (21-day stagnation) |
| DZR | Required per BS EN ISO 6509-1 |
| Pb limit | ≤ 0.10 μg/L in extract (BS EN 15664) |
| Alloys | CW724R approved; CW617N excluded |
| Product | Finished component approval required |
KIWA is a notified body and certification institute. KIWA approval (KIWA-ATA) is required for materials in contact with drinking water in the Netherlands and is widely recognised in Scandinavian markets.
| Key test | ATA (Allowable amount) leaching protocol |
| DZR | Required per ISO 6509-1 for copper alloys |
| Pb limit | Very low — effectively requires Pb ≤ 0.10% |
| Alloys | CW724R approvable; leaded grades excluded |
| Process | Component + system testing required |
ACS is the French sanitary conformity declaration for products in contact with water intended for human consumption. It is issued by accredited French test labs and is mandatory for the French market under Code de la Santé Publique.
| Key test | Migration test to French regulation arrêté |
| DZR | Required for brass alloys in water service |
| Pb limit | Migration ≤ 1 μg/L (strict) |
| Alloys | CW724R approvable; leaded grades excluded |
| Validity | 5-year renewable term |
DVGW is the German technical and scientific association for gas and water. DVGW certification (VP 585, W 270, W 534 etc.) is required for plumbing products in Germany, Austria, and Switzerland.
| Key standards | DVGW W 270, VP 585, DIN EN 15664 |
| DZR test | ISO 6509-1 pass required |
| Pb limit | ≤ 0.10 μg/L migration (W 270) |
| Microbiology | W 270 biofilm growth test also required |
| Alloys | CW724R certified; leaded excluded for DW |
NSF/ANSI 61 is the American National Standard for health effects of drinking water system components. Required by most US state codes; mandatory in 49 US states and all Canadian provinces for products in contact with potable water.
| Lead limit | < 11 μg/L Pb in extract (general) |
| NSF 372 | "Lead-free" = weighted avg ≤ 0.25% Pb |
| AB 1953 | California: ≤ 0.25% weighted avg Pb |
| Alloy | C6802 (CuZn17Si4) — ASTM B371 |
| Standard | ASTM B371 specifies composition limits |
All 13 Brassland alloys mapped against every standard and approval discussed in this guide.
| Alloy | RoHS | REACH Art.33 | DZR (ISO 6509-1) | EN 12164 | WRAS | KIWA | ACS | DVGW | NSF 61 |
|---|---|---|---|---|---|---|---|---|---|
| CW617N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ | ✗ | ✗ | ✗ | ✗ |
| CW614N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ | ✗ | ✗ | ✗ | ✗ |
| CW625N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ | ✗ | ✗ | ✗ | ✗ |
| CW612N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ | ✗ | ✗ | ✗ | ✗ |
| CW607N | Ex 6(c) | Required | Partial* | ✓ Yes | ✗ | ✗ | ✗ | ✗ | ✗ |
| CW602N | Ex 6(c) | Required | ✓ DZR | ✓ Yes | Possible† | Possible† | Possible† | Possible† | ✗ |
| CW724R | ✓ Free | Not required | ✓ DZR | ✓ Yes | ✓ Approvable | ✓ Approvable | ✓ Approvable | ✓ Approvable | Via B371 |
| C6802 | ✓ Free | Not required | ✓ DZR | ASTM B371 | UK equiv. | EU equiv. | EU equiv. | EU equiv. | ✓ NSF 61 |
| CuZn37 | ✓ Free | Not required | ✗ No | EN 12167 | Non-pressure | Non-pressure | Non-pressure | Non-pressure | Non-pressure |
| CuZn40 | ✓ Free | Not required | ✗ No | EN 12167 | ✗ | ✗ | ✗ | ✗ | ✗ |
| CW510L | ✓ Free | Not required | ✗ No | EN 12167 | ✗ | ✗ | ✗ | ✗ | ✗ |
| C27450 | ✓ Free | Not required | ✗ No | EN 12164 | Market-dep. | Market-dep. | Market-dep. | Market-dep. | ✗ |
| C11000 | ✓ Free | Not required | N/A (copper) | EN 1057 | ✓ Yes | ✓ Yes | ✓ Yes | ✓ Yes | ✓ Yes |
* CW607N's lower Zn (~36%) gives inherently better DZ resistance but it is not formally DZR-classified. † CW602N may achieve approval where both DZR and a potable-water-legal lead level are demonstrated; market-by-market approval applies. "Approvable" means the alloy composition meets requirements; component-level testing and listing is required in all cases.
Every regulatory date, test method, and threshold on this page is taken from the publishing body. Open the official source to verify any claim.
Last reviewed: May 2026. Regulatory dates change — for procurement decisions, verify the current state at the official source. Brassland is not a legal or regulatory advisor; this guide is for technical orientation.
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