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 roughly 0.8–3.5% 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 — most recently by Commission Delegated Directive (EU) 2025/2364 (OJ 21 November 2025). 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 | 1.6–2.2% | Exemption 6(c) | 30 Jun 2027 |
| CW614N | CuZn39Pb3 | 2.2–3.5% | Exemption 6(c) | 30 Jun 2027 |
| CW625N | CuZn35Pb1.5AlAs | 1.2–1.6% | Exemption 6(c) | 30 Jun 2027 |
| CW612N | CuZn39Pb2 | 1.6–2.5% | Exemption 6(c) | 30 Jun 2027 |
| CW607N | CuZn38Pb1 | 0.8–1.6% | Exemption 6(c) | 30 Jun 2027 |
| CW602N | CuZn36Pb2As | 1.7–2.8% | Exemption 6(c) | 30 Jun 2027 |
| CW724R | CuZn21Si3P | ≤ 0.10% | ✓ RoHS Free | — |
| C6802 | Bismuth brass | ≤ 0.10% | ✓ RoHS Free | — |
| CuZn37 | CW508L | ≤ 0.10% | ✓ RoHS Free | — |
| CuZn40 | CW509L | ≤ 0.2% | Free only if heat ≤ 0.10% | else 6(c): 30 Jun 2027 |
| CW510L | CuZn42 | ≤ 0.2% | Free only if heat ≤ 0.10% | else 6(c): 30 Jun 2027 |
| C27450 | CuZn36 low-Pb | ≤ 0.25% | Exemption 6(c) | 30 Jun 2027 |
| 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 — high chloride relative to the carbonate hardness, soft low-alkalinity water, pH above about 8, elevated temperature or stagnant 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 the material condition is designated by minimum tensile strength (R…) or by hardness (H…). Example — CW614N (CuZn39Pb3), EN 12164 minimum values:
| Condition | Rm (MPa) | Rp0.2 (MPa) | A (%) | Round bar |
|---|---|---|---|---|
| R360 | ≥ 360 | ≤ 350 (maximum) | ≥ 20 | Ø6–80 mm |
| R430 | ≥ 430 | ≥ 220 | ≥ 10 | Ø2–40 mm |
| R500 | ≥ 500 | ≥ 350 | ≥ 5 | Ø2–14 mm |
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 are approved under national or regional rules. In Europe, metals are accepted by listed composition; NSF/ANSI 61 tests leaching from the finished product. The approval always belongs to the finished product.
Regulatory concern about lead in drinking water has grown since the 2010s. The WHO guideline value is 10 μg/L, and EU Drinking Water Directive (EU) 2020/2184 lowers the EU limit from 10 to 5 μg/L by January 2036 — markets are moving toward lower-lead and lead-free alloys for potable-water contact.
In the US, leaded brasses such as CW617N (Pb 1.6–2.2%) are above the 0.25% weighted-average lead limit of NSF/ANSI 372 for wetted parts. In the EU, the European positive list that applies from 31 December 2026 contains no leaded brass; national approvals remain usable until 31 December 2032. The lead-free grades CW724R (silicon brass) and C6802 (bismuth brass) stay within the US limit, and CW724R is on the European positive list.
A listed alloy is necessary but not sufficient — the approval (WRAS, Kiwa, ACS, DVGW, NSF/ANSI 61) is granted to the finished component.
WRAS approval is voluntary evidence that a fitting complies with Regulation 4 of the Water Supply (Water Fittings) Regulations 1999. Non-metallic materials are tested to BS 6920 for their effect on water quality and the complete fitting mechanically; BS 6920 does not apply to metals.
| Regulation | Water Supply (Water Fittings) Regulations 1999 |
| Non-metallic parts | BS 6920 — effect on water quality |
| Metals | BS 6920 does not apply |
| Approval | The finished fitting — product-specific |
Materials and products in contact with drinking water must meet the Drinkwaterbesluit and the Regeling materialen en chemicaliën drink- en warm tapwatervoorziening. The recognised quality declaration is a certificate with the Kiwa Water Mark (formerly Kiwa-ATA), issued by Kiwa Nederland once the end product meets the requirements.
| Rules | Drinkwaterbesluit; Regeling materialen en chemicaliën |
| Certificate | Kiwa Water Mark (formerly Kiwa-ATA) |
| Assessment | The end product and its production process |
| EU requirements | For new products from 31 December 2026 |
ACS is the French sanitary conformity attestation for products in contact with water intended for human consumption. Under the Arrêté of 29 May 1997 it is required for organic materials and for accessories with an organic component; metallic parts must use accepted compositions.
| Regulation | Arrêté of 29 May 1997 |
| Organic materials | ACS required — also for accessories with an organic component |
| Metallic parts | Accepted compositions |
| Issued by | Accredited French test laboratories |
DVGW is the German technical and scientific association for gas and water, and it certifies drinking-water products. Metallic materials are assessed against the Umweltbundesamt (UBA) list of accepted metallic materials, which lists the accepted alloys by product group; organic parts are tested to KTW-BWGL and DVGW W 270.
| Metals | UBA list of accepted metallic materials |
| Organic parts | KTW-BWGL (migration); DVGW W 270 (microbial growth) |
| Certification | DVGW — the finished product |
NSF/ANSI/CAN 61 covers the health effects of drinking-water system components — leaching of metals and organic compounds. Lead content is covered separately by NSF/ANSI 372: “lead-free” means a weighted average of no more than 0.25% lead on the wetted surfaces.
| Health effects | NSF/ANSI/CAN 61 — leaching |
| Lead content | NSF/ANSI 372 — weighted avg ≤ 0.25% Pb |
| California | AB 1953 — weighted avg ≤ 0.25% Pb |
| Lead-free alloys | C6802 (bismuth), CW724R / C69300 (silicon) |
Thirteen of our most-specified alloys, mapped against RoHS, REACH, dezincification resistance, the EN product standard and the lead rules for drinking water. See the full materials library for all 30 grades.
| Alloy | RoHS | REACH Art.33 | DZR (ISO 6509-1) | EN 12164 | US lead-free (NSF/ANSI 372) | EU positive list |
|---|---|---|---|---|---|---|
| CW617N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ Pb 1.6–2.2% | Not listed ¹ |
| CW614N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ Pb 2.2–3.5% | Not listed ¹ |
| CW625N | Ex 6(c) | Required | ✓ DZR | ✓ Yes | ✗ Pb 1.2–1.6% | Not listed ¹ · on the 4MS list |
| CW612N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ Pb 1.6–2.5% | Not listed ¹ |
| CW607N | Ex 6(c) | Required | ✗ No | ✓ Yes | ✗ Pb 0.8–1.6% | Not listed ¹ |
| CW602N | Ex 6(c) | Required | ✓ DZR | ✓ Yes | ✗ Pb 1.7–2.8% | Not listed ¹ |
| CW724R | ✓ Free | Not required | ✓ DZR | ✓ Yes | ✓ Pb ≤0.10% | ✓ EUPL 1658 · B–D |
| C6802 | ✓ Free | Not required | ✗ No | JIS H3250 | ✓ Pb ≤0.10% | Not listed |
| CuZn37 | ✓ Free | Not required | ✗ No | EN 12167 | ✓ Pb ≤0.10% | ✓ CW508L-DW · EUPL 1647 · B–D |
| CuZn40 | By heat (Pb ≤0.2%) | If Pb > 0.10% | ✗ No | EN 12167 | ✓ Pb ≤0.20% | ✓ CW509L-DW · EUPL 1648 · B–D |
| CW510L | By heat (Pb ≤0.2%) | If Pb > 0.10% | ✗ No | EN 12167 | ✓ Pb ≤0.20% | ✓ CW510L-DW · EUPL 1649 · B–D |
| C27450 | Ex 6(c) | If Pb > 0.10% | ✗ No | UNS only | ✓ Pb ≤0.25% | Not listed |
| C11000 | ✓ Free | Not required | N/A (copper) | ASTM B152 / B187 | ✓ no lead addition | ✓ Cu-ETP · EUPL 1669 · C–D |
EN 12164: ✓ = listed in EN 12164; otherwise the standard the grade is made to. US lead-free: the grade’s lead range against the 0.25% weighted-average limit of NSF/ANSI 372 for wetted surfaces. ¹ EU positive list: compositions authorised by Commission Implementing Decision (EU) 2024/367, Annex II, which applies from 31 December 2026 — shown with the entry number (EUPL) and the product groups (Implementing Decision (EU) 2024/365): B = fittings and ancillaries in building installations; C = components of group-B products, and fittings and ancillaries in water mains and treatment works; D = components of fittings and ancillaries in water mains and treatment works (under 0.1 % of the contact surface). Leaded brasses are not on the list. Compositions approved nationally between 13 July 2021 and 31 December 2026 — for example on the 4MS / UBA lists — may be used until 31 December 2032 if the product meets 5 µg/l lead at the tap; for product group D only (components in water mains and treatment works, not in building installations), entry 1691 accepts other copper alloys with Pb ≤ 1.8 % until 31 December 2031. Approvals (WRAS, Kiwa, ACS, DVGW, NSF/ANSI 61) are granted to the finished product, never to the alloy alone.
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: September 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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