Low Lead Plumbing Products Guide

Last Updated: Thursday, September 17, 2009

[Faucet Photo]NSF International is at the forefront of the low-lead plumbing products issue, having actively worked with the State of California and other key States for over fifteen years, through the ongoing development of NSF/ANSI Standard 61. The standard has played a key role in CA Proposition 65 lead settlements and is now the American National Standard for lead content in plumbing products.

Most recently, NSF developed the evaluation procedures in NSF/ANSI Standard 61- Annex G to establish an American National Standard to determine product compliance with the ≤0.25% percent maximum weighted average lead content requirement of the California Health and Safety Code (Section 116875; commonly known as AB1953) as well as for other states developing similar regulations.

[Valve Photo]NSF offers certification to this standard to manufacturers of products that contact drinking water, including faucets, flexible plumbing connectors, valves, meters and many other product types. Certification to the optional NSF/ANSI Standard 61- Annex G enables manufacturers to demonstrate product compliance with the ≤0.25 percent maximum weighted average lead content requirement of these new state laws which go into effect January 1, 2010.

This webpage has been created to assist all involved parties with recent happenings in regards to legislation of low-lead plumbing products, NSF 61, Annex G developments, and certification. We encourage you to bookmark this page and check back frequently for the latest information.

This page is updated frequently, however, if you find incorrect or outdated information, please email us at watermarketing@nsf.org.

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Top 10 Questions

  1. What do I need to know about California with respect to low-lead laws?

    The State of California enacted legislation (AB 1953) which revises the term "lead free" as it relates to any pipe, pipe or plumbing fitting, or fixture intended to convey or dispense water for drinking or cooking. For these products, "lead free" means not more than a weighted average lead content of 0.25 percent. The weighted average is determined by multiplying the lead content of each wetted component times the proportion of the total wetted surface area represented by that component and summing up the results.

    Effective January 1, 2010, no person will be able to use, install, or bring into commerce these products unless they comply with new "lead free" requirements of the law.
  2. Does NSF/ANSI Standard 61, Annex G satisfy the requirements of California law?

    Yes. NSF/ANSI Standard 61, Annex G was developed specifically to meet the requirements of California's AB 1953. Simply put, being certified to NSF/ANSI Standard 61, Annex G means that you comply with California's Health & Safety Code Section 116875 (commonly known as AB 1953).

    In addition, NSF International is named in both the California law itself (SB 1334) and the California Department of Toxic Substance Control (DTSC) fact sheet entitled, "Requirements for Low Lead Plumbing Products in California" (page 3, "Are there any certification requirements?"). For more information, visit NSF's press release on this subject.
  3. What is NSF's role in the development of a standard to meet California requirements?

    No one has more experience working with California legislators and officials on AB 1953 and its requirements than NSF. Sponsors of the bill and other key groups asked NSF for input and to develop procedures and methods to certify products to the California requirements. Considering NSF International's long history of writing standards and certifying products, it is natural that NSF would serve this role. More specifically, in 1996, Section 1417 of the Safe Drinking Water Act (SDWA) - the main federal law that ensures the quality of Americans' drinking water - was amended to require endpoint devices which dispense drinking water to comply with the lead leach requirements of the American National Standard, NSF/ANSI Standard 61.

    After California passed AB 1953 in 2006, means for complying with the new law, including testing methods, still needed to be developed. The NSF Standard 61 Joint Committee then charged its Lead Task Group with reviewing and developing criteria that would meet AB 1953 requirements. This Lead Task Group received guidance from key regulators, proponents of the California lead bill, and industry representatives, in addition to the NSF Standard 61 Joint Committee (a group comprised of equal representation from public health, user communities, and industry to ensure an open, transparent consensus process).

    The resulting document - NSF/ANSI Standard 61, Annex G - was voted on by the consensus-based Standard 61 Joint Committee, approved by the NSF Council of Public Health Consultants and published in late 2008.
  4. As a manufacturer of plumbing products, what should I be doing to prepare for the January 1, 2010 deadline?

    Since the deadline is right around the corner, it is advisable to start by confirming the lead content of your products. If your products are within the ≤0.25% lead content level, you can have a competitive advantage by getting certified to NSF-61 Annex G now. If your products don't currently comply with the new requirement, you should begin working toward product revisions that will comply with the new legislation.
  5. Can a manufacturer use plating, coatings or acid wash treatments to make a device comply with Annex G and the California low lead regulations?

    No. While NSF Standard 61 allows the use of platings, coatings, or acid wash treatments, these cannot be used to meet the 0.25% weighted average lead content requirements of Annex G. The weighted average must be based on the lead content of the component, not just the lead content on the surface. This requirement was incorporated into Annex G based on a letter expressing the legislative intent of AB 1953 sent to NSF from the California legislator who authored AB 1953. This is also reflected in a legal opinion from East Bay Municipal Utility District's counsel, the utility that sponsored AB 1953. While the California legislation does not specifically address coatings, platings or acid wash systems, manufacturers that attempt to use these techniques to comply with the California requirements may face legal challenges.
  6. Is laboratory testing required as part of NSF/ANSI Standard 61, Annex G certification program?

    Currently, NSF/ANSI Standard 61, Annex G does not specify what procedures are to be used to verify of lead content of a component. The California Department of Toxic Substances Control (DTSC) is working with NSF and the Lead Task Group to validate a methodology for this purpose.

    NSF product certification to Annex G takes into consideration the worst-case potentials for lead content. This is achieved by incorporating the maximum lead content potential for each component and is determined through the material specifications used. For instance, the lead content specifications for copper alloys like brass are often provided as a range and it's the maximum value of that range that is used in the calculation of weighted average lead content and forms the basis of product compliance.
  7. Is there an NSF/ANSI Standard 61, Annex G certification mark for my product and literature? How will my NSF online listing be updated?

    Products that are NSF Certified to NSF/ANSI Standard 61, Annex G utilize a special certification mark that should be used on products, literature, and in other promotional ways. NSF's online listings are also updated to include the addition of Annex G for those certified products. Listing information for those products certified to Annex G will bear a listing note stating, "Product also Certified to NSF/ANSI Standard 61, Annex G (weighted average lead content of ≤0.25%) and is in compliance with California's Health & Safety Code Section 116875 (commonly known as AB 1953.)"

    For samples and more information, see the Annex G Product Marking section.
  8. Can a product be certified only to the lead content requirements of Annex G and not the lead leaching and other requirements of NSF/ANSI Standard 61?

    No. Annex G requires that products must be compliant with the full requirements of NSF/ANSI 61 plus the weighted average lead content to comply with Annex G. However, NSF can evaluate products that are not covered under NSF/ANSI Standard 61, such as pressure and temperature relief valves, coffee machines or point-of-use water treatment devices, to determine if they meet the weighted average lead requirements.
  9. Are other U.S. states considering enacting low-lead legislation for plumbing products?

    Vermont recently enacted a law similar to California's, which is also scheduled to take effect January 1, 2010. Maryland proposed similar legislation within Maryland House Bill 357, and legislation regarding lead content marking of consumer products has been proposed in the State of Washington House Bill 1346.
  10. Where can I go for more information on this subject?

    For technical information, contact NSF's Pete Greiner at (+1) 734.769.5517 or greinerp@nsf.org. For information about getting new products certified, contact NSF's Ellen Van Buren at (+1) 734.827.3822 or vanburen@nsf.org.

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Annex G Overview

[Faucet Photo]NSF/ANSI Standard 61 was revised in December 2008 to establish requirements for use when a 0.25% lead content requirement needs to be met in addition to current chemical extraction requirements of the standard. The requirements were placed in Annex G - Weighted Average Lead Content Evaluation Procedure to a 0.25% Lead Requirement. In addition, mandatory language placing restrictions on the use of lead as an intentional additive in water contact materials was also added to Section 3. To view the full content of the annex as adopted in NSF/ANSI 61 - 2008, download the PDF document.

A request was made to add these requirements to the standard to allow manufacturers the option of being certified to a lead content standard, such as California's Health & Safety Code (Section 116875) commonly known as AB1953. That law, which goes into effect January 1, 2010, applies to any pipe, pipe of plumbing fitting, or fixture intended to convey or dispense water for human consumption through drinking or cooking. A similar law has been enacted in Vermont and is also to take effect January 1, 2010.

The annex was developed through the Lead Task Group of the Drinking Water Additives Joint Committee and includes requirements that enable conservative and consistent application of the lead content evaluation procedure. Highlights include:

  • The annex contains <0.25% weighted average lead content requirements. Compliance is determined by a weighted average calculation involving the maximum percent lead content of material specifications and wetted surface areas.
  • Does not consider coatings or acid washing. Compliance is determined by the maximum percent lead content of material specification for each component prior to application of any coatings or lead wash treatments. Documents including an opinion from East Bay Municipal District and statement of legislative intent were provided to the Lead Task Group during development of the annex.
  • For internally threaded products, the wetted surface area includes 25 percent of the threaded area(s). This is consistent with the assumptions used in the rest of Standard 61.
  • Annex G does not contain a verification test protocol at this time as compliance is determined based on calculations using the maximum % lead content of material specification. A verification test methodology is under development for addition to Standard 61 that can be used when a there is a need or desire to verify that the actual lead content of a component is within the stated lead content of the material specification. The work being done on this verification methodology is being performed through the Lead Task Group and California's Department of Toxic Substance Control (DTSC) to establish a consistent protocol that can be used by all.
  • Annex G is an optional annex under NSF/ANSI 61. Certifications to Annex G note compliance within the NSF/ANSI 61 or NSF/ANSI 14 listing.
  • The annex requires full compliance with NSF/ANSI 61.
  • The annex does not specifically reference California and applies to any jurisdiction with a ≤0.25% weighted average lead content requirement.

For questions or concerns regarding NSF 61 Annex G, please contact Pete Greiner at (+1) 734.769.5517 or greinerp@nsf.org.

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NSF-Certified Products

To search for of NSF-61 Annex G certified products, visit the NSF listings page on the public website. Remember to look for the Annex G footnote on the listings page which states, "Product also Certified to NSF/ANSI Standard 61, Annex G (weighted average lead content of ≤0.25%) and is in compliance with California's Health & Safety Code Section 116875 (commonly known as AB1953.)."

You may also access the complete lists of NSF-certified products to Annex G:

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Product Markings for Annex G NSF-Certified Products

Products that are NSF-certified to NSF/ANSI Standard 61, Annex G utilize a special certification mark that designates the addition of Annex G certification. This will vary slightly depending on whether the product is certified to NSF/ANSI Standard 61, NSF/ANSI Standard 61, Section 9, or NSF/ANSI Standard 14 (which references NSF 61).

NSF Mark NSF Mark
NSF Mark

The NSF Annex G certification marks can be downloaded via the NSF marks download page.

Should you have any questions about product marking, contact your NSF certification project manager, or Kim Van Kirk, NSF Marketing Manager, at (+1) 734-913-5749 or vankirk@nsf.org.

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NSF PR on Low-Lead/Annex G

NSF issues press releases as new developments arise with the low lead situation. Click on the release titles below to access the full release.

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Getting Certified

If you are interested in getting your products certified to NSF/ANSI Standard 61, Annex G, please email annexg@nsf.org today. Don't forget to indicate your country of origin so we can put you in touch with the NSF representatives located closest to you.

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Helpful Links

For more information on this subject, NSF encourages you to visit these websites:

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