Lead-Free by Design

For decades lead was a natural part of brass and gunmetal. It improves machinability, lowers tooling costs and gives clean threads. Lead-free brass with lead at max. 0.1 % is turning from a niche material into a requirement, because two sets of rules act on the same material at the same time, and both work with fixed dates: the RoHS Directive 2011/65/EU with exemption 6(c), and the EU Drinking Water Directive (EU) 2020/2184 with the European positive lists.

The legal framework in two sentences

RoHS limits lead to 0.1 % by weight per homogeneous material, transposed into national law in every Member State. The Drinking Water Directive allows permanent contact with drinking water only for materials held in a positive list, subject to the transitional arrangements to 2032.

RoHS: exemption 6(c) and its timeline

Without an exemption, leaded copper alloys would not be admissible in electrical and electronic equipment. Exemption 6(c) in Annex III allows up to 4 % lead in copper alloys. Delegated Directive (EU) 2025/2364 of 08.09.2025, published in the Official Journal on 21.11.2025, set its expiry date uniformly at 30.06.2027 for all equipment categories; the earlier separate date for category 11 has gone. A further renewal application was filed on time on 12.12.2025. Under Art. 5(5) of the Directive the exemption stays valid until the Commission decides, so the expiry date is suspended. That is not something to plan on: if the application is refused, the exemption expires under Art. 5(6) no earlier than 12 and no later than 18 months after the decision. Requalification, tooling, documentation and stock run-off all have to be completed within that window. Companies that have made the changeover reckon with at least two years. Anyone waiting for the decision will then have less time than the changeover needs.

New since 1 July 2026: the footnote to 6(c)

Since 01.07.2026 a footnote to exemption 6(c) applies; national transposition was due by 30.06.2026. It covers equipment supplied to the general public whose accessible parts can be put in the mouth by children. For that equipment 6(c) applies only with evidence of a lead release of no more than 0.05 micrograms per square centimetre and hour and, for coated parts, effectiveness for at least two years. For all other equipment 6(c) continues to apply unchanged. A statement of conformity under 6(c) should nevertheless give the proven lead content of the batch, otherwise a gap remains in the technical documentation.

Equipment or component: where RoHS applies

A common misjudgement concerns the scope. RoHS applies to equipment, not to individual pipework components. A purely hydraulic manifold without electrical function is not electrical equipment. Once an actuator, pump, controller or heat exchanger is added, the assembly is normally equipment, and RoHS then applies to every homogeneous material inside it, including the valves. What counts is the independent function, the classification under Art. 3 and the exclusions under Art. 2(4), among others for large-scale fixed installations. Heat pumps usually fall under category 1, transfer, domestic, fresh water, apartment and buffer charging stations usually under category 11. Responsibility for the declaration of conformity rests with the equipment manufacturer, not with the valve supplier. That is exactly why verbal assurances are not enough.

In short: what counts is not the material designation but the proven lead content per batch and the positive list entry of the material.

Terms on this page: lead-free means lead at max. 0.1 % and therefore RoHS conformity without exemption, low-lead means lead at max. 0.2 % and RoHS only via exemption 6(c), leaded means more than 0.2 % lead.

Drinking water: European positive lists from 31 December 2026

In parallel, the Drinking Water Directive applies. From 31.12.2026 the European positive lists under Implementing Decision (EU) 2024/367 replace the national assessment schemes, together with the conformity assessment under Delegated Regulation (EU) 2024/370 and the marking under Delegated Regulation (EU) 2024/371. From 01.01.2027 new products go through the EU route with EU certificate and EU marking.

The transitions matter in practice. Under Art. 3, nationally approved starting substances, compositions and constituents may continue to be used in manufacturing until 31.12.2032, provided 5 micrograms of lead per litre are met at the tap. Products holding a valid national conformity confirmation on 31.12.2026 may continue to be used within the transitional period, at the latest until 31.12.2032. Entries in the first European positive lists carry staggered expiry dates of their own: what determines how long a position can be built in is the expiry date of the entry, not the material name.

Lead at the tap: 10 or 5 micrograms per litre

The EU parametric value for lead at the tap is 10 µg/l and falls to 5.0 µg/l by 12.01.2036 at the latest; Member States may bring that date forward. Germany has done so with effect from 12.01.2028, and from then only listed materials may be newly installed there; free-cutting brass CW617N and CW614N drops out. Independently of the water value, the figure of 5 µg/l already governs the material side: it is the benchmark for the assessment of compositions and the condition attached to the Art. 3 transition. This affects not only new developments but every position that is still to be in the catalogue after 2028.

What applies to your component?

 Six questions, two minutes: the lead-free check shows you the RoHS and drinking water status of your material, the deadlines that count for you and the suitable alternatives from our range. You can print the result or save it as a PDF.

EU Positive List: who is already listed and who is covered by the transition rules

From 31.12.2026 the European positive list under Annex II of Implementing Decision (EU) 2024/367 applies. It contains only compositions assessed against the lead value of 5.0 micrograms per litre. CW510L-DW, CW724R-DW (entry 1658) and gunmetal CC470K (entry 1657) are already in it. CW511L-DW lead-free (Pb max. 0.1 %) is listed in the German UBA assessment basis and in the 4MS list, but not yet in Annex II. For this material Art. 3 of the Decision applies: compositions approved nationally between 13.07.2021 and 31.12.2026 may be used until 31.12.2032, provided they meet the lead value. Inclusion in the European positive list via the ECHA procedure is expected; applications are possible from 31.12.2026. The leaded grades CW617N, CW614N and CC499K as well as the standard version of CW511L-DW with up to 0.2 % lead are not in Annex II.

The material name alone is not enough

Lead-free brass is not a protected term. Two deliveries of the same material can have different lead contents.

For CW511L-DW the standard allows up to 0.2 % lead, while the German entry 2.5.3.2 without an expiry date requires lead at max. 0.10 %, arsenic 0.02 to 0.10 % and nickel at max. 0.10 %. What counts is the batch analysis and the delivery specification, not the short designation.

In practice many buyers choose CW510L-DW (CuZn42), because it was listed earlier than the lead-free CW511L variant and is already in the European positive list. Two things are easily overlooked: CuZn42 is not dezincification resistant, and the standard version contains up to 0.2 % lead. It is therefore listed for drinking water, but admissible under RoHS only via exemption 6(c). CW510L-DW becomes lead-free and compliant without exemption only with lead at max. 0.10 % in the delivery specification.

Less well known: since the fifth amendment of the German UBA assessment basis of 05.03.2025, CW511L-DW lead-free with Pb max. 0.1 % has been listed without an expiry date (UBA entry 2.5.3.2, listed there as "niedrig Blei", in the 4MS list as "low lead"). This provides a dezincification resistant material that meets RoHS without exemption and may be used in drinking water beyond 2028.

Stainless steel is back in focus

The copper price reached a record high on the LME in September 2026 and is well above the previous year. Brass and gunmetal follow this trend almost directly, because copper drives their price: CW511L-DW is about 62 % copper, CC470K 90 to 96 %. Stainless steel follows other price drivers, above all nickel and chromium through the alloy surcharge. As a result, stainless steel is again more often the cheaper option in cost comparisons, especially in larger nominal sizes. There are technical arguments too: stainless steel is structurally lead-free, does not dezincify and is listed for drinking water. On the other side are more demanding machining and, with chloride-bearing waters, the choice between 1.4301 and the molybdenum alloyed grades 1.4404 or 1.4571. Anyone who has to change over anyway should include stainless steel in the material comparison instead of only comparing brass with brass.

REACH applies on top, and it applies now

Lead has been on the REACH candidate list of substances of very high concern since 2018. Two obligations follow from this that apply independently of RoHS and drinking water law and have no transitional period: if an article contains more than 0.1 % lead by weight, the supplier must inform professional customers unprompted under Art. 33, answer consumers on request within 45 days, and since 2021 notify the article to the ECHA SCIP database.

This is where the wheat is separated from the chaff. A body made of CW510L-DW or CW511L-DW in the standard version with up to 0.2 % lead is above the threshold. It is listed for drinking water and, with 6(c), also RoHS compliant, but it triggers the full chain of information and notification: an Art. 33 declaration per position, a SCIP dossier per article, customer queries with every supplier self-assessment, and maintenance in master data and supplier portals. Anyone managing hundreds of article numbers carries a permanent administrative burden that grows with every customer.

At max. 0.1 % lead all of this falls away. It is no coincidence that three sets of rules converge on the same value: RoHS limits lead to 0.1 % per homogeneous material, REACH ties its duties to 0.1 % in the article, and the entries without expiry date for CW511L-DW lead-free, CW724R-DW and CC470K also require max. 0.10 %. Anyone specifying 0.1 % today meets all three without exemption, without notification and without an end date.

Pressure is more likely to rise. In April 2023 ECHA recommended lead for Annex XIV, the list of substances subject to authorisation. If that happened, lead could only be used in the EU with an authorisation granted. The Commission's decision is pending; the direction is clear.

For the delivery specification this means: 0.1 % not as an option, but as the standard. The batch analysis proves the value, and the Art. 33 declaration becomes the simplest statement in the file: not affected.

Evidence that counts

A changeover is only robust with traceable documentation. Mill and material certificates as well as further certificates are provided on request. In addition come the product-related declarations on RoHS, REACH and drinking water and the reference to the relevant positive list entry. All of this comes together in the technical documentation to EN IEC 63000, which supports the conformity assessment of the equipment.

The changeover in six steps

Y-pattern strainer with male thread, series 5.74, in CW511L-DW (No Lead, max. 0.10% Pb).            Microbubble separator with female thread, series 5.90/VA, in stainless steel 1.4301

Availability: valves in lead-free brass and stainless steel from SferaTec

Deadlines can only be met if the right materials are available in time. A large part of our range is already available in CW511L-DW and CW724R-DW; all other positions we produce lead-free to customer specification. We check per position which version is suitable for your article.

Materials and dimensions

• Valves and fittings in CW511L-DW and CW724R-DW, lead content max. 0.1 %
• Stainless steel versions in V2A and V4A
• Further positive list materials on a project basis, for example CW510L-DW or lead-free gunmetal CC470K
• Standard sizes from G 1/4 to G 2½, smaller and larger nominal sizes on a project basis and with minimum quantity

Evidence for every position

• Material certificate with the corresponding positive list entry
• Batch-specific material analysis stating the lead content
• RoHS declaration of conformity without relying on exemption 6(c), provided the material’s lead content does not exceed 0.1%

Coating as an option

For additional corrosion protection we offer a high-performance electroplated coating. It is free of chromium, lead, cobalt and cyanides, assessed by the German Environment Agency (UBA) and held in the 4MS list as well as in the first version of the European positive list. The coating complements the base material; it does not replace it. For drinking water applications a coated part must also be made of a positive list material.

Info Sheets to download

Frequently asked questions about RoHS, drinking water and materials

SferaTec Gebäudetechnik GmbH, Cliev 16, 51515 Kürten, T +49 2207 84 64 491, kluth@sferatec.de