Why do No-Lead (NL) products have PROP 65 warning labels?

California PROP 65 warning labels are another area of confusion. The question is why NL (No-Lead) and LF (Lead-Free) products like brass (yellow brass), red brass, and bronze products have the Proposition 65 warning labels.

The reason for this labeling requirement is because these materials are allowed to have an extremely low % of lead (Pb) under the NSF / ANSI-372 No-Lead requirement which is <0.25% Pb by weighted average.

However, California’s PROP 65 requires that the warning be applied if there is any trace of a chemical on the Prop 65 list of hazardous chemicals. Therefore, brass or bronze products, although referred to as NL or LF, must be labeled due to lead content.

304 SS and 316 SS do not require PROP 65 warning labels.

Materials such as 304 or 316 Stainless Steel valves, fittings, and other plumbing components which are 100% lead free (0.000% Pb content) do not require the PROP 65 warning labels although they are certified to the same ANSI/NSF-372 certification and testing protocols as materials with a low % of lead. This certification was forced on products manufactured from materials and alloys that were 100% lead free by nature in order to legally sell them in some areas of the USA. This defies common sense and makes the issue very confusing, needlessly increasing the cost. Unfortunately, it has caused many to believe that 304 and 316 SS alloys have lead in them, which is not the case.

Additional Resources:

https://www.p65warnings.ca.gov/about/frequently-asked-questions

https://oehha.ca.gov/proposition-65/proposition-65-list

https://support.boshart.com/are-products-certified-to-ansi/nsf-372-truly-no-lead-nl-or-lead-free-lf