AB 100 prohibits a person from manufacturing, and offering for sale in the state, an endpoint device, as defined, that does not meet a certain lead leaching standard. The bill requires products to be third party certified and would require the consumer-facing product packaging or product labeling of an endpoint device to bear specified lettering if the endpoint device meets that lead leaching standard.

Effective Jan. 1, 2023, a person is prohibited from manufacturing, and offering for sale in the state, an endpoint device that leaches more than one microgram (1µg) of lead per NSF/ANSI/CAN 61-2020.

Yes, until July 1, 2023. After this date a person is prohibited from introducing into commerce or offering for sale in the state an endpoint device that does not meet that lead leaching standard. (effectively Inventory sell through of non-compliant product, 5µg or less)

AB 100 defines an “endpoint device” as a single device, such as a plumbing fitting, fixture, or faucet, that is typically installed within the last one liter of the water distribution system of a building.

Ab 100 specifically clarifies what is and isn’t an endpoint devise. An endpoint device includes all of the following:

1. Remote chillers
2. Lavatory faucets
3.  Bar faucets
4.  Kitchen faucets
5.  Hot and cold water dispensers
6. Drinking fountains
7. Drinking fountain bubblers
8. Water coolers
9. Glass fillers
10. Residential refrigerator ice makers

NOTE: An endpoint device does not include either of the following:

1. Devices specifically exempted from section nine, “Mechanical Plumbing Devices,” of the 2020 NSF International Standard 61, which became effective in the year 2020
2. Devices the 2020 NSF International Standard 61, which became effective in the year 2020, subjects to a different lead leaching standard or normalization requirement than that specified in subdivision (A).

AB 100 requires consumer-facing product packaging or product labeling of an endpoint device that’s intended to convey or dispense water for human consumption that meets the Q ≤ 1 and is certified by an American National Standards Institute-accredited third party, shall indicate that compliance by including the lettering “NSF/ANSI/CAN 61: Q ≤ 1” in an easily identifiable manner.

Yes, currently the following low lead requirements are voluntary in the NSF/ANSI/CAN 61-2020 standard.

• Endpoint devices other than supply stops, flexible plumbing connectors, and miscellaneous components, the test statistics Q or R calculated in accordance with Section N-1.8.9 shall not exceed 1 μg/L
• For supply stops, flexible plumbing connectors, and miscellaneous components, the lead test statistic Q shall not exceed 0.5 μg/L.
• These become mandatory in the standard 1, 2024

Yes, you will need to submit such request to IAPMO R&T and provide test reports that we will review against your file in our records. Once we confirm that the current Q value is 1µg or less for devices other than supply stops, flexible connectors and miscellaneous components, and 0.5µg for supply stops, flexible connectors and miscellaneous components, we will then update your certificate accordingly.

For all models requested to be verified per the updated lead Q value requirement, we will verify during our review that packaging or labeling artwork or photos are provided showing compliance to 9.5.1.1.2 of the standard.

No, IAPMO R&T will place a footnote at the bottom of the existing listing that reads “For models indicated with a subscript “Q” the lead statistic Q value are in compliance with the “Optional Lower Lead Requirements” per Section 9.5.1.1 of NSF/ANSI/CAN 61-2020”.

Please submit a new application for the applicable work to be completed. It will be processed and quoted based on the number of families and extent of modifications needed.