Washington State Updates Regulations on Lead in Aluminum and Brass Cookware
Washington State has amended its regulations under the 70A.565 RCW code to address lead content in cookware made from aluminum or brass. Effective immediately, these changes establish new definitions, lead restrictions, and compliance deadlines for manufacturers, retailers, and importers of affected products.
Key Changes to the Law
Washington State has updated its law (70A.565 RCW) to focus specifically on cookware, components, and utensils made from brass or aluminum. Here’s what’s covered:
Cookware: Pots, pans, kettles, griddles, and vessels like internal pots for rice cookers or pressure cookers.
Components: Lids, rivets, fasteners, valves, and vent pipes.
Utensils: Knives, forks, spoons, spatulas, and similar tools used for preparing, serving, or eating food.
Exclusions: Items with an internal layer of aluminum or brass completely enclosed by stainless steel are exempt, as are the bodies of electronic cooking devices (like slow cookers) with removable containers. This is a shift from the previous, broader law that didn’t specify materials.
Previously, the law set a stricter limit of 5 ppm starting January 1, 2026, for all cookware and components. The new approach reflects a balance between safety and manufacturing realities, aligning with guidance from the U.S. Food and Drug Administration (FDA).
New Restrictions on Lead Content
The law sets phased restrictions on lead levels:
| New action | Previous action | |
| Target substance | Lead | Lead |
| Product scope | Aluminum or brass cookware Aluminum or brass cookware components Aluminum or brass utensils | Cookware and cookware components |
| Requirements | ≤ 90 ppm (1 January 2026) ≤ 10 ppm (1 January 2028)* | ≤ 5 ppm (1 January 2026) |
Why It Matters: Health and Compliance
Businesses must meet the following obligations:
Product Identification: Confirm which cookware, components, or utensils use aluminum or brass and fall under the new definitions.
Lead Testing: Verify compliance with the 90 ppm limit by January 1, 2026, and the 10 ppm limit by January 1, 2028.
Manufacturing Adjustments: Update materials or production processes to meet lead limits.
Supply Chain Coordination: Ensure suppliers comply with the new standards.
Future Monitoring: Track potential changes to lead limits after December 2030.
Context and Importance
Lead is a toxic metal that can leach into food from cookware, posing health risks—especially to children and pregnant women. The FDA underscored this concern in a December 2024 warning letter to retailers and distributors, flagging lead in imported aluminum and brass cookware. Washington State’s update is a proactive step to protect consumers.
Non-compliance may lead to:
Product recalls
Legal penalties under Washington State law
Potential federal enforcement actions
With the FDA also watching this issue, non-compliance could invite federal scrutiny. Staying ahead of these regulations isn’t just about following the law—it’s about keeping your customers safe.
A recommended approach is to partner with a trusted third-party provider, such as QIMA, to conduct comprehensive food contact material testing. QIMA offers specialized laboratory testing services, including heavy metal analysis, to help businesses ensure compliance with regulatory standards.
For the latest updates on product safety standards and regulations, visit Regulatory Updates. We provide regular updates to help you stay informed and ensure compliance with the latest requirements.
Related Articles
