The California law requires that a “Testing Certification Agency” (registrar) serve as the official source for registering and certifying brake friction materials for compliance. The “testing certification agency” is defined as “a third-party testing certification agency that is utilized by a vehicle brake friction materials manufacturer and that has an accredited laboratory program that provides testing in accordance with the certification agency requirements that are approved by the department.”
Under the California law, a Testing Certification Agency (Registrar) uses an accredited laboratory to certify compliance. The accredited laboratory is “…an accredited laboratory program that provides testing for the following constituents: cadmium and its compounds, chromium (VI) salts, lead and its compounds, mercury and its compounds, asbestiform fibers, and copper and its compounds.” The accredited laboratory needs to either meet the ISO 17025 standard or be accredited by the National Environmental Laboratory Accreditation Program (NELAP). If the analytical laboratory is accredited under the International Laboratory Accreditation Cooperation (ILAC) agreement and can perform the methods listed in SAE J 2975-2013 then the results from this laboratory would be acceptable to the department. If the laboratory is ILAC accredited but uses an alternative analysis method that may be equivalent to one or more methods listed in SAE J 2975-2013, the department would like to review the method(s) to confirm equivalence prior to testing.
The department published guidelines for the brake friction material manufacturers regarding the obligations of testing certification agencies (registrars) which intend to certify the content of brake friction materials offered for sale in California. The guidelines are intended to provide an outline of the minimum criteria for the testing certification agency which will certify products for sale in California.
An organization that is interested in becoming a testing certification agency (registrar) should also contact the Automotive Aftermarket Suppliers Association (AASA) to find out more about sublicensing their package mark, the AASA LeafMarks. Although a packaging mark is not required under the California law, the use of the packaging mark is not prohibited in California. Please note that the State of Washington’s regulations for brake friction material require the packaging mark.