What is Lead Free Pewter?
In the early 1990's the term "lead free" pewter was commonly used in the trade, and specifically applied by metal suppliers, to alloys of 900,000 ppm tin, with no more than .05% (500 ppm) lead. The voluntarily adoption of this "standard" appears to have been to identify alloys that would meet the Food and Drug Administration' s regulation that limited lead in pewter in contact with food. That regulation, FDA 2009 Food Code 4-101.13 (B), states:
"Pewter alloys containing lead in excess of 0.05% may not be used as a Food-Contact Surface."
Even with the actions first taken by the State of California and then recently by the Consumer Products Safety Commission, this loose definition of "lead free" still has not received clarification. In 1995 a pewter item testing at 450 ppm would have been considered by the trade as "lead free". In 2011 that same item would not necessarily be considered "lead free" due to the steadily lowering limits for lead in "children's jewelry" under the Consumer Product Safety Improvement Act (CPSIA). While this act is specifically directed to a narrow definition for children's jewelry, the effect has been to create an increased awareness of lead in metal alloys whether or not the product is intended for children.
Without a clear definition of "lead free", the trade has been left to monitor themselves. Most suppliers, manufacturers, wholesalers and retailers abide by the understanding that even though a particular product is not subject to the CPSIA lead limit (currently set at 300 ppm, and scheduled to drop to 100 ppm in August 2011) they will not promote a product as "lead free" unless it contains less than the old FDA limit of 500 ppm.
Regarding products that are promoted as "100% lead free": While it is, in theory, possible to cast a pewter product that would test at 0 ppm for lead, the practical reality is that production quantities of high quality "lead free" pewter contain somewhere between 30 – 100 ppm lead in the alloy. This lead is not intentionally added to debase the metal or reduce its cost, but naturally occurs in the ores that are refined to produce one or more of the elemental metals used to make the pewter alloy itself. Metal refiners continually strive to keep this "trace" out of the mixture, but the realities of the refining and alloy process can not readily eliminate all traces. Hence, claims of 100 % lead free pewter should be taken with skepticism.
In summary, though the trade continues to wrestle with definitive guidelines for "lead free pewter," the standard is generally accepted to be less than 500ppm of lead by weight.