Yes. While there is no requirement in the statute to label pipes, fittings or fixtures as either lead free or not lead free, a manufacturer could use labeling to establish that the pipe, fitting or fixture is used exclusively for nonpotable services and therefore, exempt from the lead free requirements in SDWA 1417(a)(1) and (3). In implementing the new requirements, EPA would generally consider pipes, fittings or fixtures to be used exclusively for nonpotable services if they are marketed and sold for use in nonpotable services, and prominently and clearly labeled as illegal to use in potable services and not anticipated for human consumption.
EPA also recommends that the label identify some examples of potable services to convey that it includes more than drinking water. For example, the label could say "It is illegal to use this product in potable services such as drinking water, handwashing, food preparation, and dishwashing."