Better Brakes Law - guidance for manufacturers

We provide guidance for manufacturers to help them comply with Washington's Better Brakes Law, including how to mark brake friction material and how to apply for a waiver from baseline reporting requirements.


Guidance for marking brake friction material

We've received questions about how to mark brake friction materials to comply with the requirements of the Better Brakes Rule, Chapter 173-901 WAC. The Better Brakes Rule requires brakes sold in Washington to be marked according to SAE J866, an industry standard. SAE J866 as designed enables people throughout the supply chain to identify the information contained in an edge code.

SAE J866, industry standard

To summarize SAE J866, brakes must be marked with the following information, in the following order:

  1. Manufacturer identifier
  2. Friction formula identifier
  3. Hot and cold coefficients of friction (Not required in Washington — but are required by several other states)
  4. Optional batch code or other optional information
  5. Environmental designator and year of manufacture

SAE J866 says, "The environmental markings are to be the last characters in the edge code string with no additional alpha or numeric characters following." When the edge code cannot be placed on a single line of text, it is read from top-to-bottom and left-to-right. Markings should be clearly legible. It is acceptable to place the markings under a clip or shim, provided it may be removed and replaced by hand without damaging the part, to read the markings underneath.

Brake markings

Markings on your brake friction material must match what you report to us when certifying your product. You must report the manufacturer identifier and the friction formula identifier. Ecology will reject certification documents with edge codes that clearly do not comply with SAE J866, such as "LW" or "9769."

It is preferable to mark brakes with an edge code in a single line of text, but we understand that there are a variety of marking technologies. Manufacturers should make a good faith effort to mark their products as described in J866. A brake marked with each of the required pieces of information in a manner that does not obscure the environmental markings is in substantial compliance with the Washington brake friction material marking requirements.

Marking brake packaging

Under the Better Brakes Rule, brake packaging must be marked with a registered certification mark that is intended to certify compliance with the Better Brakes Rule.

Additional marking guidance

Applying for a waiver from reporting requirements

The Better Brakes Law required manufacturers of brake friction material to submit baseline reports by January 1, 2013. Manufacturers may not certify brakes for sale in Washington until they submit a baseline report. However, some manufacturers may qualify for a waiver (exemption) from this reporting requirement, because they did not manufacture brake friction material during 2011, or their suppliers submitted information on the formulas they distribute. A manufacturer must submit a baseline report or receive a waiver from us before they may certify their products.

Installers and retailers

  • What can I do with pads that have copper once the bill goes into effect?
    Brake pads manufactured before 2015 containing copper or other regulated constituents may be sold or installed on vehicles normally until Jan. 1, 2025.
  • Since brake pads are not currently marked, what can I do unmarked products?
    Unmarked products may be sold until Jan. 1, 2025. After this date, all products must be marked with proof of certification.
  • Are low- and no-copper pads currently available?
    Yes. Low- and no-copper brakes are currently available from many manufacturers.
  • What happens if I sell or install a pad that is in violation of the law?
    If a retailer or distributor is found to be selling pads that violate the law, Ecology will advise them on how to comply, and notify the company that sold the pads. Repeated violations by retailers may result in a penalty.