LCRI 2027 and Your CCR

Beginning November 1, 2027, community water systems must comply with the Lead and Copper Rule Improvements (LCRI), which lower the lead action level from 15 µg/L to 10 µg/L and add new sampling, inventory, and disclosure requirements. If your system issues a Consumer Confidence Report — and every community water system does — those changes show up directly in what you're required to report.

This page covers the operational impacts on your CCR: what the rule requires, how it differs from what came before, and what your report must say starting with the 2027 reporting cycle.

What LCRI is and why it replaced LCRR

The Lead and Copper Rule has been revised twice in quick succession. The original Lead and Copper Rule (LCR) dated to 1991 and set a 15 µg/L action level. The Lead and Copper Rule Revisions (LCRR), finalized in 2021, introduced the first mandatory service-line inventory requirement and set an October 16, 2024 deadline for initial inventories. The Lead and Copper Rule Improvements (LCRI) came next: finalized October 8, 2024, published in the Federal Register on October 30, 2024 (89 FR 86416, document ID 2024-23549), and effective December 30, 2024. Full compliance is required by November 1, 2027.

LCRI supersedes the LCRR entirely for systems that haven't yet hit the LCRR compliance gates. The practical effect is that your path forward runs through LCRI, not LCRR, for the requirements that matter most to your CCR.

The statutory chain: SDWA § 1412 (42 U.S.C. § 300g-1), the 1996 SDWA amendments, and the America's Water Infrastructure Act of 2018 (AWIA, Pub. L. 115-270) all feed authority into the rule. The CCR-specific disclosure requirements for lead sit at 40 CFR § 141.153(h)(8), within 40 CFR Part 141 Subpart I where the Lead and Copper Rule lives.

For a side-by-side comparison of all three versions of the rule, see LCR vs. LCRR vs. LCRI.

Before/after at a glance

| Requirement | LCR (original 1991) | LCRR (2021) | LCRI (effective Nov 1, 2027) | |---|---|---|---| | Lead action level | 15 µg/L (40 CFR § 141.80(c)(1)) | 15 µg/L (unchanged) | 10 µg/L (89 FR 86416) | | Sampling protocol at LSL sites | First-liter (1L) sample only | First-liter (1L) sample only | Paired 1st-and-5th-liter samples; use the higher value (89 FR 86416) | | Service-line replacement | Required only after action level exceedance; no system-wide mandate | Must replace 3% annually if AL exceeded; full inventory required by Oct 16, 2024 | 10-year mandatory full replacement schedule for all lead and GRR lines (89 FR 86416) | | Inventory categories | Lead / non-lead (two categories) | Lead / non-lead / lead status unknown / galvanized requiring replacement | Lead / galvanized requiring replacement (GRR) / non-lead / lead status unknown (four categories, same as LCRR, formalized in LCRI) (89 FR 86416) | | CCR disclosure language | Lead health effects boilerplate; source of lead statement if action level exceeded | Added: statement that service-line inventory has been prepared; instructions to access it | Updated statement of inventory, replacement plan reference, and new action level in any exceedance disclosure (40 CFR § 141.153(h)(8)) |

The lead MCLG has been zero since the original LCR and remains zero under LCRI — there is no safe level for lead exposure. The copper action level is 1.3 mg/L and is not changed by LCRI.

Lower action level: 10 µg/L

The LCRI lowers the lead action level to 0.010 mg/L (10 µg/L), down from 0.015 mg/L (15 µg/L) under the LCR (89 FR 86416). This is the threshold that triggers corrosion control treatment requirements, accelerated monitoring, and public notification when exceeded.

For your CCR, the consequence is specific. If your 90th percentile lead sample result is above 10 µg/L as of the 2027 reporting cycle, the report must disclose an action level exceedance and include the mandatory health-effects language under 40 CFR § 141.153(h). Systems that were under the 15 µg/L bar but above 10 µg/L will have a new exceedance to report that they didn't have before.

The action level is distinct from the MCLG. The MCLG for lead is zero — meaning EPA has determined no level of lead exposure is without risk. Because the MCLG is zero, there is no maximum contaminant level (MCL) for lead. The action level is a compliance threshold for corrosion control and replacement actions, not a safety guarantee. Your CCR's health-effects language must reflect this distinction: the boilerplate under 40 CFR § 141.154 says that lead can cause serious health problems, particularly in children, and that there is no safe level of lead in drinking water.

For more on how lead is reported in CCRs, see Lead and your CCR.

Paired first-and-fifth-liter sampling

Under the original LCR and the LCRR, systems took a first-draw (first-liter) sample at lead service line sites. Under LCRI, systems sampling at those sites must take paired 1st-and-5th-liter samples, analyze both for lead, and use the higher of the two values when determining compliance with the 10 µg/L action level (89 FR 86416).

The fifth liter is drawn after the first liter to capture lead that may be leaching from the service line further from the tap. In some systems, the fifth liter actually shows higher lead concentrations than the first. Using the higher value is the conservative approach that EPA is requiring — and it means that systems relying only on first-liter data to estimate compliance are now running an incomplete picture.

This is not just a monitoring change. It affects what you report. If the paired samples produce a higher 90th percentile result than your previous first-liter-only data, your CCR narrative and data tables need to reflect that updated figure. Systems moving into the LCRI sampling protocol in 2026 and 2027 should expect their monitoring data to shift before the compliance date.

Service-line inventory and the 10-year replacement schedule

The LCRR required systems to complete an initial service-line inventory by October 16, 2024 — that deadline has already passed. LCRI carries that inventory obligation forward and adds a mandatory replacement schedule: all lead service lines and galvanized requiring replacement (GRR) lines under a system's control must be replaced within 10 years of the November 1, 2027 compliance date, at an average annual replacement rate of 10% (89 FR 86416).

The four inventory categories LCRI formally defines are:

  1. Lead — confirmed lead service line
  2. Galvanized requiring replacement (GRR) — galvanized steel line that is, or was, downstream of a lead line or lead connector
  3. Non-lead — confirmed not lead, not GRR
  4. Lead status unknown — not yet confirmed in any category

Lines in the "lead status unknown" category are treated as lead for purposes of calculating the annual replacement obligation. That matters to your CCR: the disclosure required under 40 CFR § 141.153(h)(8) now includes both a reference to the inventory and a reference to the replacement plan if the system has one.

For detailed guidance on the inventory disclosure requirement, see Lead service line inventory disclosure.

What your CCR must disclose

The CCR lead disclosure rules are codified at 40 CFR § 141.153(h)(8). Under LCRI, your CCR must include:

Service-line inventory statement. Every CCR must include a statement confirming that a service-line inventory has been prepared and providing instructions for customers to access the publicly accessible version. If your system has zero lead, GRR, or unknown lines, your inventory is a written statement to that effect — and the CCR still needs to say the inventory exists and where to find it. (40 CFR § 141.153(h)(8)(ii))

Replacement plan reference. If your system has a replacement plan (required for any system with lead or GRR lines), the CCR must include a reference to it. (40 CFR § 141.153(h)(8)(iii))

Action level exceedance language. If your 90th percentile result exceeds 10 µg/L, the standard health-effects and exceedance language under 40 CFR § 141.153(h) applies. The action level referenced in that disclosure shifts from 15 µg/L to 10 µg/L starting with the 2027 reporting cycle.

Mandatory educational language. Regardless of whether your action level is exceeded, CCRs must include health-effects language for lead under 40 CFR § 141.154. This boilerplate covers sources of lead, health impacts (especially for children and pregnant women), steps consumers can take, and the zero MCLG.

The 2024 CCR Rule Revisions also added a mandatory summary section at the beginning of the CCR under 40 CFR § 141.156. This summary must include the most significant water quality information, which for systems with lead exceedances or active replacement programs means lead disclosure language will likely appear twice in the report — once in the summary, once in the body.

For the full landscape of changes coming in 2027, see What's changing in 2027 CCRs.

Timeline and milestones

| Date | Milestone | |---|---| | October 16, 2024 | LCRR initial service-line inventory deadline — already past. If your system hasn't completed this, it is overdue. | | December 30, 2024 | LCRI effective date (89 FR 86416 published October 30, 2024) | | July 1, 2025 | CFR codification date for the LCRI provisions that become enforceable November 1, 2027 | | January 1, 2027 | 2024 CCR Rule Revisions (biannual delivery, mandatory summary section) take full effect for the 2026 reporting year (40 CFR § 141.152(a)) | | November 1, 2027 | LCRI compliance date: 10 µg/L action level, paired sampling, and 10-year replacement program all take effect | | January 30, 2029 | First annual inventory update due under LCRI | | November 1, 2037 | Target date for full lead service line replacement (10 years from compliance) |

The two most commonly confused dates in this timeline are October 16, 2024 (LCRR inventory deadline) and November 1, 2027 (LCRI compliance date). They are different deadlines from different rules — conflating them leads to compliance errors in both directions.

What utilities should do now

Verify your inventory is complete and categorized. The October 16, 2024 deadline for the initial LCRR inventory is past. If your system hasn't completed or published the inventory, that gap needs to close before November 1, 2027. Under LCRI, the inventory is the foundation for calculating your replacement pool and for the CCR disclosure at 40 CFR § 141.153(h)(8)(ii). Every service line should be categorized as lead, GRR, non-lead, or lead status unknown.

Reduce your "unknown" count. Lines classified as lead status unknown count as lead for replacement calculation purposes. The fewer unknowns in your inventory, the smaller your mandatory replacement pool — and the lower the risk that your 2027 CCR discloses a large, potentially alarming replacement obligation. Field verification, permit records, and customer-side inspections all help reduce unknowns before the 2027 deadline.

Update your sampling plan for paired protocol. Under LCRI, sites with lead service lines require paired 1st-and-5th-liter samples. If your current sampling protocol only collects first-liter samples, that protocol will need to change before November 1, 2027. Running the paired protocol in 2026 gives you a pre-compliance data set that is directly comparable to your post-compliance results.

Prepare your CCR disclosure language now. The inventory statement, replacement plan reference, and (if applicable) action level exceedance disclosure language all need to be drafted before the 2027 reporting cycle opens. Using the 15 µg/L threshold in your 2027 CCR when the rule requires 10 µg/L is a compliance error — one that will show up in state primacy review. Draft the language against the corrected 10 µg/L action level and the 40 CFR § 141.153(h)(8) disclosure framework now.

Check your state primacy agency's implementation guidance. LCRI sets the federal floor. Primacy agencies may issue implementing guidance that affects how requirements are applied in your state, including inventory verification requirements, replacement plan formatting, and CCR review procedures. Check with your state drinking water program before the 2027 reporting cycle.

Last reviewed: 2026-05-03. Next scheduled review: every 3 months until Nov 1, 2027 compliance date.