The cutoff point is related to the rate that the engine is revving, if you manually drop down the gears as ACC slows you down it will go pretty low before it gives you the warning beep and tells you to take over.
Isn't there two types of brake warning? I thought at speed you could get a 'tap' on the brakes to draw your attention, but that's not the same thing as the slow speed braking (city braking) where the car will do a full emergency stop if required.