On 12th September 2017, EDW has participated in the first meeting of the newly established 4MS task group “Minor and Assembled Product Testing”. In lack of a European regulatory framework, four member states (4MS): Germany, France, the Netherlands and the United Kingdom, have agreed to work towards harmonizing tests for the hygienic suitability of products in contact with drinking-water.
The objective of the 4MS task group is to draft a proposal for the 4MS Common Approach on how to assess minor and assembled products for hygienic fitness for drinking water contact. The scope only includes hygienic assessment (migration, microbiological and organoleptic requirements), performance related mechanical assessment is excluded.
EDW is pleased to join the 4MS task group, because better policy and regulation for products in contact with drinking water - regardless whether at European, national or 4MS level – requires that technical requirements are prepared in full knowledge of their expected impact to maximize benefits for consumers and to avoid unnecessary, non-value adding burdens to industry. EDW member associations have substantial experience with national drinking water approval schemes throughout Europe, and are therefore able to bring a new angle to the discussions from the perspective of market actors on which technical rules are imposed.
In preparation for the meeting, in February 2017, EDW established a working group focusing on assembled products (Products WG). Experts of around 20 industry associations are represented in the working group with extensive experience in numerous drinking water approval schemes and food contact legislation in Europe, North America, Far East and Australia.
During the first half of 2017 the working group has systematically reviewed and compared the main approval schemes within the EU, and based on current practices and following guidance form the Commission’s “Blue Guide” on implementation of EU product rules, it started to outline the principles of a drinking water approval scheme that would safeguard the quality of drinking water and would represent best practice across Europe. EDW follows the principles of proportionality and therefore is in favor of an impact based assessment scheme both when it comes to type testing and production control.
Assembled products make up a large part of products that come into contact with drinking water, and the Products WG members represent the whole range of assembled products - product which comprise of only a few materials and products which comprise of 30+ different materials. Due to the very different construction and complexity of the various product types, it is hard to find a one size fits all solution, but through fostering collaborative discussions for several months, the EDW’s Products WG was able to come to a consensus and conceptualize two alternative mechanisms for demonstrating compliance - one is based on components and the other one is based on the assembled product –, which can cover the complete drinking water product range, and which was shared with the 4MS task group on “Minor and Assembled Product Testing”.
The first meeting of the 4MS task group centered around sharing and discussing different practices and approaches to hygienic product assessment, and moving towards conceptualizing an impact based evaluation procedure, where the assessment burden is proportionally reduced for products which have a lower impact on water quality (see documents below). The meeting was characterized by openness and strong willingness to find a common solution and adopt another member states’ or the industry’s approach when it proves to be more pragmatic and still safeguards the quality of drinking water.
The next meeting of the 4MS task group will be late November, and the ambition of the meeting is to finalize the impact-based evaluation procedure and to draft a Common Approach proposal for the assessment of assembled and minor products that can be presented to the 4MS Group Joint Management Committee.
