The EU Drinking Water Directive (Directive (EU) 2020/2184), which entered into force in January 2021, introduces for the first time EU-wide harmonized minimum hygiene requirements for materials and products in contact with drinking water. For the specific requirements, the EU Commission has to publish several legal acts with supplementary regulations by January 2024.
Industry position on conformity assessment
One of these legal acts will regulate the future conformity assessment procedure for products in contact with drinking water. A draft of this legal act is not yet publicly available. However, European Drinking Water has already published a position paper with an explanatory scheme at this stage, after an intensive and lengthy coordination process, and submitted it to the EU Commission.
Based on experiences already made at national level, a pragmatic process is described, which is supported as a compromise by the entire value chain involved. The position paper focuses on plastics and other organic materials, proposing regulations that are proportionate to the potential impact on drinking water quality, particularly for products with a smaller surface in contact with drinking water such as sanitary taps.
This paper must be considered as a general compromise from the industry. The members of the EDW Alliance support the content of the paper, but the approaches set out in the document shall be considered applicable only for the specific topic in the scope of this paper. While the proposal set in the document is deemed as the best option by the Alliance, this shall not be interpreted as the EDW Alliance's members support this approach also on other product regulations. Each regulation and related verification procedures must be addressed in a case-by-case approach.
UBA study supports industry position
At the same time as the position paper was published, the German Environment Agency released the final report of a study on the migration of substances from injection-molded components in contact with drinking water produced by different companies. The study was initiated by the EDW member association figawa and significantly supported by its member companies.
The results fully support the regulations described in the position paper. For example, the study concludes that the testing and evaluation of specifically manufactured test panels, and thus the certification of preliminary products (granules), appears to be a suitable way to reduce the testing effort for components manufactured at different locations.
A prerequisite for this, however, would be that the process parameters of injection molding are monitored and taken into account in the certification of the components. For certain components or products, a certificate for the preliminary product (granules) could thus be sufficient to demonstrate hygienic suitability with regard to the release of substances into drinking water.