Revised EU Drinking Water Directive explained: What industry professionals need to know

The recast EU Drinking Water Directive 2020/2184 has introduced a harmonized regulatory framework, establishing world-leading standards for water management across the supply chain.

On January 1, 2027, the Delegated and Implementing Acts under Article 11 of the Directive will take effect, defining the minimum hygiene requirements for products in contact with drinking water.

In light of the upcoming changes, we sat down with David Felecan, Molecular Biology and Neuroscience Postgraduate from the University of Vienna and Consultant at the Austrian Research Institute for Chemistry and Technology (OFI). We asked David to explain how the transition will be implemented and what the new requirements mean for water industry professionals — as well as for the general public.

The revised EU Drinking Water Directive entered into force in 2021, aiming to harmonize the different national requirements for materials and products in contact with drinking water. Why was the update necessary right now?

Currently, there are national regulations for each EU Member State. If a manufacturer wants to place a product on the market, they must ensure their product meets the respective national requirements, conduct all the necessary testing and obtain national certification. This is both an administrative and a financial burden, especially for manufacturers targeting multiple Member States.

Which of the changes introduced by the recast Directive are the most impactful?

The revised EU Drinking Water Directive introduces harmonized minimum hygienic requirements. These requirements ensure that the products in contact with drinking water do not negatively affect human health — directly or indirectly.

[They ensure that] microbial growth is not enhanced, that there is no leakage of contaminants into the water above specified thresholds and that the sensory qualities of the water — its odor, color and taste — are not affected.

From January 1, 2027, the harmonized requirements will apply for all such products sold in the EU markets. However, there will be a transition period until the end of 2032. Can you explain how the transition period works, and why it was introduced?

The transition period is defined in the Delegated Regulation (EU) 2024/370, and its goal is to give manufacturers time to switch from the national conformity certificates to EU certification.

The certification process is time consuming, and without a transition period, it would not be possible to ensure that all products currently on the market are tested and certified by January 1, 2027.

Not all manufacturers know yet whether their products will meet the requirements of the revised Directive. They have to conduct testing, and they may need time for product optimization.

How will the new framework affect manufacturers of products in contact with drinking water? How can they stay compliant and support their customers in the transition process?

After January 1, 2027, manufacturers must ensure that their products have an EU certificate issued by a notified body. Based on this, they can label their product with the conformity mark and take full responsibility for compliance. The transition period will only apply to products that already have a national conformity certificate. And the national conformity certificates will remain valid only within the respective Member State in which they were issued.

For every new product placed on the market after January 1, 2027, the manufacturer must ensure that the product carries an EU declaration of conformity and is labeled accordingly. If neither a national conformity certificate, nor an EU declaration exists, the product may not be sold on the EU market.

What do these changes mean for other stakeholders? What changes should property developers, contractors and plumbers prepare for after January 2027?

They should be aware that not all products will remain on the market after January 1, 2027. They should verify that the products they intend to use have either a national conformity certificate or an EU declaration of conformity based on an EU certificate issued by a notified body.

After the transition period ends, who will be responsible if the drinking water in a building is found not to meet the new requirements?

Here, Article 11 of the new Drinking Water Directive applies. The products on the EU market will be controlled by market surveillance authorities. However, these requirements apply only to new installations, the existing ones will not be affected.

As the new requirements mainly target future projects, what about the current safety and quality of drinking water in Europe and the products already on the market? Should consumers be concerned?

I can only speak for Austria or Germany as I'm not accustomed to the national regulations in other Member States. But both Austria and Germany require thorough testing, and the requirements are strict. These regulations do ensure that the quality of the drinking water is not impacted by the materials and products used for its distribution or storage.

Earlier this year, OFI became the first accredited conformity assessment body in Europe to carry out testing, inspections and certifications in accordance with Delegated Regulation (EU) 2024/370. What were the biggest challenges in preparing for accreditation under this new framework?

We had the advantage of already having obtained extensive experience in testing, auditing and certification of products in contact with drinking water under the German regulation, the KTW certification. These certification procedures are very similar to those in the recast Directive.

Of course, familiarizing ourselves with the differences in classification was a bit of a challenge — as was incorporating some of the new testing procedures.

What are the main changes introduced in the material testing process?

There are new EU positive lists that have been instated with updated threshold values and material values, as well as new testing methods, such as screening for non-intentionally added substances or the migration test in chlorinated water.

However, the [fundamental] principles of formulation, testing and analysis remain the same as before. A key addition — for manufacturers currently not certified under the Austrian regulation — is the parameter of flavor. It will now be tested under the new Directive.

What advantages does OFI’s early accreditation bring to manufacturers and other industry stakeholders in Austria?

OFI already offers manufacturers the opportunity to submit applications under the new Drinking Water Directive and start testing. We can provide support throughout the entire procedure, covering testing, auditing and certification.

The EU certificate itself cannot be issued before January 1, 2027, but the entire process from testing to auditing can be completed beforehand.

For other laboratories and testing bodies across Europe seeking accreditation as a national conformity assessment body — what opportunities and challenges do you see for them?

By definition, a conformity assessment body must be able to perform all the required procedures, namely testing, auditing and certification.

At OFI, we have the advantage of being able to carry out all these procedures within one facility. For other testing laboratories, this presents an opportunity and a challenge — to find partners to cooperate with to meet all the requirements for a conformity assessment body.

Europe’s water industry is clearly set to undergo a major transformation, and the process will take time. Looking ahead a few years, what would a successful implementation of the recast Directive look like to you — and what positive impacts do you expect it will have?

The revised Directive will benefit manufacturers as the certification process will become unified — the EU certificate will be valid across the entire bloc. The [administrative and financial] burden on manufacturers targeting multiple Member States will be drastically reduced.

The new Directive will also ensure the safety and quality of products in contact with drinking water throughout the whole EU. Currently, some Member States may not have such stringent regulations; this harmonization will lead to improvement.

Drinking water is our most precious resource. We have a moral obligation to ensure it is safe for consumption — and that the products in contact with the drinking water do not impede this safety.