EU Drinking Water Directive
The European Union’s new Drinking Water Directive (EU) 2020/2184 introduces significant changes to ensuring the safety of drinking water. At the same time, its impacts extend much further than might initially be expected.
What is new in the EU Drinking Water Directive?
One of the most significant reforms is the introduction of a harmonised EU-wide approval system for materials that come into contact with drinking water (Article 11).
The directive aims to facilitate the functioning of the EU internal market, while at the same time requiring materials to meet stricter safety criteria than before. Approved materials will be included in an EU positive list, the first version of which will be based on existing national positive lists and regulations. Economic operators, including manufacturers of materials in contact with drinking water, can apply to have new starting substances, compositions or constituents added to the list.
Competent authorities in Member States may apply to ECHA to remove or modify existing materials. Changes to the positive list – additions, updates or removals – are processed through delegated or implementing acts of the European Commission in cooperation with ECHA’s Risk Assessment Committee (RAC).
The EU positive list is published on ECHA’s website. Materials are divided into four categories: organic, metallic, cementitious, and enamel as well as ceramic and other inorganic materials.
Key steps and dates in the EU Drinking Water Directive
The Notice of Intention (NoI) is a mandatory step before submitting a full application. Its purpose is to ensure transparency and improve the efficiency of the approval process. It also seeks to promote joint applications and reduce the need for animal testing. Submission of Notices of Intention began on 31 December 2025.
The full application has significantly more extensive data requirements than the NoI. The application must include, for example, material identification data, chemical and physical properties, analytical data, migration levels of substances released into water, absorption and toxicological data, intended use and a risk assessment. Submission of applications will begin on 31 December 2026.
Both the Notice of Intention and the full application documentation must be prepared in ECHA’s IUCLID system.
Materials on the positive list have an expiry date. To remain on the list, an application must be submitted before the expiry date. ECHA recommends submitting the application at least 18 months before expiry. There are four different expiry timelines, with the first expiring at the end of 2028 (31 December 2028). This means that, according to regulatory guidance, the first applications should be submitted in summer 2027.
The expiry dates are based on risk assessment: the higher the hazard profile, the earlier the approval expires. Approval will expire at the end of 2028 for some constituents of organic and cementitious materials, such as cellulose and lignocellulose.
It is important to start preparing application documentation without delay, especially for materials with expiry dates at the end of 2028.
Sweco supports your company throughout the entire process – from assessing material compliance and preparing Notice of Intention and application documentation in IUCLID, to conducting drinking water risk assessments using the Water Safety Plan (WSP) approach.
Get in touch — we’re happy to guide you through the entire EU Drinking Water Directive process.
Saila Kivijärvi, Food Safety Specialist, saila.kivijarvi@sweco.fi