The European Drinking Water Directive (DWD) mandates that starting substances, compositions, or constituents used in materials that come into contact with drinking water—from the source to the tap—must be listed on one of four European positive lists. Once water exits the tap, materials that interact with it fall under food safety regulations.

European Positive Lists for Drinking Water Materials

The European Commission has established positive lists for four categories of materials in contact with drinking water:

  • Organic materials
  • Metallic materials
  • Cementitious materials
  • Enamel, ceramic, or other inorganic materials

These lists are based on national positive lists submitted by EU Member States to ECHA in July 2021. The positive list for organic materials incorporates the plastic food contact materials list from Annex I of Commission Regulation (EU) No 10/2011.

ECHA will publish these lists in a searchable format, though the Commission’s implementing decision remains the official source.

Key Features of the European Positive Lists

Unique Identification (EUPL Number) Each entry on the lists is assigned a unique 4-digit European Positive List (EUPL) number. If a chemical appears on multiple lists (e.g., as an organic material starting substance and an organic constituent in cementitious materials), it receives separate EUPL numbers.

Expiry Dates

Every entry has an expiry date, marking the end of its permitted use in manufacturing drinking water contact materials. The first European positive lists include four possible expiry dates:

  • 31 December 2028
  • 31 December 2031
  • 31 December 2034
  • 31 December 2037

The European Commission sets these dates based on ECHA’s recommendations, considering factors such as substance hazards, risk assessment status, and priority concerns (e.g., PFAS).

Usage Conditions and Concentration Limits Each listed substance may have specific conditions for its use. Additionally, Maximum Tolerable Concentrations at the tap (MTCtap) may be established for certain substances or their reaction products.

Reviewing and Updating the Positive Lists

Economic operators wishing to maintain a substance on the list must submit a review application to ECHA before its expiry date. ECHA’s Committee for Risk Assessment (RAC) will evaluate these applications, and the European Commission will decide whether to retain, amend, or remove the substance from the lists. Entries without a review application will be automatically removed.

New substances can be added to the lists through applications from economic operators, while Member States may propose removals or updates based on new data. RAC will assess these proposals before the Commission makes a final decision.

Implementation Timeline

  • The first European positive lists take effect on 31 December 2026. Until then, national positive lists and other national provisions remain in force.
  • Substances approved by Member States between 13 July 2021 and 31 December 2026 may continue to be used in manufacturing drinking water contact materials until 31 December 2032.

These updates aim to harmonise regulations, enhance safety, and ensure high-quality drinking water standards across the EU.

Source: European positive lists, ECHA.

Sandy Van den Broeck
ESG Director, ESA