European Drinking Water Association (EDW), the Drinking Water Directive (DWD) and Article 10 Rewrite, Construction Products Regulations in Contact with Drinking Water (CPR)
ESA is a member of European Drinking Water industrial alliance (EDW); a group of industry associations (like Europump) who have agreed to act together to assist in the finalisation of the test procedures for materials and products used with potable water.
The meeting, held on 4th October 2017 in Brussels, has ruled that the DWD cannot be used to generate a single European wide test for materials and assemblies in contact with drinking water. This is because it contravenes Article 193, which allows member states to add their own more stringent requirements to any European test. It has therefore suggested that Construction Products Regulation (CPR) is the only route to follow.
This clearly is directly opposite to EDW members views and causes a serious issue for the progress on a single test.
A new DWD was issued 31. 1. 2018:
- Article 10 of EC98/83 deleted, and implied “mutual recognition” removed. Only 20 years after the original plan was set out!
- New standardisation mandate to be issued under CPR, which will set requirements for construction materials and products in contact with drinking water.
- Use Harmonised European standards (hEN) and Horizontal assessment methods in European Standards (EN).
- Some existing tests to be included in new requirements.
Targets for revised harmonised test are now set for mid-2019. The EC Expert group met on 23. 2. 2018. This meant a position paper was issued, and EDW has set out a plan of action, with a presentation attached, showing their preferred way forward:
- CPR tests do NOT cover many items used for water, including Pumps, Filters, and Gaskets, and therefore is not an appropriate way forward.
- The CE mark proposed is not relevant to drinking water as it does not confirm “non- contamination” and EDW propose a “Water Drop” marking system instead.
- EDW proposes test similar to 4MS with “mutuality” across Europe for this one single test.
- Their main point is that testing as it stands is too expensive, and the right of each member state to add its own requirements is against the spirit of WHO initiative.
EDW has been very active in meeting with Michel Dantin (MEP and rapporteur on the revision of the Drinking Water Directive), and ESA is committed to following the EDW plan and has agreed to help with the EDW advocacy plan.
EDW supports whole-heartedly the concept of one single harmonised test procedure to be used throughout Europe. They also support the concept of approved substances (organic materials, elastomers, cement, metals) lists, and the adding of hygienic requirements (e.g. microbiological growth and organoleptic characteristics). EDW also insists there is a link between the Drinking Water Directive and other product legislation.
The European Parliament ENVI committee published a report on the Drinking Water Directive questioning the new approach and offering a much more sensible approach. This report and approach were adopted by the European Parliament on 27th March 2019.
- Press Release on the European Parliament Plenary Vote on the Recast of the Drinking Water Directive
The signs are now much more positive that the same high hygienic standards and a single harmonised test will be adopted. The current position is that negotiations between the European Parliament and the EU Council are taking place which will lead to a final new version of DWD to be issued before the end of 2019.
It is anticipated that by March/April 2020 the final agreed legislation will be issued. The EDW group held the latest plenary meeting on 11th April 2019 in Brussels.
David Mitchell, Standards and Legislation Director
Read also other parts of the Standards and Legislation report: