European Drinking Water association (EDW), the Drinking Water Directive (DWD) and Article 10 rewrite, Construction Products Regulations in contact with Drinking Water (CPR) - European Sealing Association

ESA is a member of European Drinking Water industrial alliance (EDW); a group of industry associations 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 4^th 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 been 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.

The EDW group held the next plenary meeting on Tuesday 19^th December in Brussels, which Mark Neal attended.

A new DWD was issued 31.1.18.:

• 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 23.2.18.

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 (Rapporteur on the revision of the Drinking Water Directive), and Kalin Iliev and Ms. Slavitza Dobreva of the Bulgarian government who hold the European presidency and are hence in charge of the first response on DWD. ESA is committed to following the EDW plan and has agreed to help with the EDW advocacy plan. The EDW presentation will be given at the ESA AGM in May.

Meanwhile, ESA is currently reviewing the 4-member states test details to try to bring some sensible suggestions to the table on creating one single test that might satisfy all member states. This is against the background where rival tests in Germany are being promoted by ELL and UBA, and the German Federal Ministry of Health and Environmental Agency is demanding the “fullest harmonization possible”.

David Mitchell, Standards and Legislation Director

Read also other parts of the Standards and Legislation report:

• Waste Gas from Chemicals (WGC) BREF Update
• ESA government affairs committee