The European Union’s new Drinking Water Directive (EU) 2020/2184 (DWD for short) outlines harmonized minimum quality criteria for water intended for human consumption. The directive has direct implications for water suppliers as well as manufacturers and importers of materials that come into contact with water.
This article answers some of the most frequently asked questions about the practical implications of the new DWD for companies, with a focus on testing-related requirements.
Table of contents
What are the quality criteria for drinking water under the new DWD?
To be acceptable under the new Drinking Water Directive, water for human consumption must comply with the parametric values specified in its Annex I. These cover microbiological quality, harmful chemicals, and general indicator parameters for water quality.1
Examples of chemical parameters and their maximum concentrations in drinking water include:
Heavy metals, including arsenic (10 µg/l), cadmium (5 µg/l), mercury (1 µg/l), and lead (10 μg/l until 12 Jan 2036, 5 µg/l after)
Bisphenol A (2.5 µg/l)
Polycyclic aromatic hydrocarbons (PAH, 0.1 µg/l for the sum of benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(ghi)perylene, and indeno(1,2,3-cd)pyrene)
Per- and polyfluoroalkyl substances (PFAS, 0.5 µg/l for total, 0.1 µg/l for the sum of selected compounds)
Pesticides (0.1 µg/l for individual compounds, 0.5 µg/l for their sum)
Residual monomers acrylamide (0.1 µg/l) and vinyl chloride (0.5 µg/l)
What are the general requirements for materials in contact with water?
Under the revised Drinking Water Directive, materials in contact with water must not have detrimental effects on human health, adversely affect the taste, color, or smell of water, lead to increased microbial growth, or release significant quantities of contaminants into water. These principles are very similar to those that underpin EU food contact material legislation, as specified in the Framework Regulation (EC) No 1935/2004.2
How is compliance with DWD requirements evaluated?
On a more practical level, materials in contact with water must be composed of starting substances included in European positive lists, and they must comply with specific migration limits set for certain substances. Testing may also be required to measure the release of unexpected substances and to assess the material’s impact on water quality parameters such as odor and flavor, color and turbidity, enhancement of microbial growth, and leaching of total organic carbon (TOC).
How does material type affect testing requirements?
Materials in contact with water are divided into four categories under the new Drinking Water Directive: organic, metallic, cementitious, and enamels/ceramic materials. Positive lists are established separately for each type of raw material.3
Testing requirements also vary. They are stricter for organic materials and cementitious materials with organic constituents, as these have a higher risk of releasing substances into water than more inert metallic and ceramic materials.
Table 1. Testing requirements for materials that come into contact with drinking water according to Directive (EU) 2020/21844
Quality parameter | Testing standards | Organic materials | Metallic materials | Cementitious materials | Enamels and ceramic materials |
Odor and flavor | EN 1420, EN 1622 | ✓ | ✓ | ||
Color and turbidity | EN ISO 7887, EN ISO 7027 | ✓ | ✓ | ||
Leaching of total organic carbon | EN 1484 | ✓ | ✓** | ||
Surface residues | EN 16057, EN 16058 | ✓ | |||
MTC(tap)* of positive list substances | EN 12873-1, EN 12873-2 | ✓ | ✓** | ||
Unexpected substances (GC-MS)*** | EN 15768 | ✓ | ✓** | ||
Compliance with composition lists | - | ✓ | ✓ | ✓ | ✓ |
Enhancement of microbial growth | EN 16421 | ✓ | ✓** |
* MTC(tap) = maximum tolerable concentration at the tap
** If the material contains organic ingredients
When will materials in contact with drinking water have to comply with the new DWD?
The European positive lists and associated testing requirements for materials in contact with water will apply from 31 December 2026. Until then, materials are assessed in accordance with established national laws and standards.
A transitional period until 31 December 2032 will apply to starting substances approved by national authorities before the application date of the positive lists.5 This will give companies time to find alternatives to substances that were previously authorized under national laws but are not included on DWD positive lists.
What if a substance is not on the positive list?
After the transitional period expires, substances not included in a European positive list can only be used to produce contact materials if there is no possibility of migration into water at levels above 0.1 μg/l. Substances may also be added to positive lists, but only after an extensive risk assessment and approval from the European Chemicals Agency’s (ECHA) Committee for Risk Assessment (RAC).6
What is the watch list of substances of concern?
The revised Drinking Water Directive obligates Member States to monitor the concentrations of substances included on a European Commission watch list of substances of concern. The Commission plans to update this dynamic watch list periodically, but as of October 2025, the list still contains just the two substances originally added in 2022: 17-beta-estradiol and nonylphenol.7
What does the Drinking Water Directive say about microplastics?
The Commission intends to add microplastics to the DWD watch list of substances of concern due to the potential health risks they may cause.8 Once this happens, a guidance value for microplastics will be established, and water suppliers will need to monitor concentrations and implement mitigation measures if the guidance value is exceeded. A methodology for measuring microplastics in drinking water has already been established by a Delegated Decision.9
The addition of microplastics onto the DWD watch list may also impact manufacturers of plastic materials that come into contact with water, as microplastics can originate from the wear and tear of such materials.
What are the DWD rules for PFAS?
The revised Drinking Water Directive sets the following limits on the maximum acceptable concentration of PFAS compounds in drinking water:
0.5 µg/l for “PFAS Total”, meaning the totality of per- and polyfluoroalkyl substances.
0.1 µg/l for “Sum of PFAS”, meaning the sum of 20 compounds listed in Annex III to the DWD.10
The restriction is relevant for water suppliers as well as contact material operators that use fluorinated chemicals during the production process.11
How should PFAS be measured for Drinking Water Directive compliance?
The recommended methods for measuring the “Sum of PFAS” parameter for DWD compliance are Parts A and B of standard EN 17892, which have been validated for all the listed compounds. Equivalent standard methods can be used if they meet performance requirements, for example, regarding the limit of quantification (LOQ). “PFAS Total” is measured using proxy methods, such as TOP assays, EOF-CIC (extraction of fluorine followed by combustion ion chromatography), or non-targeted LC-HRMS analysis.12
One partner for all your Drinking Water Directive-related testing needs
Measurlabs provides a wide range of analyses to support companies with EU DWD compliance. Some of the highlights from our service scope include:
Release of unexpected substances according to EN 15768
PAH testing of water
TOC testing according to EN 1484
Bisphenol A content and migration testing
Do not hesitate to contact us using the form below for more information or a quote.
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References:
1 Part A of Annex I to Directive (EU) 2020/2184 specifies microbiological parameters, Part B chemical parameters, and Part C other indicator parameters. Part D specifies additional parameters for the risk assessment of domestic water distribution systems.
2 The minimum hygiene requirements for materials in contact with water are outlined in Article 11 of Directive (EU) 2020/2184. For a comparison, see Article 3 of Regulation (EC) No 1935/2004 on food contact materials.
3 DWD positive lists for starting substances were established by Commission Implementing Decision (EU) 2024/367. They are listed in Annexes I (organic materials), II (metallic materials), III (organic constituents of cementitious materials), and IV (enamels, ceramic, and other inorganic materials).
4 Test methods are outlined in Commission Implementing Decision (EU) 2024/368.
5 The timeline is established in Articles 3 and 4 of Commission Implementing Decision (EU) 2024/367.
6 More information on positive lists is available on the ECHA website.
7 The watchlist is established by Commission Implementing Decision (EU) 2022/679, with substances of concern listed in the Annex.
8 The plan to add microplastics to the watch list is outlined in Article 13(8) of Directive (EU) 2020/2184.
9 Commission Delegated Decision (EU) 2024/1441 outlines the methodology to measure microplastics in drinking water.
10 The substances falling under the “sum of PFAS” parameter are listed in point 3 of Part B of Annex III to Directive (EU) 2020/2184.
11 In Annex I to Commission Implementing Decision (EU) 2024/367, group restriction (38) corresponds to “PFAS Total” and group restriction (39) to “Sum of PFAS”.
12 Commission Notice C/2024/4910 provides the technical guidelines for PFAS analysis, including recommended analysis methods.