From 31 December 2026, products in contact with water intended for human consumption will need a European conformity certificate to be placed on the EU market. The requirement comes from a set of Commission acts adopted in January 2024, which replace the different national approval systems with a single, harmonized framework. With less than three months to go, manufacturers of pipes, fittings, tanks, seals and coatings should be planning their conformity assessment now.

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The Legal Basis

The framework comes from Article 11 of the recast Drinking Water Directive (EU) 2020/2184, which sets minimum hygiene requirements for materials in contact with drinking water. In January 2024, the European Commission adopted six acts that put these requirements into practice. They fall into two groups.

For final materials, products, components and assembled products:

Implementing Decision (EU) 2024/368 sets the testing procedures and acceptance criteria for final materials.
Delegated Regulation (EU) 2024/370 sets the conformity assessment procedures for products.
Delegated Regulation (EU) 2024/371 establishes harmonized marking for these products.

For starting substances, compositions and constituents:

Implementing Decision (EU) 2024/367 establishes the European positive lists of substances that may be used.
Delegated Regulation (EU) 2024/369 sets the procedure for adding substances to or removing them from those lists.
Implementing Decision (EU) 2024/365 sets the methodologies for testing and accepting substances for inclusion.

The scope covers products used in new installations or in repair and renovation work on existing installations, for the abstraction, treatment, storage or distribution of drinking water. This includes pipes, fittings, valves, tanks, seals, coatings and similar items. A product intended for other uses as well still needs certification if it will be in contact with drinking water.

A European Certificate from 31 December 2026

From December 31^st, all products within the scope of Regulation 2024/370 placed on the EU market must hold a European conformity assessment certificate. The certificate confirms that the product meets the minimum hygiene requirements of Decision 2024/368, and that it is made only from starting substances included in the positive lists of Decision 2024/367.

Key points of the new system:

The certificate is issued by a notified conformity assessment body and is valid for five years.
Manufacturers can apply to a notified body in any EU Member State, and the certificate is recognized across the EU. The list of notified bodies is published on the Commission’s Single Market Compliance Space.
After certification, the manufacturer or authorized representative draws up a declaration of conformity in the language(s) required by each Member State where the product is sold.
Certified products must carry the marking set out in Regulation 2024/371.

Transition Period until 31 December 2032

For products that comply with national hygiene requirements and hold a national conformity certificate that is still valid on 31 December 2026, the Regulation applies from 31 December 2032. During this period, a product may hold either a national certificate or a European one.

A manufacturer with a valid national certificate can apply for the European certificate at any time. Once the European certificate is issued, the national one automatically ceases to be valid.

After 31 December 2032, only the harmonized European system will apply.

Positive Lists and Starting Substances

Only substances on the positive lists of Decision 2024/367 can be used to make products that will be assessed for the European certificate. The lists cover organic materials, metallic materials, organic constituents of cementitious materials and enamels, ceramics and other inorganic materials. Products made from substances outside the lists cannot be assessed under the new system and therefore cannot obtain the European certificate.

Producers who want a substance added to the lists apply directly to the European Chemicals Agency (ECHA), following the procedure of Regulation 2024/369.

Under Article 3 of Decision 2024/367, substances approved by a national authority between 13 July 2021 and 31 December 2026 may be used until 31 December 2032, provided they comply with the lead limit of 5 μg/l at the tap, set in Part B of Annex I of Directive 2020/2184.

Conclusion

Manufacturers have limited time to prepare. In practice, this means checking whether each product falls within scope, confirming that all starting substances appear on the positive lists, reviewing the expiry dates of existing national certificates and contacting a notified body early, since demand is likely to increase as 2026 ends.

For manufacturers of pipes, fittings, tanks, gaskets and coatings, the shift from national approvals to a single EU certificate removes the need for separate approvals in each market. It also means that all products in scope will be assessed against the same testing methods and acceptance criteria across the EU from 2033 onwards.