Drinking water contact approval in the EU and UK

The rules for what may touch drinking water in Europe are being replaced. Twenty-seven national approval regimes are giving way to European Positive Lists under Article 11 of the recast Drinking Water Directive, with the changeover starting on 31 December 2026. If you are specifying a potable water container for the EU now, you are buying across that boundary.

What Article 11 does

Directive (EU) 2020/2184 sets minimum hygiene requirements for materials that come into contact with water intended for human consumption. It requires the Commission to establish European Positive Lists: reference lists of the substances, compositions and constituents considered safe for drinking water contact.

Getting onto a list runs through a risk assessment of migration into the water under the worst foreseeable conditions of use and an opinion from ECHA’s Risk Assessment Committee. The finished material is then tested for taste, odour and microbial growth.

Check the scope before you pay for either route. Article 11 is written for installations: the pipes, fittings and storage that carry water through buildings and supply networks. Water drawn from the tap counts as food under EU food law, so a portable container may be assessed under the food-contact rules instead. Ask the buyer which regime its market applies to the container.

That testing explains why a food-contact file does not transfer. Migration is measured after conditioning that simulates the worst realistic case rather than an average one. Taste and odour are assessed by a sensory method against a control water. The material is also tested for whether it encourages microbial growth, an endpoint with no analogue in food-contact work. A surface that leaches a trace of organic carbon feeds a biofilm in a pipe over months, and that is a drinking-water failure with no food equivalent.

The system also separates the material from the product, which is where a lot of confusion starts. A positive list is a list of substances, compositions and constituents, so what gets assessed is what the wetted surface is made of. Whether a finished container is acceptable then depends on that material assessment plus how the product is built and used. Asking a supplier whether "the can is approved" often gets a truthful answer about the material and an unhelpful one about the product.

The dates that matter

Until 31 December 2026, national approvals still do the work: the German UBA schemes, the French ACS, the Dutch KIWA route and the others. That is the practical position today, and it is why a supplier can hold approval in one member state and not be accepted in another.

The national schemes share some groundwork, which softens the problem. Germany, France, the Netherlands and, before it left, the United Kingdom ran a joint acceptance initiative that aligned test methods and produced common material lists. The European Positive Lists build on that groundwork. A supplier already assessed under one of those schemes is closer to the new system than one holding nothing. That is a reason to pursue a national approval now instead of waiting for 2027.

For metals, the German route is the most developed. The German Environment Agency maintains a positive list of metallic materials hygienically suitable for drinking-water contact. Austenitic stainless steels are accepted for drinking-water use in Germany, so the material choice on a stainless water can keeps the approval route open. The list attaches to the alloy, so the mill certificate is the document that matters.

What this means by material

• Stainless steel. Austenitic grades are the established choice for potable contact because there is no liner or coating in the wetted path to fail, and the composition itself is what gets assessed. Ask for the grade and the mill certificate, because the assessment attaches to the alloy rather than to a brand name.
• Plastics. Both the polymer and its additives are in scope, so a food-contact declaration under the plastics regulation is not by itself a drinking-water approval. They are separate regimes answering different questions.
• Coated steel. The coating is the contact material, so the approval question lands on the coating system rather than on the steel underneath it.

The UK is a separate answer

Great Britain did not follow the recast directive. In England and Wales, products in contact with public drinking water supplies go through Regulation 31 approval administered by the Drinking Water Inspectorate, with WRAS approval widely used as the route for fittings. So an EU positive-list position does not carry into the UK and a UK approval does not carry into the EU.

Plan the sequence rather than running both at once. The UK route is stable today and the EU one is mid-transition, so a supplier serving both usually starts where the requirement is fixed and adds the second as the European lists finalise. Starting both against a design that is still moving pays for two assessments of something that then changes, which is the same trap that catches UN and AS/NZS testing run in parallel too early.

Food contact is not drinking water contact

Confusing the two is the most common specification error in this category. A container can hold a valid food-contact declaration under the EU framework regulation and the plastics regulation and still not be approved for potable water. Drinking water contact is assessed against different endpoints: long contact times, low-nutrient water, and effects on taste, odour and microbiology. Ask which of the two you are being sold, and for what market.

The tell is the document. A declaration of compliance names a food-contact regulation; a drinking-water approval names a national scheme or a positive-list position. If the paperwork offered names a food regulation and the question was about potable water, the question has not been answered, whatever the covering email says.

Where we stand on this

Our stainless water line is AISI 304 across the wetted path with no liner or coating, the right material choice for potable use. We supply the mill certificate for the grade. National drinking-water approvals are not held on the standard range today. They are obtainable per product and per market, and we scope them as part of a programme.

The material is the reason that route is open. An approval assessment attaches to what touches the water, and an uncoated austenitic stainless wetted path is a single, declarable material with no liner or coating system to assess alongside it. That is a considerably shorter file than a coated steel or multi-additive plastic container presents.

How we handle it in practice:

• Private, emergency and field water storage. The grade and the mill certificate are normally what a buyer needs. This ships now.
• Contact with a public supply, or a market where a national approval is the entry ticket. Name the member state at enquiry and we will come back with the applicable route, what it costs and how long it takes. If your timeline is shorter than that route, we will say so rather than let you find out late.
• Across the 2027 transition. Specify the material and hold the mill certificate now. The European Positive Lists assess substances and compositions, so a documented single-material wetted path is the right position to be holding when national approvals give way to the EU system.

Where to start

Common questions

What approval does a drinking water container need in the EU?

Article 11 of Directive (EU) 2020/2184 sets minimum hygiene requirements for materials in contact with water intended for human consumption, backed by European Positive Lists of permitted substances. Until 31 December 2026, national approvals such as the German UBA schemes, French ACS and Dutch KIWA carry the market, and certificates valid on that date run to 31 December 2032.

When do the European Positive Lists take effect?

The lists were adopted in January 2024 and apply from 31 December 2026. A product holding a valid national certificate on that date may stay on the market under it until 31 December 2032. A container specified for the EU now is being bought across that boundary.

Is a food-contact declaration the same as drinking water approval?

No, and it is the most common specification error in this category. Drinking water contact is assessed against different endpoints: long contact times, low-nutrient water, and effects on taste, odour and microbiological balance. A valid food-contact declaration does not answer the water question.

Does an EU drinking water approval work in the UK?

No. Great Britain did not follow the recast directive. In England and Wales, products contacting public drinking water supplies go through Regulation 31 approval administered by the Drinking Water Inspectorate, with WRAS widely used for fittings.

Does stainless steel need a coating for drinking water?

No, and that is its advantage. Austenitic stainless resists corrosion through its own passive layer, so there is no liner or coating in the wetted path to fail or to require separate assessment. The evaluation attaches to the alloy composition, so ask for the grade and the mill certificate.

References

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

• Directive (EU) 2020/2184: quality of water intended for human consumption
• European Commission: materials in contact with drinking water
• ECHA: Risk Assessment Committee
• Drinking Water Inspectorate: Regulation 31 approvals (England and Wales)
• WRAS: Water Regulations Approval Scheme approvals
• NSF/ANSI/CAN 61: drinking water system components

First published 12 August 2026

Last reviewed 26 October 2026 by Clarence Cheang, Co-Founder & COO. How we review our guides Fortitude21 makes and sells liquid containers; our guides carry no affiliate links.