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 running from 1 January 2027. 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, and 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 is not a paperwork exercise. It runs through risk assessment covering migration into the water under the most unfavourable conditions of use, conformity testing including effects on taste, odour and the microbiological balance of the water, and an opinion from ECHA’s Risk Assessment Committee.
The dates that matter
| When | What happens |
|---|---|
| By 31 December 2026 | The European Positive Lists are finalised into law |
| From 1 January 2027 | Transition begins from national provisions to the European system |
Until the transition completes, 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.
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. Two markets, two files.
Food contact is not drinking water contact
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, because 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.
Where we stand on this
Straight, because a page about approvals should be. Our stainless water line is AISI 304 across the wetted path with no liner or coating, which is the right material choice for potable use, and 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
| 用途 | おすすめの缶 | 選ぶ理由 |
|---|---|---|
| Potable water storage |  20L ステンレス給水缶 |
AISI 304 wetted path, no liner to fail. |
| Smaller potable reserve |  10L ステンレス給水缶 |
Same grade, easier one-hand carry. |
| Food and beverage in plastic |  食品グレードHDPEジェリ缶 |
Food-contact route; confirm the water question separately. |
| The part people forget |  キャップ・クロージャー・ガスケット |
The gasket is a contact material too. |
よくあるご質問
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 the transition completes, national approvals such as the German UBA schemes, French ACS and Dutch KIWA still carry the market.
When do the European Positive Lists take effect?
The lists are being finalised into law by 31 December 2026, with a transition period running from 1 January 2027 for the changeover from national provisions to the European system. 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. Two markets, two files.
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.
参考資料
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 Advisory Scheme approvals
- NSF/ANSI/CAN 61 — drinking water system components
最終確認日 .