What is the transition period?

The recast Drinking Water Directive (DWD) 2020/2184 introduces, for the first time, a fully harmonised EU-wide system for approving materials and products in contact with drinking water.

This replaces the patchwork of national schemes that manufacturers have worked with for decades — such as Germany’s KTW-BWGL, France’s ACS, etc.

To avoid a sudden cut-off for existing approvals, the Directive builds in a transition period.

This period gives industry time to:

• Adapt material choices to meet the new European Positive Lists in Implementing Decision (EU) 2024/367.
• Complete conformity assessments using the new EU modules set out in Delegated Regulation (EU) 2024/370.
• Introduce the EU Drinking Water Mark in accordance with Delegated Regulation (EU) 2024/371.
• Align supply chains so that upstream materials also comply with the new requirements.

For manufacturers, this is not “extra time to ignore the rules” — it is a strategic window to phase out non-compliant materials, update designs, and secure EU-wide certification before the national systems are switched off.

In this regard, it’s worthwhile to prepare early.

How the Transition Works

Start Date

The Directive entered into force on 12 January 2021. Member States had to transpose it into national law by 12 January 2023.

EU-wide System Start 

The new harmonised EU rules (Article 11, Positive Lists, conformity assessment) apply from 31 December 2026. Informal certification will be achievable earlier: manufacturers may undergo the procedure already in 2026 so the Notified Body can issue certification immediately when 2027 starts.

Transitional Approvals for Materials (2024/367)

Within the positive list there are specific approvals that can be subject to phase-out periods:

• Materials approved under national rules after 13 July 2021 but before 31 December 2026 may continue to be used until 31 December 2032, provided they comply with the 5 μg/L lead limit and other Annex I parametric values. This window applies to materials — not national product approvals.
• Materials approved before 13 July 2021 have no bearing here. Older approved materials not on the Positive List may no longer be used.

Note! 
This applies to materials - not to product approvals. 
The exact provision is found in Article 3 of 2024/367

No new approvals

Planning to introduce a product into the EU without an existing approval? After 31 December 2026, the DWD Article 11 route is the only valid option — new national approvals cannot be used.

Products with National Approvals

If your product already holds a valid national approval (e.g., KTW-BWGL, ACS), you can continue placing it on the market during the transition period. National approvals granted before 31 December 2026 remain valid until 31 December 2032.

This means you can keep selling nationally approved products across the EU until 2032 — but after that, all products must comply with the EU-wide Article 11 system. Manufacturers should use this window to phase in Positive List–compliant materials and complete EU conformity assessment.

Note!  
Changes to products may cause national approvals to expire.  
If you change your product beyond what your national approval allows, 
you may be forced into DWD certification — because national approvals 
will no longer be possible after 2026.

Why It Exists

For very obvious reasons.

It gives manufacturers and suppliers time to: 

1) Adapt designs to comply with the EU Positive Lists (2024/367). 

2) Complete conformity assessments (2024/370 and 2024/371). 

3) Clear existing stock and adjust supply chains.

And generally ensure they are compliant.

So you need to take into account:

• Dual Systems — Until 31 Dec 2026, national schemes (e.g., KTW-BWGL, ACS) remain valid.
• EU Market Access — From 2026, only Article 11 approvals grant EU-wide recognition.
• Long-Tail Sales — Transitional products can be sold until end-2032.