The recast EU Drinking Water Directive (DWD) 2020/2184 and its 2024 acts introduce a large change to the use of lead in drinking water infrastructure and a tightening of lead requirements. This affects material selection, product design, supply chain control, testing regimes, and conformity assessment.
1. The New EU Lead Limit
- Previous limit: 10 µg/L at the tap.
- New limit: 5 µg/L at the tap (Annex I, Part B).
- Implementation:
- Applies fully to new EU approvals from 31 December 2026.
- National approvals from 13 July 2021–31 December 2026 remain valid until 31 December 2032.
2. Where Lead Appears in the New EU Framework
- Parametric value: 5 µg/L at the tap.
- EU Positive Lists & Conformity Assessment:
- Lead may appear as part of certain metallic compositions.
- Lead may be restricted in other material categories based on purity rules.
- Formulation review: All relevant substances must be declared (2024/368 Annex I).
- Unexpected substance in migration: If detected but not declared, an investigation is required.
3. Metallic Materials – Brass and the Positive Lists
The EU Positive List for metallic materials includes several brass alloys for drinking water applications.
[LINK] to our positive list searcher (EUPL 1644–1693).
Excluded: Traditional high-lead brasses and some dezincification-resistant grades (e.g., KTW-BWGL grades) are not on the EU list. This means:
- No use for new approvals after 31 December 2026.
- Some countries (e.g. Germany) prohibit earlier (e.g., 12 January 2028).
- CW617N must be replaced for EU supply.
- Objections in some Member States (e.g. Finland) have been raised, but the DWD limit cannot be adjusted.
4. Organic Materials – Lead and pigments, colourants, and fillters
For organic materials, if pigments, colourants, and fillters are used that:
- Do not meet the purity requirements in 2024/368 Annex I (2.22 H or J), or
- Purity testing is not performed
Then lead is monitored during migration testing. It becomes a relevant substance even as an impurity.
5. Enamels, Ceramics, and Other Inorganic Materials
For final enamels, ceramics, and similar materials: Lead content must be < 0.02% by weight in the final material. This applies even if migration is low. It is a compositional requirements.
6. Migration Testing Requirements
Under Implementing Decision 2024/368, migration is measured on final materials. Metallic lead limits align with the 5 µg/L parametric value, considering allocation. Risk groups (RG1–RG4) determine surface area-to-volume ratios for testing. Testing conditions and water composition are harmonised EU-wide.
7. Design, Supply Chain, and Compliance Actions
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Material Choice
Use low-lead brasses (CW509L, CW510L) or lead-free alternatives. For organic materials, confirm purity; for inorganic materials, ensure low lead content.
Supply Chain Control
Require supplier declarations for Positive List compliance. Collect purity and migration test results for intermediate materials.
Product Design
Reduce stagnation zones; ensure coatings remain stable over product lifetime.
8. Why This Is Critical
The new framework combines a stricter parametric limit, restricted alloy list, purity rules, and tight composition limits. Compliance is now about material eligibility from the start, not just passing migration tests.
Failure to adapt may restrict market access from 2026 onward.