With the adoption of the recast Drinking Water Directive (DWD) 2020/2184, the EU has introduced a single harmonised system for approving materials and products in contact with drinking water.
At the heart of this system are the European Positive Lists (EUPLs) , defined in Commission Implementing Decision (EU) 2024/367.
This list is similar to the 4MS approach.
What Is the European Positive List?
The European Positive List is a centralised EU register of all starting substances, compositions, and constituents authorised for use in manufacturing final materials in contact with drinking water.
It covers four material categories:
- Organic materials (starting substances)
- Metallic materials (compositions/alloys)
- Cementitious materials (constituents)
- Enamels, ceramics, and other inorganic materials (compositions and constituents)
This replaces multiple national approval lists and the voluntary 4MS Initiative lists with a legally binding EU-wide reference.
Why It Matters for Manufacturers
Only materials on the list can be used in products placed on the EU market after the transitional periods.
Each entry specifies purity requirements, composition limits, and conditions of use.
If a material you currently use is not listed, it will need a formal application (via a notified body) to be added — a process involving safety assessment, migration testing, and EU authorisation.
How to Read the EUPL in 2024/367
For each material type, Annexes to 2024/367 contain tables.
The Annexes are structured as follows:
- Annex 1 - Organic materials
- Annex 2 - Metallic materials
- Annex 3 - Cementitious materials
- Annex 4 - Enamels, ceramics, and other inorganic materials
- Annex 5 - MTC for metals of relevance in the migration water
Each table entry typically includes:
Column | What It Means |
|---|---|
EUPL Entry Number | Unique identifier for the substance, composition, or constituent. |
Name / Description | Chemical name or alloy designation (e.g., CW509L, CW501L-DW). |
Material Type | Organic starting substance, metallic alloy, cementitious constituent, or enamel/ceramic composition. |
Restrictions / Purity Requirements | Maximum allowable impurity levels (e.g., lead < 0.02%), limits for specific elements, or technical specifications. |
Conditions of Use | Specific permitted applications (e.g., only in certain risk groups, temperature limits, coating requirements). |
Expiry / Review Date | Date when the entry will be reassessed, ensuring ongoing compliance with the latest science. |
What 2024/367 Contains for Each EUPL Entry
For all materials:
- An EUPL number — one of over 2042 entries so far.
- An EC number if available.
- A CAS number if available.
- Name.
- An expiry date.
Organic materials (Annex I)
- FCM Substance number
- Technical function authorised for use
- Categories of materials authorised (e.g., limitations on use in rubber)
- Maximum Tolerable Concentration at the tap (MTCtap, organics)
- Reference to total MTC(T)tap (Annex V), based on:
- (a) Total moiety (Annex I Table 3)
- (b) Total bound or unbound element/ion (Annex V)
- (c) Specific compound groups (e.g., phenols)
- Conditions for use, if applicable
Metallic materials
- Exact alloy designations (e.g., CW501L-DW, CW509L, CW510L, CW724R)
- Compositional limits for metals such as copper, lead, and zinc
- Required surface treatments or restrictions
- Product group limitations (e.g., cast iron restricted to mains)
- Also some generic names such as 'cast-iron' which must comply with underlying EN or ISO standards.
- Product group restrictions. Some materials can only be used in water-mains.
Cementitious materials
- Approved constituents (cements, additives) with purity limits and restrictions
- A list of generic constituencies.
- Similar list to organics
Enamels, ceramics, and other inorganics
- Specific compositions with maximum content limits (e.g., lead < 0.02% by weight) and MTC limits
As an example see below:
Where you can see the following in order:
EUPL Number
EC Number (empty)
CAS Number
FCM Number
Starting substance name
Technical function
What contact materials can be used
The MTC
And a reference to to 2 substances from Table 3 for MTC limits
Conditions for use
And the expiration.
Practical Tips for Manufacturers
- Start with your List of Materials — Check each material against the EUPL where possible, or ask suppliers.
- Verify alloy codes exactly — CW501L-DW ≠ CW501L; compositional limits must match.
- Read conditions carefully — Approved use may be restricted by product group, temperature, or application.
- Check review dates — Materials can be removed or tightened in future reviews.
- Engage suppliers — Request EUPL references and purity test results.
Bottom Line
The EUPL is the gatekeeper list for all materials in contact with drinking water in the EU.
It’s not enough to pass migration testing — the material itself must appear on the list, in the exact form and purity required.
Failure to check early could make a product ineligible for EU market placement.
Bonus: Amending the European Positive List
The EUPLs can be updated — manufacturers, suppliers, or associations may request addition, removal, or modification of entries. This is governed by:
- Commission Delegated Regulation (EU) 2024/365 — procedural rules
- Commission Implementing Regulation (EU) 2024/369 — operational format and documentation
- ECHA — receives, validates, coordinates scientific assessment, and advises the Commission
- We have written more guidance in the ECHA section of this helpdesk.
Key Points for Manufacturers
- Who can apply? Manufacturers; see ECHA guidance.
- When to apply? If a needed material is not listed or needs amended conditions.
- Timeline: Long, can be up to 18–24 months.
- Review cycles: Renewal required when expiry dates are reached.