The short answer: no — but you do need to be ready after the transition period starts. You have some time, but you need to start preparing.
If your product already has a valid national approval for use in contact with drinking water, you can continue to sell it during the DWD transition period without rushing into the new EU approval system. However, there are clear rules on what you can and cannot change, and a firm deadline after which national approvals will no longer apply.
Beyond this, any new products you make must comply after the transition window. And changes to existing products that affect approvals will have real impact and will likely mean acquiring a new approval.
This also means a strategic risk: if a raw material supplier you depend on stops functioning, you may abruptly be forced to switch to the DWD due to the fact that you cannot find an alternative material.
Bottom line = You Can Keep Selling – If Nothing Changes
Your national approval stays valid for the transition period as long as:
- The approval is still in force on 31 December 2026.
- You do not make changes that affect the hygienic properties of the product.
- Any updates you make are minor and do not affect the national certificate. The updates must be minor as the national certification body cannot amend the certificate (e.g. if you want to switch out materials).
Some things can change in your product though — maybe
The details are so far a bit fuzzy and may depend on national regulators and approvals, but generally it can be expected that cosmetic changes to non–drinking-water parts will not affect compliance and the national approval can remain valid.
It is also conceivable (although not confirmed) that if you have an approved assembled product, and you switch a component with a national approval for one with DWD approval, this may fall under the original national certification.
The same goes for family certificates — for example, pipes with diameters 20–40 mm: introducing a new pipe within that range is likely still within the certificate.
However, these are minor changes and the flexibility is very limited. The general rule is that changes should always be internally reviewed and preferably communicated with the issuing body (e.g. Kiwa). Major changes generally result in loss of certificate.
Any change to the formulation introducing a new material, changes (even relative) in wetted surface fraction, changes to production processes (e.g. new polymerisation aids), etc. will immediately cause issues with the national approval.
And if that happens during the transition window, it means DWD is the only option.
Contact us and we can perform a full impact assessment on a case-by-case basis.
Bottom Line for Manufacturers
- No need to change right now if your product has a valid national approval on 31 December 2026.
- Plan for EU compliance before 2032 to avoid losing market access.
- Details are somewhat lacking on exactly what changes are allowed; future clarification may come, but it will always remain case-by-case. Reach out to us and we can, together with your certification body, document what must happen.
- National laws can change. For example, some alloys in Germany are approved only until 2028, after which they can no longer be used — and these alloys are not on the EUPL. They will not be allowed in Germany after that date.