If you want to introduce a new starting substance, constituent, etc. into use in the EU (i.e., in a national list) for use in drinking-water-contact products, the transition period under the DWD works differently for you than for manufacturers with existing approvals. The grace period until 31 December 2032 only applies to final materials and products that already have a valid national approval before the EU system starts on 31 December 2026.
A completely new substance (i.e., a starting substance) will be treated as a new application, and you must follow whichever approval system is active at the time you apply. If you act before the EU system starts, you can still apply under your national scheme and possibly continue to operate until 2032 under Article 3 of 2024/367. This must be issued before 31 December 2026, and it is up to the national body to accept your application.
If you wait until after the EU system is in force, you will need to go through the EU Article 11 process — which includes the EU Positive Lists and ECHA.
In other words, there is a short-term strategic choice: either get in early under your national rules and benefit from a transitional extension, or go straight into the EU system to avoid doing the work twice.
Realistically, for new materials from 2026 (even at the start of the year), national authorities will refer to the DWD.
Key takeaways:
- The 2032 deadline only applies to materials and products already approved nationally before 31 December 2026. Trying to get onto a positive list with a national approval works differently.
- New materials approved nationally before 2026 can be sold until 31 December 2032 (if they meet DWD parametric values).
- New materials approved after 31 December 2026 must follow the EU Article 11 system from the start. This involves 2024/367.