Under the current framework, treatment chemicals and filter media are excluded from the European system for materials in contact with water intended for human consumption. This exclusion can create confusion, because in practice, certain treatment chemicals and filter media form part of products that are otherwise fully regulated under the Drinking Water Directive (DWD) — but it is what it is as these are regulated under Article 12.
For example, ion exchange resins, sacrificial anodes, filter membranes, and other media may sit inside housings, cartridges, or treatment units that are clearly considered “products in contact with drinking water” under Article 11. In such cases, the European system still applies to all the other components in contact with the water — such as housings, O-rings, seals, and even adhesives used to fix membranes — but not to the treatment chemicals or the media itself.
What Rules Apply to the Media and Chemicals Themselves?
According to Article 12 of Directive (EU) 2020/2184, treatment chemicals and filter media within these products are subject to national requirements rather than the EU Article 11 regime. This means that:
- Products must bear the European mark to show Article 11 conformity for the regulated components.
- In addition, they must carry national conformity marks for the treatment chemicals and filter media where applicable.
It is hopeful but not fully likely that Member States refer to the European requirements for the materials used as filter media. Generally speaking, the situation at the moment is unclear and the above should be monitored should you use filters and chemicals in your system.
Other Exclusions
Sliding or fitting lubricants, metal machining lubricants, and other lubricants used during the assembly process are also not covered if they are completely removed before the product or system is put into service. The same applies to other substances used for production that are removable and removed.