The positive list

Consortia

H2O
H2O Register
Chemical Registration Expert
3 min read

Under the Drinking Water Directive (DWD), manufacturers face many of the same challenges that led industry to form consortia under REACH: high testing costs, complex technical requirements, and the need to present a coherent, defensible data package to authorities and conformity assessment bodies. Although the legal framework is different, the logic is similar—where several companies use the same or very similar materials or formulations, working together can significantly reduce duplication of effort and expense.


A DWD-focused consortium can pool resources for migration testing, toxicological assessment and dossier preparation for inclusion on the European Positive List or for demonstrating conformity of materials and products. By sharing data and coordinating test programmes, members can benefit from economies of scale, reduce individual financial exposure, and speed up time to market. Consortia can also help align technical positions (e.g. on worst-case compositions, reference materials, or grouping strategies) and present a united, consistent approach in discussions with authorities.


Unlike REACH, however, there are no formal SIEFs and no “forced” consortia or mandatory data-sharing mechanisms under the DWD. Participation is voluntary, structures are flexible, and any collaboration must be designed to respect competition law and confidentiality while still allowing meaningful cost and data sharing. This gives companies considerable freedom to tailor the consortium setup to their needs (for example by product type, polymer family, or supply chain segment).


Beyond the ECHA Notifications of intention - there is also no guidance. 


We can help you explore whether a DWD consortium makes sense for your situation, identify potential partners across the supply chain, and design the governance, cost-sharing model and technical work plan. If you are interested in forming or joining a consortium for DWD conformity, please reach out to us so we can discuss options and next steps.

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