Whilst ANEC welcomes that materials in contact with drinking water have been recognised as one of the key issues to be tackled in the revision, we strongly disagree with the problem definition that “different national approval systems for such products and materials, which are not mutually recognised” and “too much legal flexibility” lead to “multiple testing” and, as a consequence, create an “unnecessary burden” for industry.
The main problem is the lack of consumer protection resulting from only few countries having comprehensive approval systems in place (and many Member States having virtually nothing).
The current legal provision lacking any substance is simply inadequate as it does not lead to a high level of safety for consumers in all EU contries. Apart from that the lack of European rules not only leads to cost burdens for industry, but also for those Member States who want to protect their citizens and cannot build on European rules. These problems cannot be solved by “proposing EU harmonized standards for materials and products in contact with drinking water” (if “harmonised standards” means standards prepared by the European standards bodies upon request by the Commission).
We need a regulatory approach either in form of implementing measures adopted by the Commission (provided for in the DWD) or a separate legal framework for materials in contact with drinking water. They may be complemented by European test standards prepared by CEN.
Finally, mutual recognition of approved materials in Member States is definitely not a way forward given the absence of such rules in many Member States.
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