Materials intended to come into contact with drinking water

For materials intended to come into contact with drinking water, the main obligations set out in Directive (EU) 2020/2184 and related Regulations cover several key aspects. The Directive requires that such materials are safe, comply with strict hygiene standards and subject to constant monitoring and control.

In particular, Member States should ensure that materials used for the extraction, treatment, storage or distribution of drinking water:

1. Do not compromise human health:
   The materials should not release substances that may alter the quality of the water in such a way as to damage human health, respecting the safety limits defined by the directive.
2. Do not negatively affect the colour, smell and taste of the water:
   The materials should not perceptibly alter the water from an aesthetic or sensorial point of view (colour, smell and taste), ensuring that the water remains pleasant to consume.
3. Do not promote microbial growth:
   Materials should not promote the growth of pathogenic microorganisms or other microorganisms that could compromise the healthiness of the water.
4. Do not release contaminants at levels higher than necessary:
   Materials should avoid the release of contaminants (such as heavy metals, hazardous chemicals, etc.) in quantities that may exceed the limits established by regulation, while ensuring the correct functioning of the material for its intended purpose.

These requirements are essential to ensure that drinking water remains safe and of good quality for consumers, protecting public health and ensuring the reliability of the distribution network.

New European drinking water system

The new European system introduced by Directive (EU) 2020/2184 establishes precise rules for the choice of materials and objects that are used in plants for the treatment, storage, supply and distribution of water intended for human consumption. The aim is to establish, through implementing acts, a first positive European list of starting substances, procedures and methods for testing and accepting materials and products.

Timing and transition process

The new regulation, regarding materials intended for contact with drinking water, applies from 2026 for new objects placed on the market, while objects already compliant and installed before that date will have a transition phase until 2032.

In conclusion, the choice of materials for contact with drinking water is essential to guarantee the quality and safety of water and the protection of public health, as well as compliance with current legislation.

SVHC and packaging

With regard to the use of SVHC substances in packaging materials and products, packaging producers and importers must comply with some requirements set out in the REACH regulation: they must ensure that all chemical substances present in the packaging are registered, evaluated and, if necessary, authorised; if a package contains an SVHC substance in a concentration higher than 0.1% by weight, the producer or importer must inform the users of the packaging and provide information on the substance, including its identification and any risks to health and the environment.
Companies should try to reduce the use of SVHC substances in packaging, adopting safer alternatives or optimising production processes. This is to reduce the risk of damage to human health and the environment and ensure compliance with European regulations.

SVHC and food packaging

The obligations for SVHC substances must also be respected for food packaging.
Food packaging may contain SVHC substances (such as plasticizers, colorants, stabilizers or additives) which, if released into the food, could pose a risk to human health. If a SVHC substance is present in concentrations above 0.1% by weight in the packaging material and can migrate into the food product, there may be a risk to the consumer.
The risk assessment of SVHC (Substances of Very High Concern), as well as all other substances considered potentially dangerous, in food packaging is a fundamental part of safety management and compliance with European regulations, in particular food safety legislation, such as Regulation (EC) 1935/2004.

Detection and identification of SVHC substances

The first step in the risk assessment is to identify whether there are any hazardous substances in the food packaging. If there are any SVHCs among them, this involves:

• Materials Analysis:
  Examine the materials used to produce packaging, such as plastic, paper, metal, varnishes and adhesives.
• Consultation of the candidate list:
  Check whether some of the substances used in the materials are included in the candidate list, which is constantly updated by the European Chemicals Agency (ECHA).
• Migration risk assessment:
  One of the crucial steps in the risk assessment is to determine whether the SVHC substance migrates from the packaging material to the food in quantities that may be dangerous to human health. Migration is influenced by various factors, including the type of packaging, conditions of use, chemical properties of the substances.

Conclusions

Risk assessment of hazardous substances, including SVHCs, in food packaging is a complex process that requires a combination of chemical analysis, migration testing and compliance with food safety regulations. Companies must ensure that packaging does not release hazardous substances in quantities that could compromise consumer health and food, managing risks through preventive measures, such as the use of appropriate materials and continuous verification of compliance with current legislation.