A European Acceptance Scheme (EAS) for products in contact with drinking water is under development by the European Commission (DG Enterprise). The aim is to introduce in due time a harmonized European approval system which will replace the existing national regulations and procedures in the area of drinking water contact in a broad sense.
The intention is to develop a drinking water approval procedure for Construction Products under the umbrella of the Construction Products Directive (CPD).
Experts from TEPPFA are actively participating in the Expert Group and Sub groups where we can share a long time experience of our industry. A joint working group for drinking water from TEPPFA and PlasticsEurope is in place and systematically prepares our contributions, strategy and commenting on draft documents that are prepared. This united approach on the part of the plastics industry is needed to strengthen our joint contribution.
Coordination where useful also takes place at CEPMC (Council of European Producers of Materials for Construction) to deal with general and horizontal aspects. Support is also canvassed for any relevant issues.
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TEPPFA Position Regarding EAS
Experts from TEPPFA and PlasticsEurope have issued a joint position paper, which is the basis for our contribution to the EC committees:
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The basic objective of our contributions is to achieve an optimum consumer protection by ensuring a high and consistent level of drinking water quality.
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Support of European Acceptance Scheme
We basically support the principles of a European Acceptance Scheme with the aim to harmonize test methods and requirements through all EU Member States and to achieve full mutual recognition of test reports between accredited laboratories.
We support the view that the EAS must be based on a sound scientific basis for the protection of public health, and that it must be transparent.
The pass/fail criteria to be set for the different parameters have to be such that materials that are currently authorised in the market are not disqualified for such use.
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The EAS will be applied under the umbrella of the CPD. This implies the following aspects:
Approach and Consequences
- EAS is related to Essential Requirement 3 of the CPD (Health, Hygene)
- The drinking water characteristics have to be defined in the harmonized EN standards
- All the applied test methods will be harmonized in the EU. The test methods are to be defined in CEN/TC164.
- The required limits or pass/fail criteria of all test methods remains the responsibility of the national authorities.
- If implemented, the drinking water approval be covered by the CE marking.
- It is expected that complete Mutual Recognition of test results, test report and audits will be in place.
TEPPFA experts together with PlasticsEurope experts participate in the Expert Group and sub groups of the European Commission DG Enterprise (Organisation chart).
TEPPFA supports this approach assuming that:
- Tests to be performed are relevant for consumer protection
- There is one test standard per EAS characteristic and national schemes will implement that standard and withdraw their own ones
- Type test results are mutually recognised
- Audit test results are mutually recognised
- The requested (and actually existing) intermediate stage of approved plastics compositions comparable to the metals composition list is taken on board
- The Type Test and Audit Test schemes as proposed by our industry are seriously taken into consideration
- An EU Drinking Water Product List (DWPL) of assessed substances based on the EU food contact Product List (PL) is established, taking into consideration the inventory of national DW lists and replacing these DWPL’s (details to be worked out!)
- A EU list of approved plastics compositions based on national lists
is established
- Mathematical modelling of migration and exposure is accepted as is already the case in the EU food contact directives
- A uniform way of calculation of practical values for migration
is defined and uniform conversion factors are applied
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