DRINKING WATER DIRECTIVE (DWD)
PRODUCTS
ALREADY ON THE MARKET
Here's what the DWD requires and how to comply.

Your product is already on the market.

TRANSITION PERIOD IN ITALY

The European Drinking Water Directive (DWD – EU 2020/2184) has redefined the rules for all products that come into contact with water intended for human consumption.
If your product is already on the market, the transition period directly affects you: There are deadlines to meet and documentation requirements to fulfill—and two practical ways to do so without market access barriers.

If your product complies with Ministerial Decree 174/2004 and has a declaration or certificate of conformity valid through December 31, 2026, you may continue to market it on the Italian market during the transition period. The rules, however, vary depending on the lead level in the tap water.

What can you do now, and until when?

Until

31.12 2026

You can begin the certification process with an accredited body such as ICIM and gather all the necessary documentation. Doing this now will allow you to get a head start and obtain the certificate as soon as the organization is officially notified.

Until

31.12 2030

Products that comply with Ministerial Decree 174/2004—with a declaration of conformity valid through December 31, 2026—may be placed on the market. If the product does not comply with the lead limit of 5 µg/l, its sale will be suspended as of that date.

Until

31.12 2032

If your product complies with the lead limit of less than 5 µg/l on tap, it may be sold throughout the transition period. Effective January 1, 2033, European DWD certification will be mandatory without exception.

Warning: Every product that comes into contact with drinking water must be accompanied by a self-declaration of compliance with Ministerial Decree 174. A general statement is not enough: it must be supported by documented objective data—in particular, test reports on migration tests—and must specifically identify materials and suppliers.

Two routes. One goal:
To be ready, without market access barriers.
To support manufacturers during this phase, ICIM Group offers two complementary routes. Choose the one that best suits your company’s needs and schedule.

Voluntary third-party certification

Accredited by Accredia – valid until December 31, 2032

The ICIM certification scheme is based on the same principles as the mandatory European system. Choosing it today means having recognized, verifiable proof of compliance that is marketable throughout the transition period—and being ready when the European directive takes full effect.

HOW IT WORKS (3 steps):

1

Documentary analysis

of the manufacturing process, materials, and supply chain

2

Migration tests

at the OMECO-accredited laboratory (ISO 17025, Accredia)

3

On-site audit

to verify the adequacy of production processes: suppliers, control plan, traceability

BENEFITS

To ensure that the certificate of conformity is issued by December 31, 2026, the initial stages of the certification process—including the submission of samples to OMECO—must be completed by September 30, 2026.

Laboratory tests for self-declaration

Certified technical support for your declaration of conformity with Ministerial Decree 174
If you proceed with a self-declaration of compliance with Ministerial Decree 174, you will need a solid and verifiable body of documentation. Migration testing conducted by an accredited, independent laboratory is not merely a technical requirement: they ensure that your self-declaration will stand up to any scrutiny by customers, distributors, or authorities.

WHAT YOU GET:

For laboratory testing only, ICIM can guarantee the issuance of the test report only for samples received by OMECO by October 15 2026.
Do you sell in Europe? The rules vary from country to country.

The DWD establishes a harmonized European framework, but each Member State has implemented the transitional provisions according to its own timeline and procedures. The result is a regulatory landscape that remains diverse: the deadlines for lead vary, the conditions for maintaining national certifications differ, and the documentation requirements are not uniform.

If you manufacture or distribute products in multiple countries, understanding these differences isn’t just a minor detail—it’s a priority.

FRANCE

Decree 2026-80 of February 11, 2026, stipulates that products with an ACS certification valid as of December 31, 2026, may obtain an extension of the certificate’s validity through December 31, 2032 — provided that the product has not undergone any changes in its composition or hygienic properties.

Lead limit 5 µg/l: Probably starting January 12, 2028 (regulatory process still being finalized)

GERMANY

Certificates of conformity issued based on the criteria of the Federal Environment Agency (UBA) may be extended or remain valid for the entire duration of the transition period, through December 31, 2032—provided that the composition of the products’ materials remains unchanged.

 

Lead limit 5 µg/l: Effective January 12, 2028

AUSTRIA, FINLAND, THE NETHERLANDS, POLAND, SWEDEN

These countries will make full use of the entire transition period: The lead limit of 5 µg/l will not take effect until December 31, 2032, coinciding with the end of the transition period.

PORTUGAL AND LIECHTENSTEIN

They will be an exception compared to the rest of Europe: they are expected to comply with the lead limit of 5 µg/l by 2036, after the general transition period has ended.

OTHER COUNTRIES

The European regulatory framework is constantly evolving, and national transpositions vary significantly from one country to another.
If you operate in a market not listed here, our team is available to provide you with an up-to-date and detailed analysis of the regulatory landscape in the country you are interested in—including deadlines, documentation requirements, and conditions for maintaining existing certifications.

BENEFITS

1

Reduced risk of non-compliance and market access restrictions

2

Enhanced technical and commercial value of materials and components

3

Reduction in time and costs for finished product certification

4

A single partner for the entire DWD process

Why ICIM SpA?

ICIM SpA is accredited by ACCREDIA for the product certification scheme in compliance with the DWD Directive.
Specific technical and regulatory expertise on products in contact with drinking water
The Pre-Products scheme is designed for full alignment with the mandatory compliance process
Strategic support to transform a regulatory obligation into a competitive advantage
Integrated approach: training, verification, testing and certification
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