Water filters, bottles and drinking water contact products

• Directive (EU) 2020/2184 — drinking water, Article 11 materials in contact
• Regulation (EC) No 1935/2004 — food contact
• Regulation (EU) 2023/988 — GPSR
• Regulation (EU) No 528/2012 where an antimicrobial claim is made

Who has to appoint one

Manufacturers and sellers outside the Union placing water filters, reusable bottles, jugs and products contacting drinking water on the EU market. The recast Drinking Water Directive introduced European positive lists and testing requirements for materials in contact with water intended for human consumption, phasing in from 2026 and 2027.

Thresholds and exemptions

None. Reusable bottles and jugs are food contact articles from the first unit sold.

What must appear on the label

Manufacturer and responsible person details, batch identification, the food contact indication, the intended use and any restriction such as maximum temperature or unsuitability for carbonated drinks, and for filters the replacement interval and the capacity claims. Antimicrobial claims require a biocidal product authorisation.

Marketplace fields

Marketplaces check the responsible person and remove filter listings claiming to remove bacteria or viruses without authorisation. Insulated bottles have additionally faced enforcement on lead solder in the sealing plug, which is a recurring recall ground.

Documentation you must hold

Declaration of compliance for food contact, migration test reports, and from the applicable dates the conformity documentation under Article 11 of the Drinking Water Directive with the European positive lists. Technical documentation and risk analysis under GPSR. For filters, evidence for any performance claim.

Standards and testing

Overall and specific migration testing under the intended conditions of use, lead and heavy metal release for metal bottles and their sealing components, and for products in contact with drinking water the tests set out under the Drinking Water Directive implementing acts. Performance claims about contaminant reduction require testing under a recognised protocol.

Language requirements

Use restrictions, cleaning instructions and claim substantiation in the language of each member state of sale.

When it applies

Food contact obligations apply now; the Drinking Water Directive material requirements phase in from 31 December 2026 with transitional periods, so products designed today should anticipate them.

How long records are kept

Ten years for the documentation and the supporting test reports.

What happens if you do not comply

Withdrawal and Safety Gate alerts, particularly for lead release from bottle plugs, and enforcement action for unauthorised antimicrobial claims.

Who enforces it

Food safety and drinking water authorities, market surveillance authorities, and biocides authorities for antimicrobial claims.

Where the boundary lies

A filter that claims to remove limescale is a performance claim; one that claims to eliminate bacteria is a biocidal claim requiring authorisation. And a bottle that is also marketed for hot drinks needs migration testing at the higher temperature, which many suppliers omit.

Questions we are asked

Are reusable bottles food contact articles?

Yes, and the metal sealing components are the most common failure point, with lead release above the limit a recurring recall reason.

Can we claim our filter removes 99.9% of bacteria?

Not without a biocidal product authorisation. Reduction claims about micro-organisms are biocidal claims in the Union.