Products with certificates valid as of 12/31/2026 will be able to enjoy the transitional period until 12/31/2032.
This means that, depending on the type of the certificate in question - with a fixed expiry date or a formally unlimited validity period - an extension or continuation of the certificate until 31 December 2032 at the latest is possible within the transitional period.
Constraint on the parametric value in the specific case of lead, article 3 of the act in question 2020/367 introduces conditional transitional provisions: “Substances, compositions and starting constituents which have been approved by a competent authority of a Member State between 13 July 2021 and 31 December 2026, in accordance with national provisions, may be used in the manufacture of materials or products which come into contact with water intended for human consumption until 31 December 2032, provided that they respect the parametric value of 5 µg/l Pb (lead) per tap referred to in Part B of Annex I to Directive (EU) 2020/2184.”
Each member state will manage the national transitional provisions independently.
In this regard, Germany has spoken out, where the reference limit value defined in Directive 2020/2184, i.e. 5 μg/l by 2036, will come into force from 12 January 2028, through the German Drinking Water Ordinance, ALL III (Ordinance on the quality of water intended for human consumption – Trinkwasserverordnung – TrinkwW) to guarantee that from this date onwards no more products are installed which lead to exceeding this limit value.
Clearly the current EU PL already lists only metallic materials evaluated in relation to compliance with the lead parameter value of 5 μg/l therefore the compositions present in the EU PL can also be used after 12 January 2028 in Germany. ANIMA on behalf of AVR met with MIMIT (Ministry of Business and Made in Italy) in Rome to ensure a sufficient transition period to allow companies to adapt effectively.
It is important that the necessary coordination actions are implemented with the other competent authorities so that Italy implements the transitional period allowed by European legislation, taking into consideration the specificities of our industry.