EFCEM WG3 updates: Bolstering compliance and sustainability across health, safety, and water
In its latest meeting, EFCEM's Working Group 3 (WG3) brought together industry members to focus on increasing compliance with safety standards for drinking water, food contact materials (FCMs), and plastics, as well as on sustainability efforts amid myriad regulatory updates, reports Lauren Hurrell
On Tuesday, 24 February 2026, EFCEM's Working Group 3 (WG3)'s latest meeting focused on regulatory updates and implications in Health, Safety & Water. Convened by Mattia Merlini from EFCEM Italia, the aim of the meeting is to update members and collect remarks or comments on the main topics under discussion at the European level. Key points for this iteration focused on compliance with the Drinking Water Directive (DWD), food contact materials (FCM), and plastics.
The drinking water directive
The DWD (2020/2184) aims to protect people and the environment from the harmful effects of contaminated drinking water and to improve access to drinking water. The directive introduces minimum requirements for materials that come into contact with water intended for human consumption throughout the European Union (EU).
The European Chemicals Agency (ECHA) has published Guidance Documents to facilitate the implementation of the European positive list under the DWD by describing good practice for fulfilling the obligations arising from Article 11 of the directive and associated implementing legislation.
The point of compliance in Article 6 of the DWD highlighted in the case of water intended for human consumption used in a food business, at the point at which the water is used in that business.' In point 3, however, it emerges that the DWD applies until the water is used in the business (namely, at the tap). After that point, the FCM rules apply to professional equipment. This approach would exclude the professional catering equipment from the scope of the DWD.
Food contact materials
To ensure a high level of food safety and protection of human health, all FCMs must comply with Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food when placed on the EU market. It establishes that FCM must be manufactured in accordance with Good Manufacturing Practices (GMP), as defined in Regulation (EC) No 2023/2006.
In December 2025, after reviewing current EU legislation, the European Commission published a Study on sustainability in food contact materials (FCM) in view of revising FCM legislation. The study aimed to define sustainability in the FCM context, assess existing legislation, map the market, and propose measures to improve FCM sustainability without compromising food safety or waste reduction.
Key issues include the lack of sustainability in FCM design, low use of recycled materials, and chemicals that threaten public health. Single-use FCMs are prevalent, and reuse rates are low.
Potential measures to improve FCM sustainability include standardized cleaning, traceability, labeling for reusables, eco-design guidance, and product essentiality tests to evaluate if problematic FCMs are necessary or if sustainable alternatives exist.
Sector -wide science-based targets could aim to achieve long-term improvements in FCM sustainability. Monitoring mechanisms would be put in place to track progress toward these targets.
Plastic FCMs
Regulation 10/2011 outlines rules for plastic FCM composition and a Union List of permitted substances, with restrictions and compliance requirements. An amendment to Annex I, updating the Union list, was published on 2 February 2026.
BPA, used in epoxy resins and plastics, now faces significant restrictions under the Regulation. Guidance on implementing Commission Regulation (EU) 2024/3190 was published on 17 December 2025.
The PFAS restriction proposal
PFAS are a large class of synthetic chemicals that can be negative for human health. PFAS, which resist degradation, have been frequently observed to contaminate groundwater, surface water and soil. The European Chemicals Agency – ECHA – recently published background documents for the stakeholder consultation on SEAC's draft opinion on the PFAS restriction proposal, which is expected for the middle of March 2026.
The documentation includes ECHA's survey guidance, designed to help respondents prepare for the consultation and understand what information is requested; and the PFAS use-mapping, which describes the sectors containing PFAS uses, as well as the use categories, sub-uses, and applications within those sectors.
The sectors that could be under assessment by manufacturers are FCMs and applications of
fluorinated gases.
Further details:
The next WG3 meeting is currently scheduled to take place at 10:00 - 11:00 CET on Tuesday, 10 November 2026.