From 1 January 2027, UK manufacturers selling into the EU need EU-MHR conformity, or a qualifying national approval in an EU member state valid on 31 December 2026. NSF research across five European markets finds 88% expect testing and audit capacity to delay industry readiness, yet 30% do not plan to select an external partner until 2027
Manufacturers of products and materials that come into contact with drinking water are confident they understand the European Union’s new Minimum Hygiene Requirements, or EU-MHR, but few have completed the practical work needed to prepare, according to independent research published today by NSF, a global human health organisation.
Independent research among 110 senior decision-makers from manufacturers in the United Kingdom, Germany, France, Italy and Spain found a significant gap between understanding and execution. While 99% said they were at least somewhat confident they understood what compliance requires, just 7% had completed a gap assessment. Only 22% held a detailed testing and certification plan, and 89% had not yet engaged a laboratory, certification body or consultancy of any kind. Nearly a third (30%) did not plan to appoint one until 2027, the year the rules take effect.
From 1 January 2027, harmonised requirements established under Article 11 of the revised EU Drinking Water Directive and its associated acts will govern covered products placed on the market in all EU member states. The requirements apply to relevant materials and products that come into contact with drinking water, from pipes, valves and meters to the seals, gaskets and coatings inside them. EU-MHR will progressively replace national hygiene approval schemes across the EU, including Germany’s UBA and France’s ACS, by 2032.
“Confidence is not the same as a certificate,” said Vincent Boks, vice president of water at NSF. “With months rather than years remaining, manufacturers will be measured on what they have completed, not on what they understand. Planning ahead, completing the preparatory work and engaging early with a conformity assessment partner such as NSF can help manufacturers move more efficiently through the process once formal EU-MHR certification becomes available.”
In Great Britain and Northern Ireland, products in contact with drinking water continue to be governed by the Water Supply (Water Fittings) Regulations 1999, the Water Supply (Water Fittings) (Scotland) Byelaws 2014 and the Water Supply (Water Fittings) Regulations (Northern Ireland) 2009. Compliance with UK requirements, including certification routes such as WRAS Approval and NSF Regulation 4 certification, does not provide EU-MHR conformity or access to the EU market.
Ireland, as an EU member state, is within the scope of EU-MHR, and covered new products placed on the Irish market for the first time from 1 January 2027 must meet the harmonised requirements. Ireland has no national approval scheme of its own: its national water utility, Uisce Éireann, currently requires products in contact with drinking water to hold UK approval, either a listing by the Drinking Water Inspectorate (DWI) or WRAS Approval. Ireland has indicated that products already on its market under a valid approval will continue to be recognised during the transition period to 2032, and that it will recognise other member states’ national certificates, with the arrangements kept under review.
Manufacturers placing covered products on the EU market from 1 January 2027 will need either EU-MHR conformity or qualifying national approval, valid on 31 December 2026, under transitional arrangements available in certain member states. There is no formal mutual recognition between the UK and the EU, and no confirmed indication that the UK will adopt EU-MHR. Manufacturers supplying more than one of these markets will need to demonstrate conformity with each of their regulatory settings separately.
EU-MHR transition window is narrower than many manufacturers assume
The research also identified uncertainty about when EU-MHR could affect market access. Seventeen percent of manufacturers believed the new requirements would not affect their ability to sell into the EU until 2028 or later, a full year after the framework applies.
The transition period from national schemes to EU-MHR runs to 31 December 2032, at the latest, and in several markets it ends sooner. Transitional cover in Italy ends on 31 December 2030 for products that do not meet the five microgram per litre limit for lead in specified water infrastructure. Germany will ban lead-containing alloys that cause the limit to be exceeded from 12 January 2028. What qualifies as a valid national approval, and how long it remains valid, differ by member state. Manufacturers are responsible for identifying and meeting the applicable national requirements for each product and EU market they want to operate in.
Manufacturers anticipate testing and audit bottlenecks
Eighty-eight percent of respondents expect testing and audit capacity constraints to delay industry readiness. The barriers cited most frequently were laboratory capacity and testing lead times, certification queues and access to supplier documentation.
“Certification is the final step before a product can be placed on the market, but it should not be the first conversation with a certification partner,” Boks said. “Laboratory capacity and assessor time are finite, and they are allocated in the order manufacturers arrive. A queue that looks manageable in 2026 will likely be very different in 2027.”
For some materials, testing alone can take several months. Depending on the method and test program, migration testing can run for up to 31 days per condition, while enhancement-of-microbial-growth testing can take 12 to 16 weeks. Formulation review, chemical screening, organoleptic testing, technical review and conformity assessment add further time to the process.
Supplier evidence is the second pressure point
Although 95% of respondents were confident their raw material suppliers would support the new requirements, more than a third already reported difficulty obtaining the documentation they need.
“Compliance under EU-MHR runs all the way back to starting substances,” said Samantha Duffy, senior manager of global water programs, EU and U.K., at NSF. “For most manufacturers, that is a supply data exercise before it is a laboratory exercise, and it is one they have never had to run before. The risk is late discovery, finding out too close to the deadline that evidence is missing or capacity is gone.”
What manufacturers can do now
EU-MHR certification can only be issued after 1 January 2027, but the work that determines how quickly a product moves through it happens during 2026. The starting point is engaging with a certification body to understand the applicable conformity assessment requirements and determine the appropriate route for each product. Scope confirmation, gap assessment, formulation review against the EU positive lists, supplier evidence collection and any necessary testing can then be planned and completed in the appropriate sequence.
“Manufacturers that act now can enter 2027 with clearer documentation, evaluated supply chains and testing plans in place,” Duffy said. “Those that wait risk encountering the compliance deadline and the capacity queue at the same time.”
NSF is accredited by the Belgian Accreditation Body (BELAC) to ISO/IEC 17065 for conformity assessment activities under the revised EU Drinking Water Directive and operates an ISO/IEC 17025-accredited water testing laboratory in Rheda-Wiedenbrück, Germany. Its EU-MHR services span pre-assessment and gap analysis, migration and performance testing, conformity assessment, and NSF Protocol 534, which allows suppliers of raw materials, pre-products and intermediates to generate recognised evidence earlier in the supply chain.
Read the research
The EU-MHR Readiness Gap Whitepaper introduces the NSF EU-MHR Readiness Index, which benchmarks manufacturer preparedness across six dimensions, alongside a country-by-country comparison, a self-assessment scorecard and a 2027 readiness checklist. Available at NSF Research: The EU-MHR Readiness Gap | NSF
