The Drinking Water Directive 98/83 EC has been strengthened with Directive (EU) 2020/2184, which came into force on 12 January. The revised directive aims to ensure better access to drinking water, better control over the quality of drinking water sources and better reporting. Member states are allowed to include additional requirements or set higher standards. And the FASFC in Belgium has certainly done just that. In the new circular lists a whole row of additional controls and safeguard measures that should be included extensively(er) in the HACCP system for both microbiological and chemical hazards.

If water poses a potential threat to public health, the supply of water should be restricted or prohibited and remedial measures should be taken. Consumers must then also be informed of the measures taken.   

According to Regulation (EC) 852/2004, Annex II Chapter VII, all food business operators must have drinking water available in sufficient quantities where there is a need to ensure that foodstuffs are not contaminated. This is a basic requirement.

Starting points drinking water requirements

• The company is responsible, recognised or unrecognised, to meet the objective of the Regulation.
• The drinking water requirement applies to water that:

- used as process water that can come into direct contact with foodstuffs;

- used as an ingredient in food products.

• If water is used for delivery to third parties or as drinking and washing water for staff, supervision falls under the Environmental and Transport Inspectorate.

When is the drinking water requirement met?

If a company uses only tap water and no further management measures are required by the company.

If there is water from a private well, water that is reused, storage tanks, after-treatment, a complex water supply system or a stricter regime for EC-approved companies from HFAA missions or because of requirements for export to third countries, the company must meet the conditions below:

• The company demonstrates that the water meets the standards of the Drinking Water Act and the Drinking Water Decree (which is an interpretation of Directive (EU) 2020/2184), including the associated measurement programmes, either;
• The company uses Directive (EU) 2020/2184 as a source of reference, managing the risks of possible deviations from the Directive with HACCP principles. The use of this water must not adversely affect the soundness of the foodstuff as a finished product.

Source: 'Foodstuffs' circulars | Federal Agency for the Safety of the Food Chain (favv-afsca.be) and Drinking water - EU rules & policy | Water | Europe decentralised