For UK manufacturers exporting products into the European Union, 1 January 2027 represents an important change in the route to market.

From that date, the EU Minimum Hygiene Requirements (EU-MHR) will apply to covered materials and products that come into contact with drinking water. This includes products and components such as pipes, valves, seals, gaskets and coatings. Established under Article 11 of the revised Drinking Water Directive, the new framework aims to replace fragmented national hygiene approval schemes with a harmonised EU-wide approach.

For manufacturers, harmonisation should ultimately simplify access to European markets. The transition, however, requires careful preparation.

EU-MHR is not replacing UK domestic requirements. Products supplied in Great Britain and Northern Ireland will continue to follow the applicable UK regulations and approval routes. However, UK certification does not provide EU-MHR conformity or access to the EU market. Manufacturers supplying both markets will need to manage their UK and EU compliance obligations separately.

Independent research commissioned by NSF among 110 senior manufacturing decision-makers in the UK, Germany, France, Italy and Spain found a substantial gap between awareness and action. Although 99% were at least somewhat confident that they understood the requirements, only 7% had completed a gap assessment. Just 22% had developed a detailed testing and certification plan, while 89% had not engaged a laboratory, certification body or consultant.

Compliance is not limited to testing the finished product. Manufacturers may need to trace materials back to permitted starting substances and obtain supporting documentation from suppliers. Across the five markets surveyed, 36% were already experiencing difficulty securing this information.

Time is another important consideration. Migration testing can take up to 31 days per condition, while enhancement-of-microbial-growth testing may require 12 to 16 weeks. Technical review, production-control assessment and certification must then follow. It is therefore unsurprising that 88% of respondents expect limited testing and audit capacity to delay industry readiness.

UK manufacturers should act now by identifying products and components in scope, completing a gap assessment, screening formulations, gathering supplier evidence and planning their conformity assessment route. Waiting until 2027 could mean reaching the compliance deadline just as demand for testing and certification reaches its peak.

NSF’s EU-MHR Readiness Gap whitepaper includes further research findings and a practical readiness checklist for manufacturers.

Guest blog provided by Samantha Duffy, Senior Manager of Global Water Programs, EU & UK, NSF