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Sender: UAB „Ariston Lithuania“

Address: Pramonės pr. 4E, LT-51329 Kaunas

Company code: 307466135

Phone number.: +48 600 011022

E-mail: [email protected]

Date: 2026 April 20th

To kind attention: Aive Telling Environmental Health and Chemical Safety Manager

Institution: Environmental Health and Chemical Safety, Department of Public Health

Address: Gonsiori 29, 15027 Tallinn, Estonia

Phone number.: +372 626 9151

E-mail: [email protected]

Dear Madam,

I am writing on behalf of Ariston Group, a leading international manufacturer of domestic hot water and heating solutions. As producers of equipment intended to operate in direct contact with drinking water, we are closely following the implementation of the new Drinking Water Directive (EU) 2020/2184, , in particular Article 11. [eur-lex.europa.eu], [eur-lex.europa.eu]

Under Article 11 of the Drinking Water Directive, in April 2024 the European Commission adopted a series of Delegated and Implementing Acts setting minimum hygiene requirements for materials in contact with water intended for human consumption. These rules will apply as of 31 December 2026.

For the European thermal comfort industry, one major concern relates to the requirements pertaining to enamels used to coat steel storage tanks in heat pumps and water heaters, which ensure their protection against corrosion, hence durability. Hafnium, a substance intrinsically linked to zirconium and widely used in enamels for over 100 years, has been excluded from the lists of substances authorized for contact with drinking water. In addition, migration limits are missing for a number of key elements essential to enamel production, making enamels non-usable.1

Hafnium/zirconium compounds are crucial because of their resistance to hot water and their ability to adhere strongly to metallic substrates. Their omission from the lists, coupled with the lack of migration limits, creates severe risks for the European thermal comfort industry. In fact, it is estimated that up to 91.5% of storage tanks would no longer be marketable in the EU after 2026. As enamels are also used in heat pump tanks, their production would equally be disrupted.

1 The concerned substances are: Bismuth (Bi), Cerium (Ce), Hafnium (Hf), Molybdenum (Mo), Praseodymium (Pr), Strontium (Sr), Titanium (Ti), Yttrium (Y) and Zirconium (Zr)

These regulatory gaps could trigger disproportionate consequences, including a de facto phase-out of enamelled heat pumps and water storage tanks in Europe.

Meeting the new requirements would imply a complete redesign of production processes and replacement of existing industrial assets, demanding massive new investments. This would place European manufacturers at a severe disadvantage compared to non-EU competitors, undermining both the Clean Industrial Deal and the objectives of the European Competitiveness Compass.

The Commission’s DG Environment has suggested that industry should apply for toxicological assessments of the relevant substances. However, such evaluations are lengthy and burdensome, especially for materials with a century-long track record of use, and any updates to the enamel-related positive list are unlikely before the end of 2031.

So, although the new legislation foresees a transition period until 31 December 2032, the coexistence of fragmented national certification schemes risks creating a patchwork of compliance regimes. This would fracture the internal market and require manufacturers to seek approval separately in each Member State, putting the EU industry’s survival in jeopardy.

We understand that in Estonia, the Ministry of Social Affairs (Department of Public Health) will also take appropriate actions to define new national regulations implementing EU acts on materials and products intended to come into contact with drinking water and are planned to be prepared in the coming year, with a transitional period from 2027 to 2032.

Given the restrictions that will apply from 2027 to all enameled storage water heaters under the new Drinking Water Directive (DWD), the transitional period mechanism will be crucial for the continued import and sale of these products in Estonia after the end of 2026.

In light of this, Ariston Group would like to request a meeting with your representatives to discuss this matter in detail. Our aim is to explore potential solutions and ensure compliance with Estonian requirements during the transitional period. Specifically, we seek clarification on the following points:

• Which rules will apply during the transitional period?

• Whether a self-declaration by the manufacturer, demonstrating that the products are lawfully marketed in another EU Member State, will be recognized by Estonian authorities (i.e. mutual recognition mechanism).

• Whether any restrictions on lead alloys will be introduced between 2027 and 2032.

• The requirements for new products placed on the market after 2027.

We acknowledge that responsibilities for drinking water management and the implementation of EU water legislation lie with the Ministry of Health. We are committed to ensuring full compliance with Estonian regulations and would appreciate the opportunity to discuss these matters further.

Thank you for your attention to this matter. We look forward to your response and the possibility of scheduling a meeting at your earliest convenience.

Kind regards,

Paweł Biśta

Head of East Europe Northern Countries