The Polish Enamel Industry Association (SPPE) has joined efforts related to the implementation of new EU regulations that may have a significant negative impact on the enamel industry. As part of its support for the sector, SPPE sent a letter to the Department of Public Health, drawing attention to potential risks arising from the current regulatory situation.
The issue concerns the implementation of Directive (EU) 2020/2184 on the quality of water intended for human consumption and materials that come into contact with drinking water. In their current form, the draft implementing acts pose a risk of serious disruption to the market availability of enamelled domestic hot water tanks, commonly known as boilers.
A key issue is the absence of hafnium oxide (HfO₂) from the so-called “positive lists,” i.e., the lists of substances permitted for use in materials that come into contact with drinking water. In the proposed regulations, this element has not been included as a permitted component for use in enamel coatings applied to water storage tanks.
Meanwhile, hafnium naturally occurs as a trace impurity in zirconium oxide, a raw material whose use is permitted and which is essential for enamel coatings to achieve the required resistance to water. In practice, this means that with the current state of technology it is not possible to produce enamel intended for coating water tanks without using zirconium, and therefore without the presence of hafnium.
The attached letters also highlight a number of ambiguities in the proposed regulations and point out that some provisions are not aligned with current technological realities.
We encourage you to review the letter sent by SPPE to the Department of Public Health in Poland, as well as similar submissions prepared by the European Enamel Authority (EEA) and addressed to institutions at the European Union level.
20230720—Drinking-water-directive—Enamel-industry-position-paper
