From 12 January 2026, a limit value for the industrial chemical group of per- and polyfluoroalkyl substances ("PFAS") in drinking water applies in Germany for the first time. The new requirements are of great importance across sectors.
Overview and regulatory context
The Drinking Water Ordinance (Trinkwasserverordnung - TrinkwV)1 regulates the protection and quality of drinking water, water treatment, the obligations of water suppliers and monitoring. The recast version of the TrinkwV, which came into force on 24 June 2023, implements the EU Drinking Water Directive (TrinkwRL)2. It brings far-reaching changes for the monitoring and protection of drinking water quality. The focus is on a risk-based approach to the protection of drinking water that obliges water suppliers to identify and manage risks at an early stage, as well as on the expansion of chemical monitoring.
Chemical monitoring now also includes limit values for PFAS, also known as "forever chemicals".3 For the first time, limit values are being introduced for certain PFAS compounds in the form of sum parameters. In the first stage a limit level for a group of 20 PFAS substances relevant to drinking water ("sum of PFAS-20") will apply from 12 January 2026, and the second for four others ("sum of PFAS-4") from 12 January 2028. In addition, the risk-based approach is expanded and water suppliers will have to comply with extended reporting requirements as well as new testing, documentation and information requirements. The amendment may also have significant indirect legal consequences for indirect dischargers of PFAS, such as industrial facilities. For example, the introduction of systematic monitoring could result in the issue of liability and recourse claims becoming increasingly relevant.
Relevance of PFAS
The term PFAS refers to a group of more than 10,000 industrially manufactured substances. Since the 1950s, they have been used in many products, including consumer goods4, and many industrial processes5, due in particular to their water, dirt and grease-repellent properties.
However, the same properties that make PFAS useful also present significant challenges. PFAS are highly persistent in the environment and do not break down under normal conditions. Some PFAS are bioaccumulative and over time concentrations build up in humans and the environment, including groundwater and surface water. Due to the potential risks to health and the environment, as well as their widespread use, PFAS are becoming a key issue in regulation of chemical substances and, increasingly, in the context of drinking water protection.6
The most important points of the amendment with regard to PFAS
Introduction of new parameters and limit values for PFAS
From 12 January 2026, a sum parameter with a limit value of 0.1 micrograms per litre (µg/L) will apply to a group of 20 PFAS substances relevant to drinking water ("sum of PFAS-20").7 From 12 January 2028, an additional limit value of 0.02 µg/L will apply for the sum of four PFAS substances considered to be particularly toxic ("sum of PFAS-4"): perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), perfluorohexane sulfonic acid (PFHxS) and perfluorooctane sulfonic acid (PFOS).8
The introduction of the sum of PFAS-20 parameter for the individual compounds listed in Annex 2, Part I9 is directly attributable to the EU Drinking Water Directive.10 Under the Directive, each Member State could choose either a limit value for the sum of the 20 individual compounds (0.1 µg/L for parameter "Sum of PFAS") or a broader limit for all PFAS (0.5 µg/L for parameter "PFAS Total"). Germany opted the more stringent limit value for 20 individual compounds, known as the "sum of PFAS-20" parameter.11
The additional limit value applying from 2028 for the parameter "sum of PFAS-4" goes beyond the requirements of the EU Drinking Water Directive and is based on the tolerable weekly intake (TWI) of 4.4 nanograms per kilogram of body weight set by the European Food Safety Authority (EFSA). In addition to foods such as fish, fruit, eggs and egg products, the EFSA also considers drinking water to be a relevant source of exposure to PFAS. According to the EFSA, parts of the EU population currently consume more than the tolerable weekly intake of PFAS. The "sum of PFAS-4" parameter is intended to reduce the amount of these four PFAS entering drinking water catchment areas and raw water.12
The regulations are structured to ensure compliance with the respective limit values even if only a subset of PFAS compounds is present. The toxicological assessment is supplemented by a structured designation of concentrations to allow targeted measures aimed at tackling particularly risky substances.
In line with the EU Drinking Water Directive13 and following extensive consultation with Member States, the European Commission issued technical guidelines for PFAS monitoring methods,14 considered to be optimal based on technical and socio-economic assessments.15
Extension of the risk-based approach
The recast version maintains and extends the risk-based approach, now encompassing not only the identification of risks, but also active management of those risks along the entire drinking water supply chain. All relevant areas are systematically included in the investigation and monitoring of potential hazards to water quality (e.g. from PFAS), starting with water abstraction in the catchment areas for drinking water production via abstraction points, through to treatment, storage and finally distribution. The aim is to identify risks at an early stage and to develop and implement appropriate measures to ensure the long-term safety of drinking water.16
Risk management for catchment areas of drinking water abstraction points is governed by the Drinking Water Catchment Area Ordinance (TrinkwEGV), which implements the EU Drinking Water Directive. The Ordinance serves to protect groundwater, surface water and raw water in drinking water catchment areas against the risks posed by PFAS and to reduce the effort required for the necessary treatment of drinking water. The TrinkwV and TrinkwEGV mark a shift away from considering drinking water quality in terms of endpoint control and towards a process-based approach that takes conservation of resources into account as well.17
Extended testing, information and reporting obligations
Water suppliers are now subject to comprehensive documentation and public disclosure obligations regarding all drinking water investigations, including PFAS contamination. This also includes recording and publishing any exceedances of limit values and the measures taken to ensure water quality.18 In addition, consumers must be actively, promptly and comprehensively informed if any limit values relevant to health, such as this applying to PFAS, are exceeded. The information must clearly state which substances are involved, what the potential risks are and what protective measures are being taken.19 These obligations increase transparency and are intended to serve consumer protection.
Practical implications of the amendment and outlook for the future
Operators of water supply facilities must establish suitable analysis procedures and comply with the new PFAS limit values. Investments in complex and new technologies for water treatment and monitoring have become necessary or will become necessary. The disposal of waste containing PFAS may pose an additional challenge. Violations of the new requirements can lead to regulatory measures and liability risks. Generally, and independently of the new limits that will apply from the beginning of 2026 and 2028, under Section 7 (1) TrinkwV drinking water must not contain concentrations of any chemical substances which give cause for concern about adverse effects on human health.
The new requirements for testing, reporting and disclosures of documentation to public authorities and the general public under the TrinkwV and TrinkwEGV will improve the data available on PFAS in drinking water in Germany. Based on the improved data, further regulatory or legislative measures could possibly follow. For indirect dischargers of PFAS, questions arise in particular regarding the consequential regulatory and liability risks. The subject of PFAS will continue to be a high priority on the agenda throughout various sectors.
Global Context
In Europe, several countries like for instance Denmark, Austria, Spain and Hungary have – like Germany – opted against adopting the EU Drinking Water Directives's parameter PFAS Total and, instead, adopted the EU Drinking Water Directives's parameter Sum of PFAS. Internationally, regulatory responses to PFAS in drinking water continue to evolve. In 2025, the US Environmental Protection Agency announced it would partially roll back its PFAS drinking water rule in 2025 (see here). In other countries, there is increasing pressure to introduce more stringent regulations, such as updated guidelines in Australia and the recommendations of the Cunliffe Report in the UK (see here).
1 Ordinance on the Quality of Water Intended for Human Consumption (Verordnung über die Qualität von Wasser für den menschlichen Gebrauch) of 20 June 2023, Federal Law Gazette 2023 I No. 159, p. 2, which entered into force on 24 June 2023.
2 Directive (EU) 2020/2184 of the European Parliament and of the Council of 16 December 2020 on the quality of water intended for human consumption (recast), which entered into force on 12 January 2021.
3 Other substances, such as bisphenol A, chlorate, chlorite, haloacetic acids (HAA-5) and microcystin-LR, are also included in chemical monitoring for the first time (see Annex 2 Part I TrinkwV). In addition, existing limit values for the heavy metals chromium, arsenic and lead are to be lowered in stages (see Annex 2 TrinkwV) and the replacement or decommissioning of old lead pipes will be required by 12 January 2026 (see Section 17 (1) TrinkwV).
4 For example, in cooking pots, rain jackets, cosmetics and heart implants, as well as plant protection products and active pharmaceutical ingredients.
5 For example, as hydraulic fluids or in battery and chip manufacturing. The scientific assessment of PFAS is still ongoing.
6 See German Bundestag, Aktueller Begriff – PFAS: Wirkung auf Mensch und Umwelt sowie Regulierung [PFAS: Effects on humans and the environment as well as regulation] https://www.bundestag.de/resource/blob/1107146/pfas.pdf (5 December 2025). For information on the risks posed by PFAS in drinking water, see also FAZ, 4 January 2025, "Ewigkeitschemikalien – Gefahr für Ungeborene?"[Eternal chemicals – a danger to unborn children?] https://www.faz.net/aktuell/wissen/medizin-ernaehrung/wie-schaedlich-sind-ewigkeitschemikalien-im-trinkwasser-fuer-babys-accg-110810853.html.
7 Section 7(2), Annex 2 Part I TrinkwV.
8 Section 7 (2), Annex 2 Part I TrinkwV.
9 Perfluorobutanoic acid (PFBA), perfluoropentanoic acid (PFPeA), perfluorohexanoic acid (PFHxA), perfluoroheptanoic acid (PFHpA), perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), perfluorodecanoic acid (PFDA), perfluoroundecanoic acid (PFUnDA), perfluorododecanoic acid (PFDoDA), perfluorotridecanoic acid (PFTrDA), perfluorobutane sulfonic acid (PFBS), perfluoropentane sulfonic acid (PFPeS), perfluorohexane sulfonic acid (PFHxS), perfluoroheptane sulfonic acid (PFHpS), perfluorooctane sulfonic acid (PFOS), perfluorononane sulfonic acid (PFNS), perfluorodecane sulfonic acid (PFDS), perfluoroundecane sulfonic acid (PFUnDS), perfluorododecane sulfonic acid (PFDoDS) and perfluorotridecane sulfonic acid (PFTrDS).
10 See Annex III, Part B, Point 3 of the Drinking Water Directive.
11 See Annex I, Part B, Total PFAS.
12 See German Bundestag, Current term – PFAS: Effects on humans and the environment and regulation https://www.bundestag.de/resource/blob/1107146/pfas.pdf (5 December 2025).
13 See Art. 13(7) Drinking Water Directive.
14 European Commission, Technical guidelines regarding methods of analysis for monitoring of per- and polyfluoroalkyl substances (PFAS) in water intended for human consumption, C/2024/4910, EU OJ C of 7 August 2024 https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=OJ:C_202404910&qid=1764940765308 (5 December 2025).
15 European Commission, Drinking Water, https://environment.ec.europa.eu/topics/water/drinking-water_en (5 December 2025).
16 Part 7 of the TrinkwV.
17 See LAWA Bund/Länder-Arbeitsgemeinschaft Wasser, Vollzugshilfe zur Umsetzung der Trinkwassereinzugsgebieteverordnung – TrinkwEGV [LAWA Federal/State Working Group on Water, Practical guidelines for the implementation of the Drinking Water Catchment Area Ordinance], p. 7.
18 Section 45 TrinkwV.
19 Section 46 TrinkwV.
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