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CORONAVIRUS UPDATES
Regulation 31 approval update.
Letter to Customers, 4th August 2025
Dear Valued Customer,
You will be aware the approval period for our tank liner product is coming to an end (56/4/796).
Whilst we have been working flat out for many months to ensure a seamless renewal, It has just been notified to us that our application has been approved but with very significant restrictions. Our 1000ltr tank liner product will no longer be approved for the supply of water for human consumption. It can be used for the provision of water for sanitary purposes only either stand alone or connected for infusion into the network provided it is not consumed. This change will apply from the point the updated approval is issued.
The functional specification and high quality of the product remain unchanged and our suppliers confirmed this in a letter submitted earlier this year. However, it has transpired that, without our knowledge or notification from the supplier, the specific formulation of the liner plastic (master batch resin formulation) had been upgraded in line with industry norms. This has only been established following checks by the Drinking Water Inspectorate in the last few weeks and unfortunately there has been insufficient time to understand and assess these formulation changes. The Water Supply (Water Quality) regulations, of which regulation31 is a part, does not allow for any product not specifically tested against the UK (or equivalent) standard to be approved.
We have already submitted the upgraded film for testing against the UK water standard. As a 100% food contact approved product in the UK, EU and, USA we are confident that the testing will confirm these liners are satisfactory and will meet the requirements of regulation 31, however the testing necessarily takes a minimum of eight weeks to complete.
For the avoidance of doubt, we make clear that these changes are extremely minor and the liner bags, are and were at all times, 100% food Grade, food contact approved, FDA Certified and manufactured in BRC AA standard clean room environment. In all other industries we supply, i.e. food manufacturers, pharmaceutical manufacturers, beverage manufacturers etc. these liners remain in full use and fully approved.
The situation regarding this approval has not been clear until now. We are alerting you and all of our other customers at the earliest opportunity but appreciate that this does not provide you with any time for alternative measures to be put in place.
We apologise most profoundly for this situation, and we are working as fast as possible to see it resolved. We would anticipate a restoration of our Reg 31 approval by the end of September beginning of October ’25 .
We are working with the DWI to ascertain what impact this will have on existing inventory. We will provide an update once this is clarified.
Please see the frequently asked questions section below also we will be posting this and any new information and questions to our website: www.emergencywater.co.uk/regulation-31
Frequently asked questions
Can we use existing liner bags that we have in stock to supply drinking water?
No, the updated approval will only allow for the supply of water for sanitation.
If there is an emergency in the industry, can we use the existing bags?
On the DWI website there is guidance in Advice Sheet 9 which may allow some instances when equipment can be used for non-approved purposes. The guidance requires that contact should be made with the appropriate inspector for the drinking water supplier involved.
Can the liners be used to supply consumers during routine mains repairs or network activities?
It can be used, but only for the provision of sanitary water. Drinking water would need to be supplied by other means.
How long will it take before the product reappears on the DWI List Of Approved Products For Use In Public Water Supply?
We must wait for the testing and assessment to be completed but we very much hope that the product will be reapproved by the end of September 2025.
Assuming the product is reapproved will we be able to use our stocks of liner bags?
We are working with the DWI to ascertain what impact this will have on existing inventory. We will provide an update once this is clarified.
When did you know that the bags had changed formulation?
10 days ago. The application for reapproval was submitted more than 3 months ago. This included a letter from our supplier confirming functional continuity. This product is already tested and regulated under the food standards regulations. The change only became apparent following an assessment of the data submitted to DWI a week and a half ago. The consequence of this was only communicated to us today August 4th.
Can I use the liner bags for water storage if I am not a water company?
Yes, if you are not a water company then Regulation 31 does not apply to you. The liner bag is a high quality food grade product.
Dose this suspension apply to the Arlington water carriers?
No, the 5l AWCs do not require approval under regulation 31 or WRAS. They are themselves a high quality food contact approved product.