Important modifications regarding the KTW-BWGL

Important news: the German Environmental Agency UBA has now published the following important modifications regarding the KTW - BWGL:

  • Updated Recommendation on the Conformity attestation according to the German BWGL.
  • Extended transitional arrangements due to COVID19.

Please find the links to the official documents (German language only) and our informal translation of the most important parts below.

Official documents (in German language only)

Informal translations

Principle of product conformity attestation: (clause 6 of updated recommendation):

Due to the difficulties encountered in 2020 regarding the performance of initial inspections, external audits and the associated sampling of test specimens as a result of the COVID 19 pandemic, it is therefore possible that, regarding organic materials, the attestation of conformity of products or components - also in risk group P1 can be based on a type test until 21 March 2023. Test reports can be used for this purpose that were created for KTW test certificates.

As a prerequisite for this:

The test reports must have been issued after March 21st, 2013.

The recipe evaluation and the evaluation of the test results must be carried out on the basis of the KTW-BWGL or repeated if necessary.

Extended transitional arrangements due to the COVID-19 pandemic in 2020 (clause 4.2):

Due to the restrictions on the containment of COVID-19- pandemic only a limited number of initial inspections and audits by the certification bodies were possible. For this reason the certification bodies can use test reports on samples that were not taken by the certification bodies until 21 March 2023 for attestations of conformity according to the UBA recommendation. This enables them to make use of reports that have been issued as the basis for the withdrawn guidelines until March 21, 2023.

The condition is that such test reports must have been issued after 21 March 2013 (deadline ten years before the end of the transitional regime on 21 March 2023).

The recipe evaluations, as well as the evaluation of the hygienic aspects must be carried out according to the requirements of the KTW BWGL and must be repeated as such. For the evaluation of the recipe, the certification body must have the current formulation at hand.

If the evaluation shows that parameters should be tested that – according to the (withdrawn) guidelines were not needed to test in the migration waters, then still these reports can be considered as sufficient as basis for the attestation of conformity until March 21, 2023.

The Certification bodies should definitely inform the manufacturer about the missing listing of substances from the recipe or missing test results for individual substances.

However, at the end of this additional transitional period, certification bodies must - for all certified products - have undergone the initial inspections and use recent test reports, for assesements according to the recommendation for the conformity attestation.