Publication of the Order of 8 July 2024 on water reused in industrial food companies

On 9 July 2024, the decree of 8 July 2024 on water reused for the preparation, processing and conservation of all foodstuffs and goods intended for human consumption was published in the JORF.

This order concerns operators who carry out activities relating to the preparation, processing and preservation of foodstuffs.

It defines the categories of use and the procedures for declaration and authorisation of the production and use of water unfit for human consumption reused for the preparation, processing and preservation of any foodstuffs intended for human consumption, as well as the quality requirements applicable to such water.

Under certain conditions, companies can use recycled water from raw materials and recycled process water as an ingredient in the composition of final foodstuffs.

The use of recycled water from raw materials, recycled process water and recycled treated wastewater is possible subject to compliance with the conditions set out in the decree, whether :

• Direct contact with a processed or unprocessed product during transport, preparation and storage, and for which no subsequent stage is capable of controlling the hazards likely to be incorporated by this water.
• In direct contact with a processed or unprocessed product during the preparation, storage and transport stages, and for which there is a subsequent stage capable of controlling the hazards likely to be incorporated by this water
• Indirect contact with a processed or unprocessed product during the transport, preparation and storage stages and for which no subsequent stage is capable of controlling the hazards likely to be incorporated by this water.
•  Indirect contact with a processed or unprocessed product during the transport, preparation and storage stages, and for which there is a subsequent stage capable of controlling the hazards likely to be incorporated by this water.
• No direct or indirect contact with processed or unprocessed products during transport, preparation or storage.

At the end of the wastewater treatment plant, the operator must characterise the quality of the raw water used to produce recycled treated wastewater and, in particular, identify the pollutants by referring to the regulated parameters for HWW that are subject to a quality limit in the Order of 11 January 2007, the microbiological criteria defined in Regulation (EC) N°2073/2005 and the regulated contaminants defined in Regulation (EU) 2023/915.

It must also identify any other biological or chemical agents on the basis of potential inputs that are likely to compromise food safety, such as: the chemicals used on the site concerned, any treatment of recycled water, during the food preparation process and in particular during the cleaning of installations and the maintenance of premises and equipment, the various hazards that may be introduced by raw materials or packaging or that may be released from the materials making up the equipment used in the food preparation process, the by-products that may be formed from these various inputs.

Recycled treated wastewater and recycled water from raw materials and recycled process water must meet the criteria defined in Annex 2 of the Order.

This order is directly applicable.

Phytocontrol is nationally approved by the Ministry of Health and the Environment to carry out sampling and analysis for water health control.

Details of our accreditations can be found in our COFRAC technical appendix N°1-6066.

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