Water in primary plant production: when can you analyse less often?

What has changed in version 2.0?

The circular on the use of water in primary plant production (reference PCCB/S1/1829373) received a new version on 09/10/2026. There are no major, general changes. The FASFC does add two relevant points:

• Fewer analyses during and after harvest: under certain conditions, you may lower the analysis frequency.
• Definition of treated water: an explanatory footnote clarifies what counts as treated water.

The circular provides guidance on complying with the hygiene requirements on water use laid down in Regulation (EC) No 852/2004 and Regulation (EC) No 183/2005.

Fewer analyses, under clear conditions

Do you use untreated water during or after harvest from a source that is vulnerable to contamination, such as surface water, collected rainwater or well water from shallow layers (< 10 m)? Then a high analysis frequency applies: at least two analyses per season.

After three consecutive years of compliant results, six analyses in total, you may reduce that frequency to one analysis per season.

Which uses are covered?

The relaxation only applies to the situations marked with footnote (b) in table 2 of the circular:

• Products intended for processing or for the fresh market (annex 1, part A): water use during and/or after harvest, such as the final wash and rinse, transport and sorting.
• Products eaten raw or ready for consumption (annex 1, part B): washing and rinsing of the products and of the packaging material during and/or after harvest, except for the final step.

Nothing changes for the final post-harvest stage of products eaten raw (for example the final rinse or wash): the stricter requirements for water of drinking water quality continue to apply. In other words, the relaxation does not automatically apply to every use of water.

When do you return to the normal frequency?

If you obtain a non-compliant result or the risk changes, you must apply the normal frequency again.

A similar option already existed for water that comes into contact with the edible part of products eaten raw before harvest: there, after two consecutive years of compliant results (four analyses in total), you can switch to one analysis per season.

What does ‘treated water’ mean?

The circular defines treated water as water that has undergone a physical, chemical or biological treatment to remove impurities and make it suitable for a specific use. Disinfection is one example.

This distinction matters: if you treat water from a vulnerable source, a medium frequency of at least one analysis per season applies instead of two.

What should your company do?

Review your analysis plan before you change the frequency:

• Water source: which water source do you use, and for which operations?
• Use: does your use fall under the situations marked with footnote (b) in table 2?
• Results: can you demonstrate three consecutive years of compliant results?
• Risk: has the risk changed since those analyses?

Our practical tip: record the justification for a lower analysis frequency in your self-checking system. That way it remains clear why your analysis plan fits your water use.

From guideline to a workable analysis plan

An appropriate analysis frequency starts with a clear view of your water sources, processes and risks. Want to know what this update means for your business? AMNorman helps you work out your risk assessment and analysis plan in a practical way.

Source: FASFC, Circular on the use of water in primary plant production, PCCB/S1/1829373, version 2.0 of 09/10/2026 (available in Dutch and French).