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Would you like to treat drinking water without silver or silver ions? In Germany, the regulatory basis changed in 2017: since the 19th announcement in December 2017, silver and silver chloride have no longer been listed in the former list of permitted treatment substances under section 11 of the German Drinking Water Ordinance. Today's membraclean drinking-water products work without silver; their active substance is active chlorine released from hypochlorous acid.
This treats germs in the water and gradually breaks down biofilm in the tanks and pipes being treated. Our activity table compares the pathogen groups shown.
Silver and silver chloride: change since 2017
Up to the 18th announcement of the former list under section 11 of the German Drinking Water Ordinance, silver and silver chloride were still listed for a narrowly defined purpose: preserving stored water in certain water-supply systems and only in exceptional cases of non-systematic use.
With the 19th announcement in December 2017, silver and silver chloride were removed from that list. Since then, they have no longer been listed there as permitted treatment substances for that purpose.
What the current German Drinking Water Ordinance requires
The German Drinking Water Ordinance in force since 2023 regulates treatment in sections 18 to 22. Under section 19(3), treatment substances and disinfection methods may generally only be used if they are included in the list maintained by the German Environment Agency (UBA) under section 20. The current section-20 list does not list silver or silver chloride as treatment substances.
The current chemical parameter lists of the German Drinking Water Ordinance also contain no separate limit value for silver. For any specific product, however, the active substance, intended use, product type and the applicable biocidal and drinking-water rules remain decisive. Outside Germany, the applicable national requirements must also be observed.
What the WHO says about silver for drinking-water disinfection
The World Health Organization (WHO) takes a cautious view of silver as a primary disinfectant for drinking water. Its technical document “Alternative drinking-water disinfectants: bromine, iodine and silver” concludes that, because of significant data and performance gaps, silver is not recommended at this time for use as a primary disinfectant in drinking-water supplies.
For point-of-use applications, WHO likewise points to insufficient evidence: on the evidence reviewed, silver did not appear to meet the WHO minimum performance recommendations for such treatment products. The technical document cites, among other factors, limited efficacy data across different groups of microorganisms and often long contact times. The current WHO Guidelines for drinking-water quality provide the broader framework for drinking-water quality; the detailed assessment of silver is set out in the WHO technical document cited above. For membraclean, this is another reason not to rely on silver for drinking-water treatment, but on a product line designed for this purpose using active chlorine released from hypochlorous acid.
Why membraclean works without silver
membraclean drinking-water products contain neither silver, silver ions nor silver nitrate. The active substance is active chlorine released from hypochlorous acid. This gives us a clearly defined silver-free product strategy for drinking-water treatment, disinfection and the gradual breakdown of biofilm in treated tanks and pipes.
The appropriate product line depends on the application: mobile tanks and motorhomes, boats and ships, animal husbandry or continuous dosing with membraclean TD.
Legal basis and primary sources
The decisive point is the exact legal basis, not a blanket statement that every conceivable use of silver is generally prohibited. For drinking-water treatment within the scope of the German Drinking Water Ordinance, the current UBA list under section 20 is the relevant reference.
The historical 18th list documents the former, narrowly limited entry for silver and silver chloride; the deletion followed with the 19th announcement in December 2017. The current German position follows in particular from sections 19 and 20 of the Drinking Water Ordinance and the current UBA list.
Interviews and independent articles
In addition to the primary sources, we link to two interviews from the camping sector in which Dr Michael Saefkow discusses criticism of silver in fresh-water tanks and active chlorine as an alternative.
- CamperStyle: expert interview with Dr Michael Saefkow on silver products in fresh-water tanks
- Womo.blog / YouTube: video interview with Dr Michael Saefkow
Related information and instructions
- Active chlorine and hypochlorous acid explained
- Biofilm in water tanks and pipework
- Drinking-water treatment: applications
- Instructions for use and dosage tables
Sources and further information
- German Environment Agency: 18th announcement of the former section-11 list (October 2015)
- German Environment Agency: current section-20 list of permitted treatment substances and disinfection methods
- German Drinking Water Ordinance: section 19
- German Drinking Water Ordinance: section 20
- EUR-Lex: Implementing Decision 2014/227/EU
- WHO: Guidelines for drinking-water quality, 4th edition with first, second and third addenda (2026)
- WHO: Alternative drinking-water disinfectants – bromine, iodine and silver


