Disinfection Byproducts in Drinking Water: What CCL 6 Signals for Food and Beverage, Personal Care, and Home Care Manufacturers

By Kristian Fried

Summary 

Disinfection byproducts (DBPs) have been regulated in public drinking water for nearly five decades. For most of that history, the food and beverage, personal care, and home care industries have engaged with DBPs primarily as a water quality concern for the public utilities that deliver process water to their facilities, rather than a matter directly affecting the manufacturers. 

The U.S. Environmental Protection Agency’s (EPA’s) draft Sixth Contaminant Candidate List (CCL 6) changes that calculus. By placing DBPs on the list as a group for evaluation, EPA is signaling that the current regulatory framework, which covers only a small fraction of the more than 700 DBPs identified in disinfected water, may be due for its first major revision since 2006. For industries that use municipal tap water as a process input, and potentially those which perform additional in-plant treatment before use, the emergence of novel, unregulated DBP classes warrants attention. And brands that use contract manufacturing organizations can outsource production, but they cannot outsource accountability. Renewed federal scrutiny of DBPs may also draw increased attention from consumer advocacy groups, warranting proactive DBP monitoring by manufacturers. 

Introduction: Why Process Water Users Need to Track the DBP Regulatory Debate 

On April 2, 2026, EPA published the draft CCL 6 under the Safe Drinking Water Act (SDWA). Disinfection byproducts appeared on the list as a continuing group designation, joined for the first time by microplastics and pharmaceuticals. The announcement drew public attention mainly to those two new additions; DBPs, as returning list members, were treated as background. That framing understates their significance for industries whose manufacturing operations depend on water. 

Food and beverage manufacturers use municipal tap water at every stage of the production chain: as an ingredient, as a processing and washing medium for raw agricultural inputs, and as a heat-transfer and cooling fluid. Personal care and home care product manufacturers similarly incorporate water as a primary raw material in emulsions, solutions, suspensions, and pastes. In all of these applications, the chemical composition of the incoming water, including the disinfectants used to treat it and the byproducts those disinfectants generate, is directly relevant to the quality, safety, and regulatory compliance of the finished product. Many manufacturing sites include additional treatment or purification steps before municipal water is used for product formulations, but new DBP analytes might challenge existing processes and technologies and thus require additional corporate focus on water as a critical resource. 

Looking Back: DBPs on CCL 1 through CCL 6 

The regulatory history of DBPs under the SDWA predates the CCL program entirely. EPA first regulated trihalomethanes in 1979, more than 15 years before the CCL was established by the 1996 SDWA Amendments. DBPs have appeared on every CCL since the program’s inception, making them the longest-tenured group on the list. The Stage 1 Disinfectants and Disinfection Byproducts Rule (1998) set enforceable Maximum Contaminant Levels (MCLs) for total trihalomethanes (TTHMs), five haloacetic acids (HAA5), bromate, and chlorite. The Stage 2 Rule (2006) tightened compliance monitoring by requiring locational running annual averages, targeting systems with the highest potential consumer exposure. 

Since 2006, the federal DBP framework has not been substantially updated. Over the same two decades, science has advanced considerably. More than 700 DBPs have been identified in disinfected drinking water. Critically, researchers have demonstrated that the regulated compounds (TTHMs and HAA5) are not necessarily the most biologically active members of the DBP family. Nitrogenous DBPs (N-DBPs) such as haloacetonitriles, halonitromethanes, and haloacetamides, and iodinated DBPs (I-DBPs), have attracted mounting scientific attention. Brominated haloacetic acids beyond the HAA5 set have also been identified as compounds of concern. 

CCL 5 (2022) carried DBPs as a group, alongside per- and polyfluoroalkyl substances (PFAS) and cyanotoxins. CCL 6 continues that designation while, per EPA’s “Chemical Contaminants” Technical Support Document for the draft CCL6, expanding the number of specific unregulated DBP compounds identified for further evaluation. The regulatory environment in which this expansion arrives is one in which a long-deferred Stage 3 DBP rulemaking (now called Microbial and Disinfection Byproduct (MDBP) Rule Revisions) has become increasingly plausible. 

What CCL 6 Means for Food and Beverage, Personal Care, and Home Care Manufacturers 

These industries share a common exposure pathway to the DBP regulatory story: they are downstream users of municipal water systems. Their obligations under the SDWA are indirect: the SDWA regulates public water systems, not the businesses they serve. But that structural distance from the regulatory framework does not translate into distance from the practical consequences and risks of evolving DBP standards. Several dimensions of the CCL 6 designation are immediately relevant. 

Water as a product input for food and beverage manufacturers: Many beverage manufacturers ensure that the water incorporated into their finished products meets quality specifications that go beyond SDWA MCL compliance, and they apply additional treatment to incoming municipal water before use. Reverse osmosis activated carbon filtration, deionization, and ultraviolet treatment are common pretreatment steps that remove or reduce existing DBPs from the incoming supply. Unregulated DBPs that are not currently monitored by utilities, including certain N-DBPs and I-DBPs, may still be present. Food and beverage manufacturers who currently validate against internal specifications should evaluate whether those standards adequately address the emerging DBP that EPA is now flagging for evaluation. 

Personal care and home care formulation water: Water is the largest single ingredient by weight in liquid personal care products (mouthwash, shampoos, conditioners, lotions, body washes) and home care formulations (dish soap, liquid detergents, surface cleaners). Operations typically specify water quality in terms of pH, hardness, conductivity, total dissolved solids, total organic carbon, and microbial limits, but DBP specifications are less commonly formalized. As awareness of unregulated DBPs and their potential health effects grows, there is increasing reason to incorporate DBP characterization into water quality standards for formulation, particularly for personal care products with incidental ingestion such as mouthwash and toothpaste. Manufacturers of home care products with potential for indirect food contact such as dish soap or cleaners for food processing surfaces, especially no-rinse cleaners and sanitizers, should be equally aware. 

Reputational and Supply Chain Considerations 

For consumer-facing industries, the reputational dimensions of the DBP story extend well beyond the SDWA compliance framework that applies directly only to public water systems. Several aspects are worth examining. 

• Reputation: As scientific literature increasingly characterizes certain unregulated DBPs, the presence of those compounds in finished water-based goods could become a basis for concerns among consumer advocacy groups. A federal MCL clearly does not apply to those products, but too often establishing the presence of a substance with known or suspected health implications is sufficient to create headlines. CCL 6’s formal recognition of the unregulated DBP class as an EPA priority could be cited as evidence that these compounds are “known concerns.” 

• Supply chain due diligence: Retailers and B2B customers are constantly updating substance restrictions for their supplier qualification programs. As unregulated DBPs gain regulatory visibility through the CCL process, buyers’ questionnaires may begin to reference DBP characterization as a quality standard. Companies that have not assessed their incoming water quality beyond SDWA compliance may find themselves disadvantaged in supplier audits. 

International regulatory divergence: The European Union and other jurisdictions apply different DBP standards to drinking water and to food-contact and cosmetic-grade water. Companies manufacturing for international markets, or sourcing from international suppliers, should assess whether the DBP profile of their process water meets the most stringent applicable standard across their distribution footprint, rather than defaulting to SDWA-only compliance. 

What Happens Next: The Regulatory Pipeline and Its Industry Implications 

The CCL process triggers a multistage federal pipeline with several near-term milestones that manufacturers in these sectors should monitor actively. 

UCMR 6 and expanded monitoring: Prior Unregulated Contaminant Monitoring Rule (UCMR) cycles have extended DBP monitoring beyond the HAA5 set. UCMR 4 required monitoring for nine haloacetic acids (HAA9), and the resulting national occurrence data set is now part of EPA’s evidence base for CCL 6. UCMR 6, expected in draft form later this year, may include additional unregulated DBP classes among its monitoring targets. For industries that rely on municipal supply water, UCMR 6 results from their serving utilities will provide the first systematic national picture of how prevalent unregulated DBPs actually are in the water streams entering manufacturing facilities. 

MDBP rulemaking prospects: The water treatment community has anticipated a Stage 3 Disinfectants and Disinfection Byproducts Rule for more than a decade. CCL 6’s continuation and expansion of the DBP group designation is the clearest recent indicator that EPA may be building toward a formal regulatory determination on specific unregulated compounds. An MDBP rule imposing new MCLs on N-DBPs or I-DBPs would require public utilities to modify treatment practices, potentially changing the DBP profile of the water delivered to manufacturing facilities. Companies that have built their in-plant water quality specifications and pre-treatment systems around the current regulatory baseline should begin scenario-planning for what a modified finished-water profile might mean for their formulations, processes, and specifications. 

Conclusions and Outlook 

The bottom line stated at the outset bears repeating: CCL 6 does not impose new compliance obligations on food and beverage, personal care, and home care manufacturers. The SDWA regulates public utilities, but the CCL 6 DBP listing is a signal that the federal baseline is likely to shift, and when it does, the shift will involve compounds that have not previously been the focus of systematic industrial process water monitoring. 

The industries addressed in this briefing share a structural vulnerability: their product quality is partly a function of the water quality provided by a regulated entity—the public utility—that they do not control. When the regulatory framework governing that utility expands, the downstream effects can reach into manufacturing specifications.  

Now is a good time to develop an informed position on unregulated DBPs. Manufacturers can characterize the DBP profile of their incoming process water to establish a baseline. Companies that apply in-plant disinfection or rechlorination steps should evaluate the DBP formation potential of those processes. Personal care and home care products companies should consider whether their water quality specifications explicitly address the categories of unregulated DBPs that EPA is now signaling for evaluation. 

Engaging in the discussion around DBPs in drinking water is not a compliance obligation—but it is an opportunity to help shape the regulatory landscape rather than simply inherit it. 

For companies looking to strengthen their product stewardship efforts, Integral Consulting Inc. can help with the technical and strategic expertise needed to act early and effectively. Dr. Kristian Fried helps industry partners navigate rapidly evolving science and regulatory landscapes surrounding consumer products. He translates complex toxicological and risk assessment science into clear, actionable product stewardship guidance. Dr. Fried worked in industry before becoming a consultant and has 19 years of global experience including engagements with U.S. and European regulatory agencies. He is board-certified by both the American Board of Toxicology and the European Register of Toxicologists. You can reach him at kfried@integral-corp.com.