Skip to content
PhytAI
Sign in
Practice

QS-GAP irrigation water: risk analysis and water testing

QS-GAP requires a water quality risk analysis and a yearly water test for fruit and vegetables. What applies in 2026, when exceptions exist and what to record.

PhytAI editorial teamPublished 6 min read

Key points

  • Scope: water used before harvest, for example for irrigation, fertigation or as spray liquid.
  • Microbiological risk analysis (3.7.1, knock-out): assess application method, crop, water origin, timing, possible contamination and abstraction points.
  • Water analysis: at least one per year by a laboratory accredited to ISO 17025; limit for Escherichia coli below 1,000 CFU per 100 ml.
  • Exception: according to the decision tree in the QS guidance document, an analysis can be omitted, for example for crops that are not eaten raw or where the harvested produce does not come into contact with water.
  • Chemical and physical (3.7.2): a separate risk analysis that sets the number of analyses.
  • Water management (3.8): abstraction permit, recording conditions, environmental risk analysis and water management plan.

Try PhytAI free for 30 days

  • No payment details needed
  • Export all your data as CSV, JSON and Shapefile at any time
  • from €59.00 a year
Try free for 30 days

Anyone selling fruit, vegetables or potatoes within the German QS scheme will be asked about water during the audit: where does the irrigation water come from, how high is the risk of contamination and where is the laboratory analysis? The guideline QS-GAP Production of Fruit, Vegetables and Potatoes in the version of 1 January 2026 covers this in chapters 3.7 and 3.8. This article explains the requirements, the clarification on exceptions added in 2026, and how to keep the evidence so that it can be found quickly during an audit.

What the requirements apply to

Chapter 3.7 of the guideline refers to water used before harvest. It names irrigation, fertigation and spray liquid for plant protection products. Water for washing or cooling after harvest is covered elsewhere.

Microbiological water quality risk analysis

Criterion 3.7.1 is marked as a knock-out criterion in the guideline. It requires a risk analysis of microbiological hazards, taking into account:

  • the application method, such as overhead irrigation or drip irrigation
  • the crop
  • the origin of the water, such as a well, surface water, rainwater storage or the public supply
  • the timing of application, i.e. crop stage and time to harvest
  • possible contamination of water sources, storage and distribution systems
  • abstraction points that may be affected, for example by inflow from sewage treatment plants

A good risk analysis is short and concrete. For each water source it describes which crops are irrigated with it and how, which hazards exist and how high the risk is judged to be. From this follows how often, where and when samples are taken.

Water analysis

Based on the risk analysis, water analyses must be carried out by laboratories accredited to ISO 17025. The guideline requires at least one water analysis per year and sets the limit Escherichia coli below 1,000 CFU per 100 ml.

The sampling point and time are also derived from the risk analysis. The sample should be taken at a representative outlet of the irrigation system, i.e. where the water reaches the crop, not just at the wellhead. Analyses from drinking, bathing or surface water monitoring, for example water quality surveys, may also be used.

When an analysis can be omitted

New in the version of 1 January 2026 is a clarification: the minimum number can be departed from if the number of analyses is calculated with the decision tree of the QS guidance document on microbiological water quality risk analysis. According to it, an analysis can for example be omitted

  • if the water is used on crops not suitable for raw consumption that are always cooked before eating, such as potatoes, and/or
  • if the harvested produce does not come into contact with the water, for example with drip irrigation.

Important: the risk analysis itself remains mandatory. Omitting an analysis must follow traceably from it.

If the analysis shows a risk

If the water analysis shows a risk to food safety, plant parts suitable for raw consumption must not come into contact with the water. The farm must set and document corrective actions with deadlines. Possible actions include switching water source, changing to drip irrigation, treatment, or cleaning storage and pipes, followed by a follow-up test.

Chemical and physical water quality

Criterion 3.7.2 requires a second risk analysis of chemical and physical hazards using the same aspects. Here the risk analysis itself determines how many analyses are needed. If an analysis shows a risk to food safety, the water must not be used. The criterion is marked with a hash sign: in case of a deviation, the deadline for corrective action is at most 28 days.

Under 3.7.3, untreated wastewater must not be used. Treated, reclaimed wastewater is only permitted if it meets the minimum requirements of Regulation (EU) 2020/741.

Water management

Chapter 3.8 adds quantity and environment to quality:

  • Sustainable use (3.8.1): irrigation method and fertigation must make economic and ecological sense for the crop; water demand is determined from available information such as rain gauges or tensiometers.
  • Abstraction and discharge (3.8.2, knock-out): any required permit must be in place, and conditions such as abstraction volumes must be recorded and documented. More in Water abstraction for irrigation in Germany.
  • Environmental impact (3.8.3): a risk analysis considers the effects of irrigation and discharge on the environment and surroundings; the intended use is recorded in a water management plan, for which the abstraction permit can also be used.

Maintenance of irrigation equipment

Under criterion 2.2.3, irrigation systems, like other equipment affecting food safety or the environment, must be kept in good condition and serviced at least once a year by qualified persons, with date and type of service recorded. Invoices count as evidence.

Common mistakes

  • risk analysis exists but does not refer to the actual water sources and crops
  • sample taken at the well instead of at the outlet
  • laboratory without ISO 17025 accreditation commissioned
  • analysis omitted without the risk analysis justifying it
  • limit exceeded, but no corrective action with a deadline documented
  • new water source used, risk analysis not updated

How to proceed on the farm

  1. List water sources: every source with origin, storage and distribution.
  2. Write risk analyses: microbiological and chemical-physical, per source and crop group.
  3. Plan analyses: derive number, place and time from the risk analysis and commission an accredited laboratory.
  4. File results: report with date, sampling point and assessment.
  5. Document actions: if there is a finding, record action, deadline and follow-up test.
  6. Review yearly: update the risk analysis before the season.

Water quality in PhytAI

PhytAI keeps water sources with permit and meter readings. For each source, risk assessments and water analyses can be filed with file, laboratory, date and conclusion: "no action" or "action required". The due date is calculated with twelve months by default and appears among open tasks. PhytAI does not check limit values itself: limits depend on crop, irrigation method and scheme, so PhytAI stores result and assessment as recorded by the laboratory and the farm.

Frequently asked questions

Is the water supplier's drinking water analysis enough? According to the guideline, analyses from drinking water monitoring may be used. The risk analysis must still exist, and pipes and storage on the farm can carry their own risks.

Do I need an analysis with drip irrigation? According to the decision tree in the QS guidance document it can be omitted if the harvested produce does not come into contact with water. The risk analysis must justify this.

Does this also apply to GLOBALG.A.P.? GLOBALG.A.P. has its own water criteria. Farms holding both standards should set up the risk analysis so that it covers both.

Sources

This article reflects the situation on the date shown, based on the sources named, and is not legal advice. Laws, approvals, official decisions and the guidance of the competent authorities prevail.

Related articles

All articles on the blog