Abstract. Recent investigations into convection in Europa's ice shell have been based on nonNewtonian (stress-dependent) or Newtonian (stress-independent) viscosity for water ice. However, despite the wide use of Newtonian convection, experimentally observed water ice flow is non-Newtonian, and analysis of stability against convection of the ice shell using updated flow laws has been only performed for non-Newtonian rheologies. Here we use the flow law proposed for diffusion creep to analyze the possibility of the onset of convection for Newtonian viscosity in relation to the thermal state of Europa. Our findings indicate that for diffusion creep convection might have started, but that significantly lower heat flows (and equivalently higher shell thicknesses) and/or grain sizes are required than for superplastic flow, which is the most probable flow mechanism if the ice shell is convective.