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Revision of lists of pollutants affecting surface and groundwaters

Environment

A recent fitness check concluded that water legislation is broadly fit for purpose, with room for improvement related to investments, implementation, integrating water into other policies, chemical pollution, administrative simplification and digitalisation. This initiative will address the findings in relation to chemical pollution and the obligation to review regularly priority substances and groundwater pollutants. This contributes to the zero pollution ambition of the European Green Deal.

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Public consultation

ID: 12662

Lobbying Activity

43 responses

Environmental groups urge stronger water pollution protections beyond Commission proposal

European Environmental Bureau, 13 Mar 2023

The EEB welcomes adding 24 PFAS and pesticides to priority substance lists but demands the Commission maintain the 20-year phase-out deadline for hazardous substances. They want threshold values for substance groups rather than individual chemicals and oppose separating drinking water and non-drinking water standards. They also call for expanded effect-based monitoring and mandatory groundwater biodiversity indicators.
This would maintain pressure on polluters and accelerate removal of toxic substances from water.
Chemical producers and industrial polluters face stricter monitoring requirements and faster compliance timelines.

Chemical industry urges risk-based approach to water pollutant listings

European Chemical Industry Council, 8 Mar 2023

Cefic requests that prioritization be based on risk assessment rather than chemical properties alone. They want listings to include only substances of EU-wide relevance with clearly identified risks through monitoring data. They seek better alignment with existing EU legislation like REACH and IED.
This would prevent overlap with existing measures and avoid new compliance costs for substances already regulated.
Environmental groups lose stronger protections as fewer substances would be regulated at EU level.

Chemical Industry Urges Risk-Based Approach to Water Pollutant Lists

European Chemical Industry Council, 19 Nov 2020

Cefic requests that pollutant lists include only substances with clearly identified EU-wide risks based on risk assessment. They want finalized dossiers with realistic timelines for stakeholder input and want substances to be assessed under REACH before water directive inclusion.
This would reduce their regulatory burden by avoiding duplicative assessments and limiting pollutant designations.
Environmental groups lose stronger protections against emerging water pollutants not yet regulated under REACH.

Pharma industry warns against less transparent EU water rules

European Federation of Pharmaceutical Industries and Associations, 14 Mar 2023

The industry opposes shifting powers to the Commission and demands closer agency collaboration. They also want the removal of generic limits for total pharmaceuticals in groundwater.
These changes would protect manufacturing permits and prevent new restrictions on production facilities.
European lawmakers would lose influence over standards because of the shift to delegated acts.

Consultation response

Orgalim – Europe's Technology Industries, 18 Nov 2020

Nowadays, only 40% of Europe’s waters are in good ecological health. Climate change, and competing water uses closely linked to population growth and insufficient water treatment, have been some of the main challenges determining the current status of Europe’s freshwaters. To alleviate these…

Pharmaceutical Industry Opposes Transfer of Water Pollutant List Powers to Commission

MEDICINES FOR EUROPE, 14 Mar 2023

The industry requests maintaining current legislative co-decision procedures rather than transferring power to adopt delegated acts to the Commission. They demand close collaboration between ECHA and EMA on pharmaceutical assessments and continued stakeholder involvement in working groups. They also request removal of the proposed groundwater standard for total pharmaceuticals.
This would preserve their influence over pharmaceutical pollution standards and prevent stricter monitoring requirements.
Environmental and public health advocates lose stronger protections against pharmaceutical pollution in water sources.

Eurometaux urges risk-based standards for EU water pollutant lists

EUROMETAUX, 14 Mar 2023

Eurometaux recommends a formalised dialogue between regulators and experts and an unambiguously risk-based approach for quality standards. They also call for robust socio-economic impact assessments and maintaining the ordinary legislative procedure for revisions.
Economic impact assessments and procedural predictability would help the industry minimize new compliance costs.
Environmental advocates face a slower and more complex process for restricting dangerous water pollutants.

Eurometaux demands scientific approach to water pollution rules

EUROMETAUX, 20 Nov 2020

Eurometaux requests that the Commission uses the best available science and finalizes technical guidance. They advocate for accounting for natural backgrounds and local environmental conditions in assessments.
This would reduce regulatory pressure by ensuring metal concentrations are assessed more accurately.
Environmental groups may see weaker standards as values vary across different regions.

CropLife Europe urges science-based revision of water pollutant lists

CropLife Europe, 8 Feb 2023

CropLife Europe accepts most pesticide standards but requests deleting unworkable total parameters. They urge aligning water legislation with existing science-based assessments for plant protection products.
This would prevent unjustified restrictions on the availability of crop protection products.
Environmental advocates lose monitoring data on the cumulative impact of pesticide mixtures.

SUEZ Group warns against rigid standards for aquifer recharge

SUEZ Group, 14 Mar 2023

SUEZ recommends that new pollution standards do not block the essential practice of recharging aquifers. They suggest using drinking water limits because proposed targets are currently impossible to measure.
The company avoids unachievable measurement requirements and maintains its existing water recharge operations.
Environmental protections are weakened by allowing higher pollutant levels during artificial groundwater replenishment.

VCI opposes expanding Commission powers over water pollutant standards

Verband der Chemischen Industrie e.V., 14 Mar 2023

VCI rejects the Commission using delegated acts to set harmonized water threshold values. They propose adding three management cycles to provide legal certainty after 2027. The group also seeks broader exemptions for industrial activities to prevent project delays.
These adjustments would reduce regulatory uncertainty and prevent costly delays for industrial projects.
Environmental protection groups lose if stricter pollutant standards and deadlines are significantly delayed.

Plastics Europe Urges Realistic Water Safety Standards for BPA

Plastics Europe, 14 Mar 2023

The group wants BPA listed as a priority substance, not a priority hazardous substance. They propose an attainable and enforceable target value of 0.01 µg/L.
This protects production sites from regulations requiring the total cessation of chemical emissions.
Water ecosystems and public health lose the protection of significantly stricter chemical safety limits.

Spanish business federation urges water pollution prevention at source

CEOE - Confederación Española de Organizaciones Empresariales, 13 Mar 2023

CEOE advocates for pollution prevention at the origin rather than downstream. They also urge the Commission to keep the existing process for listing priority substances.
The organization maintains a familiar regulatory framework while avoiding increased costs for wastewater treatment.
Environmental protection efforts are slowed by the retention of complex and outdated administrative procedures.

Consultation response

Wirtschaftsvereinigung Stahl, 20 Nov 2020

A recently carried out suitability test (assessment) of the EU water legislation showed that these legal provisions are largely fulfilling their purpose, according to the European Commission (COM) on its website “Integrated water management - revised lists of pollutants in surface water and…

BUND Urges Stricter EU Rules to Protect Groundwater Ecosystems

Bund für Umwelt und Naturschutz Deutschland e. V., 14 Mar 2023

BUND demands stronger protection for groundwater biodiversity and strict temperature criteria for thermal use. They also oppose deleting reporting requirements and call for more substances on observation lists.
These measures would ensure long-term drinking water quality and functional groundwater ecosystems.
Pesticide and chemical producers would face tougher limits and stricter emission monitoring requirements.

Self-care industry demands scientific rigor in EU water rules

Association of the European Self-Care Industry, 14 Mar 2023

The industry opposes the shift to delegated acts to preserve transparency. They request removing the aggregate limit for pharmaceuticals in groundwater. They demand that pollutant lists be based on high-quality scientific data.
This would protect existing manufacturing sites from potentially prohibitive new emission permits.
The European Parliament and Council lose their direct influence over pollutant revisions.

Surfrider Europe Demands Faster Phase-Out of Toxic Water Pollutants

SURFRIDER FOUNDATION EUROPE, 14 Mar 2023

The group opposes deleting the 20-year deadline for phasing out hazardous substances. They request monitoring chemical groups to better address toxic mixture effects.
Stricter legislation provides stronger protection for the marine environments they represent.
Chemical producers would bear higher monitoring costs and face stricter regulatory oversight.

Teva urges scientific rigor in EU water pollutant revisions

Teva Pharmaceuticals Europe BV, 14 Mar 2023

Teva requests that pollutant list revisions remain a co-decision procedure involving the Parliament and Council. They also argue for individual substance standards rather than blanket limits for pharmaceutical compounds.
Individual substance standards help Teva avoid blanket market restrictions on its pharmaceutical portfolio.
Patients may lose access to essential medicines if volume reductions meet environmental limits.

Chemours urges sound science for EU water pollutant lists

The Chemours Company, 12 Mar 2023

Chemours demands water quality targets based on sound science and predictable, proportionate requirements. They advocate for using Best Available Techniques under the Industrial Emissions Directive instead of strict limits.
This would prevent the enforcement of unattainable thresholds and reduce their immediate compliance costs.
Environmental regulators and ecosystems may suffer from the use of more harmful chemical substitutes.

Consultation response

European Federation of National Associations of Water Services, 17 Nov 2020

Drinking water and waste water services have an essential mission: ensure the supply of high quality drinking water and effectively treat waste water thus contributing to the protection of human health and the environment. We welcome the opportunity to share our views on the revision of the lists…

German metal industry warns against stricter EU water standards

WirtschaftsVereinigung Metalle, 14 Mar 2023

WVMetalle rejects the use of delegated acts for setting thresholds and calls for reforming the "One-out-all-out" principle. They also demand an impact assessment before reclassifying river-specific pollutants into the chemical status category.
Relaxing these rules would provide greater operational leeway for industrial and economic activities.
Environmental health suffers as weaker standards allow higher concentrations of industrial pollutants.

Dutch water authorities urge PFAS ban and source-based pollution control

Bureau Brussel Vewin - Unie van Waterschappen, 2 Feb 2023

The authorities support tightening standards and adding substances to the priority list. They demand a complete European ban on the production and use of PFAS. They also want deadlines aligned with updated laws for urban waste water treatment.
Targeted source control measures would help avoid additional treatment efforts at the pipe.
The pharmaceutical industry would be forced to reimburse costs for advanced wastewater treatment.

Consultation response

Jernkontoret, 20 Nov 2020

Please see attached file, Best regards, Sophie Carler

Consultation response

Bureau Brussel Vewin - Unie van Waterschappen, 20 Nov 2020

Reaction to roadmap by the Association of Dutch Water Authorities and the Association of Dutch Water Companies (Vewin) Drinking water and waste water services have an essential mission: ensure the supply of high quality drinking water and effectively treat waste water, thus contributing to…

Federchimica urges risk-based approach for EU water pollutant lists

Federazione Nazionale dell'Industria Chimica italiana, 13 Mar 2023

Federchimica requests that the prioritization of pollutants be based on risk assessments rather than just chemical properties. They argue that lists should only include substances of EU-wide relevance and that controversial proposed limits for Bisphenol A should be withdrawn.
The chemical industry would avoid the compliance costs and legal risks associated with monitoring exceedances of substances they deem harmless.
Local ecosystems and public health may receive less protection if certain substances are excluded from EU-wide monitoring lists.

Hospital pharmacists urge risk assessment before listing pharmaceutical pollutants

The European Association of Hospital Pharmacists, 14 Mar 2023

EAHP requests a prospective risk inventarisation before listing medicines to prevent unexpected therapy failure. They also advocate for waste measures and including toxicity information in package leaflets.
This would empower hospital pharmacists as policy advisors while unlocking EU financial support for their activities.
Patients may face health risks if restricted medications cause a shift toward broad-spectrum antibiotics.

Lead Association questions lack of transparency in pollutant reclassification

International Lead Association, 23 Nov 2022

The association expresses concerns about the lack of transparency in promoting lead to a hazardous substance. They question if lead meets the scientific criteria for concern regarding the aquatic environment.
Avoiding the hazardous designation prevents lead producers from facing more stringent environmental quality standards.
Environmental groups lose the stricter monitoring and protection levels associated with hazardous substance status.

Czech Chamber urges technical feasibility in new water rules

Hospodářská komora České republiky, 6 Mar 2023

The Chamber requests that the economic and technical limits of operators be considered. They propose completing existing regulatory revisions before finalizing this new directive.
Businesses would avoid excessive financial burdens and unrealistic technical compliance requirements.
Industrial operators and wastewater plants face massive investment and operational cost increases.

Consultation response

Nickel Institute, 14 Mar 2023

Please find attached the feedback of the Nickel Institute on the revision of the Nickel Environmental Quality Standard.

Swedish miners urge flexible, risk-based water pollution standards

Swedish Association of Mines, Mineral and Metal Producers, 20 Nov 2020

Svemin requests a risk-based approach that accounts for local background concentrations of naturally occurring metals. They advocate for updated methodologies to prevent overestimating the biological impact of minerals. They also emphasize balancing environmental benefits with the economic costs of industrial operations.
Mining companies would avoid restrictive project bans and reduce their overall compliance costs.
Environmental ecosystems may lose protection if safety margins from the precautionary principle are reduced.

Consultation response

European Precious Metals Federation, 14 Mar 2023

Attached pdf summarises the EPMF comments on the recent EC proposal for amending the Water Framework Directive (WFD), the Environmental Quality Standard Directive (EQSD) and Groundwater Directive in the field of water policy. Since 2007, the European Precious Metals Federation (EPMF) has supported…

Consultation response

Clariant Produkte (Deutschland) GmbH, 13 Mar 2023

Clariant, Global Product Stewardship, does not agree with the listing of a naturally occurring substance like silver to be a priority substance under the Water Framework Directive. Only substances found to pose a significant risk to or via the aquatic environment should be considered for inclusion…

Hazardous Waste Europe backs stricter monitoring of water pollutants

Hazardous Waste Europe, 5 Jan 2023

HWE supports harmonizing water regulations and updating pollutant lists. They advocate for better monitoring and source separation to treat wastewater containing harmful substances.
Clearer monitoring rules for PFAS would provide treatment plants with legal certainty.
Industrial producers would face increased costs for required wastewater source separation.

Consultation response

ERM Coalition, 31 Jan 2023

The ERM Coalition of drinking water suppliers associations represent 170 water suppliers and 188 million drinking water consumers living in the river basins of Rhine and Ruhr, Danube, Elbe, Meuse and Scheldt depending on clean drinking water in 18 states including the 13 EU member states Austria,…

Consultation response

Polska Izba Przemysłu Chemicznego, 14 Mar 2023

Stanowisko Polskiej Izby Przemysłu Chemicznego znajduje się w załączonym pliku.

Consultation response

Österreichische Vereinigung für das Gas und Wasserfach, 23 Jan 2023

In the current draft, the three directives (WFD, GWD, EQS) are changed in one go, which contributes to the coherence between the directives. The directives are relevant to the drinking water supply insofar as they contain quality targets and monitoring obligations for groundwater and surface water.…

Consultation response

Arbeitsgemeinschaft der Wasserwirtschaftsverbände NRW, 14 Mar 2023

Die Wasserwirtschaftsverbände in NRW sind öffentlich-rechtliche Körperschaften, die auf sondergesetzlicher Grundlage oder als Wasserverband nach dem Wasserverbandsgesetz ihre Aufgaben in der Daseinsvorsorge wahrnehmen. Dazu gehören neben der Abwasserreinigung die Klärschlammentsorgung, die…

Consultation response

NICOLE, 14 Mar 2023

NICOLE is the only European network combining industry, service providers and academics, formed in 1996 with an aim to bring together professionals involved in sustainable risk-based management of land and water in Europe www.nicole.org. NICOLE has drafted this paper to reflect its opinion based on…

Consultation response

European Biocidal Silver Task Force, 13 Mar 2023

The European Biocidal Silver Task Force (the EU STF) takes note of the Commission's proposal to include silver in the Water Framework Directive (WFD)'s list of priority substances. The EU STF considers that: (a) the significant costs associated with including silver in the list will far outweigh…

Consultation response

Sveriges Kommuner och Regioner, 10 Mar 2023

Sveriges kommuner och Regioner, SKR (SALAR), instämmer i behovet av uppdaterade förteckningar över föroreningar som ska kontrolleras i yt- och grundvatten samt tillhörande gränsvärden. Befintliga beteckningar behöver anpassas till rådande föroreningsbild och kunskapsunderlag, inte minst när det…

Consultation response

Glyphosate Renewal Group, 27 Feb 2023

The Glyphosate Renewal Group (GRG) is a collection of companies seeking the renewal of the EU authorisation of the active substance glyphosate in 2023. To this end, the GRGs member companies join resources and efforts to prepare a single dossier with the scientific studies and information on the…

Consultation response

Vereniging van Rivierwaterbedrijven, 20 Nov 2020

As a member, RIWA would like to bring the position of the Coalition of the European River Memorandum (ERM) regarding the fitness check of the Water Framework Directive and its daughter directives under attention, as well as the list of micropollutants in European River Basins found in exceedance of…

Consultation response

Asociación Española de Abastecimientos de Agua y Saneamiento, 17 Nov 2020

Drinking water and waste water services have an essential mission: ensure the supply of high quality drinking water and effectively treat waste water thus contributing to the protection of human health and the environment. We welcome the opportunity to share our views on the revision of the lists…