Aqua Europa
AE
Aqua Europa is representing the water technologies industries on European level.
ID: 986379335268-59
Lobbying Activity
Response to European Water Resilience Strategy
4 Mar 2025
As a member of the European Drinking Water industry initiative, we are sending our attached statement on behalf of the initiative and its other members (see document in the annex). European Drinking Water (EDW) is an alliance of 32 trade associations representing industries supplying products or materials used in drinking water applications and municipal drinking water supply within the European Union. With the broad knowledge of its members, covering both the individual elements of the supply chain and the wide range of drinking water applications, that initiative has established itself as the voice of the industry and is now a recognised partner for legislators, regulators and other stakeholders. We welcome a new EU-strategy for water resilience and the opportunity to provide comments to the call for evidence on the strategy (see document in the annex).
Read full responseResponse to Measures to reduce microplastic pollution
17 Jan 2024
Aqua Europa AISBL welcomes the possibility to bring in our position towards the pro-posed regulation on preventing plastic pellet losses to reduce microplastic pollution. We are supporting the target of reducing microplastic reduction, also a very important and meaningful target for the water industry to secure the quality of the most important resource: water. In our point of view a clean and affordable drinking water supply in the European Un-ion depends on the availability of products manufactured from plastic pellets. The whole water industry, starting from water production (well construction, water treat-ment in waterworks, etc.) to public water distribution networks over to the drinking water installations in buildings, relies on piping, fittings, sensors, control equipment and treatment or conditioning devices fully or partly made from plastic pellets. From our perspective two aspects should be strongly considered when finalizing the draft regulation: - Increase enforcement capacity instead of notification obligations - Provide further guidance and examples
Read full responseResponse to Revision of Regulation (EC) 648/2004 on Detergents
27 Jul 2023
Aqua Europa is representing the water technologies industries on European level. It is monitoring all industrial and technolgical and environmental legislation relating to the water and wastewater technologies industry. Aqua Europa supports the revision of Regulation (EC) 648/2004 on detergents and surfactants and welcomes the possibility to bring in its position. The safe use of detergents, a high-environmental performance, and a reduction in use of detergents and surfactants are also important and meaningful targets for the water industry. Due to the interdependencies between water quality and the use of detergents and surfactants we endorse a clarification as regards the determination of the medium water hardness to 2,5 millimoles CaCO3/l: In the Regulation, or at least in accompanying documents, it should be clarified that the unit millimoles CaCO3/l must be considered as an equivalent to the total water hardness. Whereby total hardness is considered as the sum of alkaline earth salts. To prevent further uncertainties, the regulation or accompanying documents, should contain a conversion table between commonly used units for water hardness such as °dH or ° fH.
Read full responseResponse to Introducing new hazard classes–CLP revision
18 Oct 2022
We reject the contemplated implementation of new hazard classes without alignment with the UN-GHS regime. Activities on the introduction of new hazard classes must be done under the leadership of UN GHS and OECD. The Commission’s proposal, therefore, does not contribute to the goal of achieving global harmonisation as pursued by UN GHS.
In particular the proposed hazard classes for vPvB and vPvM substances seem to deviate from the OECD definition of “hazard” and is lacking a profound scientific basis linked to the intrinsic properties of substances. We would like to recall that CLP does not contain any legal basis for substance specific exemptions from classification requirements (besides generic exemptions as provided for in Article 2 CLP). This would result in a scenario that substances need to be classified and labelled due to e.g. vPvM properties although no relevant physical, health or environmental hazard similar or comparable to the hazard classes defined in CLP as of today is involved (e.g. even water would qualify as vPvM substance).
In addition, we submit that the introduction of new hazard classes will have further impacts on a broad variety of other regulations (including REACH, BPR, DWD, etc.) so that the weak and non-convincing basis for the new hazard classes is likely to result in misleading and non-science-based regulations in the EU. This is not in line with principles referred to in the Green Deal and the Chemicals Strategy for Sustainability.
We, therefore, support the comments and objections on the draft delegated regulation as submitted by other business associations, like the Federation of German Industries or VCI.
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