OpenLobby.EU
Explore

Bureau Brussel Vewin - Unie van Waterschappen

UvW

Bureau Brussel represents Dutch water boards and drinking water companies on EU water policy and regulation.

Lobbying Activity

Meeting with Bas Eickhout (Member of the European Parliament)

10 Dec 2025 · Water policy

Meeting with Ingeborg Ter Laak (Member of the European Parliament) and Vereniging VNO-NCW

20 Nov 2025 · Water resilience

Dutch Water Authorities demand EU mandates for recycled materials

4 Nov 2025
Topic — The Circular Economy Act promotes sustainable production and recycling within the EU.
Message — The authorities urge the EU to implement mandatory blending quotas and minimum recycled content requirements. They also request a harmonized legal framework to help reclassify treated waste as valuable secondary resources.123
Why — New mandates would create a guaranteed market for materials recovered from wastewater.4
Impact — Virgin material producers lose their price advantage over recycled alternatives under these proposals.5
Read full response

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and Huis van de Nederlandse Provincies and Vereniging van Nederlandse Gemeenten

15 Oct 2025 · Address Pilot Event panel on Climate and Water Resilience

Response to Evaluation of the Measuring Instruments Directive

9 Oct 2025

The Association of Dutch water companies (Vewin) has read the questions from the European Commission regarding Directive 2014/32/EU regarding the Measuring Instruments Directive carefully. Vewin would like to react to this call for evidence, because the measuring instruments used by the Dutch drinking water companies would legally fall under the scope of this Directive. However, the Dutch government has chosen during the legislative implementation process in the Netherlands to exclude the measuring instruments used by the Dutch drinking water companies from the scope of this Directive. They have chosen for this legal approach due to the fact that the Dutch drinking water sector already had an exemplary self regulatory framework by then which guaranteed the protection of consumers who uses drinking water in the Netherlands. Therefore, the Netherlands has chosen to apply the "optionality"-provision within the Directive, Article 3, which allows them to exclude the applicability of this Directive due to reasons of public interest, public health, public safety, public order, protection of the environment, protection of consumers, etc. for certain sectors who use measuring instruments. This situation did not change in the following years after the introduction of the Directive. The Dutch drinking water companies are still able to guarantee the necessary standards for measuring instruments in regard to the protection of consumers within the Netherlands due to their high exemplary self regulatory framework. Vewin would, therefore, like to emphasize that the European Commission should keep this "optionality"-provision in a future revisioned or recasted Directive regarding measure instruments. This provides the Member States of the European Union the opportunity to decide, in line with the principle of subsidiarity enshrined in article 5(4) in the Treaty of the European Union, whether the available sectors in their territory that use measuring instruments, should comply with this Directive or should be entrusted to introduce a high exemplary self regulatory framework.
Read full response

Meeting with Jeannette Baljeu (Member of the European Parliament)

24 Sept 2025 · REACH, UWWTD, water

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

10 Sept 2025 · Water

Response to European climate resilience and risk management law

3 Sept 2025

The Netherlands is located in the river delta of the Meuse, Rhine, Scheldt, and Ems rivers. This means we are literally and figuratively connected with our neighboring countries in the shared responsibility of ensuring sufficient and clean water. After all, water does not respect borders, and the climate is changing. We are already experiencing its effects. | We must adapt to the new climate reality - climate adaptation. This requires making decisions without having full certainty on the scope or magnitude of climate change impacts. Moreover, the Netherlands is, to a significant extent, dependent on upstream decisions and their implementation. One critical example of necessary cross-border cooperation is the coordination of water distribution and the management of major European rivers. | It is crucial to map (systemic) interdependencies between Member States and to promote knowledge exchange and development to ensure a sustainable water supply. However, there are currently few agreements in cross-border river basins regarding water allocation during periods of drought or extremely low river discharges. | Establishing clear agreements about water allocation, will provide much-needed clarity. As water becomes increasingly scarce, reaching effective agreements will only become more important. Real-life examples include the construction of infrastructure such as the Canal Seine-Nord, which diverts significant volumes of water from the Meuse basin into the Scheldt basin, but also the recent pollution of the Meuse with propamocarb, a fungicide widely used in horticulture. Due to the extremely low discharge of the Meuse caused by drought, the pollution persists, which is why for four weeks now, water intake from the Meuse for drinking water supply has been halted. | It is essential to reach well-defined arrangements regarding the timely exchange of information throughout the entire international catchment areas of the Meuse, Rhine, Scheldt, and Ems rivers. These agreements should include, among other aspects, water allocation, as well as the construction, renovation, or modification of infrastructure such as reservoirs, weirs, and water diversions that could impact downstream water systems. Timely and transparent information-sharing is vital to anticipate cross-border effects and to ensure that decisions made upstream do not negatively affect water availability or quality downstream. This type of proactive coordination will become increasingly important as climate impacts intensify and water scarcity becomes more acute across Europe. | The Water Resilience Strategy should be used to enhance the coherence of EU legislation on water quality and water quantity, with the Water Framework Directive serving as its foundational framework. In many regions, drinking water utilities are heavily reliant on surface water sources, which are often subject to numerous potential threats. For these water bodies, like the rivers Meuse, Rhine, Scheldt, and Ems, a water quality that enables the production of drinking water, using the most natural purification methods possible, should be achieved. A report (file attached) on the level of water quality required was published by the ERM-coalition in 2020. Next to agreements on water quantity, similar arrangements should be established regarding water quality, since the two are intrinsically connected and must be addressed in conjunction with each other.
Read full response

Dutch water authorities urge EU to promote wastewater resource recovery

19 Jun 2025
Topic — The EU is developing a strategy for a sustainable, circular, and climate-neutral bioeconomy.
Message — The authorities request that the EU tackle harmful pollutants at the source. They call for standardized regulations and mandatory recycled content requirements. Finally, they want water and phosphate recognized as strategic resources.123
Why — Local resource recovery would reduce costs and dependency on volatile markets.4
Impact — Chemical and pharmaceutical manufacturers would face higher costs from stricter source-control.5
Read full response

Response to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU

24 Mar 2025

Positive Opinion on the Update of the List of Invasive Species: Statement on the initiative for the 'Update of the List of Invasive Species Threatening Biodiversity and Ecosystems Across the EU' and the amendment of Implementing Regulation (EU) 2016/1141 by the Unie van Waterschappen, The Netherlands Dear Sir/Madam, We have taken note of the consultation on the update of the list of invasive species threatening biodiversity and ecosystem services in the EU with great interest. We appreciate the initiative to extend this list and would like to respond with a positive opinion. We recognise the importance of effective policies on invasive species and support efforts to protect biodiversity and conserve ecosystems. A well-founded and up-to-date list is essential for an effective approach and to prevent further spread of harmful species in the EU. Thank you for your time and efforts. Kind regards, Dolf Moerkens Unie van Waterschappen dmoerkens@uvw.nl
Read full response

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

20 Mar 2025 · Water

Meeting with Dirk Gotink (Member of the European Parliament)

19 Mar 2025 · PFAS, Soil Monitoring Law

Meeting with Jeannette Baljeu (Member of the European Parliament)

12 Mar 2025 · EQSD, WFD, Water Resilience Strategy

Dutch water authorities urge more flexible and local procurement rules

6 Mar 2025
Topic — EU evaluation of the effectiveness and relevance of three public procurement directives.
Message — They request simplified procedures and higher threshold values to reduce administrative burdens. They advocate for flexible long-term partnerships and projects prioritizing quality and sustainability. They seek expanded options for local procurement to support regional small businesses.123
Why — Streamlining rules would reduce overhead and facilitate more stable, long-term infrastructure planning.45
Impact — Non-local competitors could face disadvantages if authorities prioritize regional suppliers and trusted bidders.67
Read full response

Dutch water authorities urge binding cross-border river basin agreements

4 Mar 2025
Topic — This initiative outlines a multi-annual plan to achieve a water resilient Europe.
Message — They advocate for binding agreements in river basins to ensure upstream activities do not harm downstream areas. They also emphasize tackling pollution at the source and strengthening regional water governance.12
Why — This strategy would protect Dutch water quality and availability from cross-border environmental risks.3
Impact — Upstream entities lose the power to unilaterally divert water or pollutants into shared basins.4
Read full response

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

13 Feb 2025 · Water Resilience

Meeting with Elisa Roller (Director Secretariat-General) and European Federation of National Associations of Water Services and Svenskt Vatten

10 Jan 2025 · PFAS in water

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)

4 Dec 2024 · Water

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

9 Oct 2024 · Water

Meeting with Jeannette Baljeu (Member of the European Parliament)

24 Sept 2024 · Water resilience strategy

Response to Environmental Implementation Review 2025

3 Jul 2024

De Vereniging van waterbedrijven in Nederland (Vewin) dankt de Europese Commissie voor de mogelijkheid om bij te dragen aan de herziening van de implementatie van het EU milieurecht (2025) en heeft de volgende opmerkingen op het gebied van (drink)water: 1. Onvoldoende actualisering van (lozings)vergunningen om doelen EU-richtlijnen te halen. Toelichting: Hierbij is de vraag naar de effectiviteit van Europeesrechtelijk milieurecht. Waarom is de herziening van lozingsvergunningen zo traag en worden vergunningen soms helemaal niet herzien om aan de doelstellingen van de richtlijnen zoals de Kaderrichtlijn Water en verordeningen te voldoen? Veel vergunningen zijn verouderd. In de tussentijd is het productieproces veranderd met allerlei nieuwe stoffen die niet in de vergunning zijn opgenomen. 2. Steeds meer algemene regels voor milieuactiviteiten in plaats van vergunningen zorgt voor minder zorgvuldige specifieke vergunningvoorschriften en goede handhaving Toelichting: In de filosofie van de nieuwe Nederlandse Omgevingswet zijn in het Omgevingsbesluit veel activiteiten uitgezonderd van de vergunningplicht, zoals lozingen naar oppervlaktewater en grondwater. Het Omgevingsbesluit bevat een limitatieve opsomming van vergunning plichtige lozingsactiviteiten: alles wat niet is aangewezen valt slechts onder algemene regels of is regelvrij/toegestaan. Dit betekent een omkering van de vorige oude hoofdregel lozen verboden, tenzij vergunning en is volgens ons in strijd met het vereiste van de Kaderrichtlijn Water om ten minste hetzelfde beschermingsniveau te handhaven. 3. Verhouding productaansprakelijkheid met het beginsel van de vervuiler betaalt. Toelichting: De uitvoering van het beginsel van de vervuiler betaalt wordt door de productaansprakelijkheid richtlijn ingewikkelder. Voor de drinkwaterbedrijven is het lastig om de vervuiler aansprakelijk te stellen, terwijl de maatstaf om hen aansprakelijk te stellen op grond van de productaansprakelijkheidsrichtlijn eenvoudiger is. Een consument die geen goed drinkwater ontvangt, kan een drinkwaterbedrijf op grond van de productaansprakelijkheidsrichtlijn aansprakelijk stellen. Alleen in de werkelijkheid is het drinkwaterbedrijf afhankelijk van een goede drinkwaterbron, maar de vervuiling vindt plaats door lozingen van chemische bedrijven/andere vervuilers. Hierdoor betaalt niet de vervuiler, maar de consument. 4. Invulling voorzorgsprincipe en omkering bewijslast Toelichting: Vewin is positief over de inzet van de Nederlandse regering om vanuit het voorzorgsprincipe een strikter regime door te voeren voor emissies van PFAS en F-Gassen. Bij deze emissies zijn gegronde redenen om aan te nemen dat er negatieve effecten zijn voor mens en milieu. Ook het creëren van een verplichting in regelgeving om aanvullende informatie aan te leveren bij het bevoegd gezag waaruit blijkt dat de risicos van ernstige gevolgen zich ondanks de onderbouwde aanwijzingen daarvoor (toch) niet voor kunnen doen, is een stap vooruit. 5. De dwingende reden van groot openbaar belang van energie ondermijnt de dwingende reden van groot openbaar belang van drinkwater Toelichting: de dwingende reden van groot openbaar belang van energie ondermijnt langzamerhand het belang van water. Zowel de EU-wetgever als de Nederlandse wetgever schiet hiermee uit de bocht.
Read full response

Dutch water boards demand stricter environmental oversight for RENURE

17 May 2024
Topic — The consultation concerns amending Nitrates Directive rules to include manure-derived nitrogen fertilizers.
Message — The organization insists that the proposal must not negatively impact Water Framework Directive goals. They recommend that an independent party evaluates environmental effects and nitrate program changes. Reporting should be used to impose consequences if RENURE use harms water quality.123
Why — Tighter controls would protect water quality and reduce risks from the production process.4
Impact — Farmers may face restricted access to RENURE if water quality goals are not met.56
Read full response

Vewin urges EU to prioritize drinking water in Nitrates Directive

8 Mar 2024
Topic — Evaluation of EU rules reducing water pollution from agricultural nitrates.
Message — Vewin demands the 50 mg/l nitrate limit applies specifically to drinking water extraction points. They seek better alignment with EU water laws to reduce purification efforts.12
Why — This would reduce operational costs by lowering the purification effort needed for drinking water.3
Impact — Farmers would face more stringent restrictions on fertilizer use near water extraction sites.4
Read full response

Response to Technical specifications for the preparation of risk management plans to ensure the safe reuse of treated waste water in

29 Jan 2024

In order to prevent the risks of contamination of drinking water sources and specifically the risks of PMT substances such as PFAS, which can end up in the aquifers and waterways from the use of urban wastewater, it is requested to prohibit the reuse of wastewater in vulnerable areas such as groundwater protection areas. This protection is also in line with the proposal for a directive amending the EU Water Framework Directive, the Groundwater Directive and the Environmental Quality Standards Directive, which aims to protect groundwater and surface water (and abstraction points of water intended for human consumption) against substances such as PFAS. It also fits with Article 8 of the EU Drinking Water Directive, which prescribes risk assessment and risk management of the river basins.
Read full response

Response to 8th Environment Action Programme – Mid-term Review

25 Jan 2024

Water- en bodemkwaliteit zijn onlosmakelijk met elkaar verbonden. De Nederlandse waterschappen en drinkwaterbedrijven pleiten voor een verbetering van de water- en bodemkwaliteit. Een vitale bodem kan meer water vasthouden, zo wordt er minder onnodig water afgevoerd en door de sponswerking van de bodem beperken we wateroverlast en droogteschade. In een drukbevolkt en intensief gebruikt land als Nederland zijn er veel bronnen van water- en bodemvervuiling, denk bijvoorbeeld aan de industrie, landbouw en huishoudens. Ook in Europees verband is te zien dat het verbeteren van de waterkwaliteit stagneert. De kwaliteit van Europese waterlichamen en bodem is er slecht aan toe. Het uiterlijk in 2027 bereiken van de afgesproken doelen uit de Europese Kaderrichtlijn Water is daardoor in gevaar. Schadelijke activiteiten en lozingen dienen een halt te worden toegeroepen. Stoffen als PFAS horen in het geheel niet thuis in het milieu en in de bronnen voor drinkwater, grond- en oppervlaktewater. De waterschappen en drinkwaterbedrijven zijn dan ook voorstanders van een milieubewust en streng stoffenbeleid met de mogelijkheid tot het verbieden van stoffen (REACH). Een meer duurzame land- en (glas)tuinbouw zou ook bijdragen aan het halen van waterkwaliteitsdoelen. Een dergelijke transitie in de land- en tuinbouw zorgt voor minder waterverbruik en minder emissies naar water, bodem en de lucht door meststoffen, gewasbeschermingsmiddelen en andere verontreinigingen. Ook juridisch zijn sterkere verbindingen nodig die uiteindelijk doorwerken in de praktijk. Waterschappen en drinkwaterbedrijven investeren volop in het zuiveren van water, maar wanneer er schadelijke stoffen in het water terecht blijven komen, zijn die investeringen nooit voldoende. Een bronaanpak vanuit de gedachte wat er niet in komt, hoeft er ook niet uit is wenselijk. Aanvullend wordt er met de huidige herziening van richtlijn stedelijk afvalwater en de farmaceutische wetgeving al invulling gegeven aan vervuiling vanuit huishoudens, zoals medicijnresten. Meer actie is nodig op Europees niveau om vooruitgang rond de uitvoering van milieumaatregelen te stimuleren. Bronaanpak moet nadrukkelijker doorgevoerd worden in Europese wetgeving en een transitie in het waterbeheer, met de focus op water beter vasthouden, is leidend. Echter, in de watersector kunnen we het niet alleen en helpt een duurzame transitie in de landbouw en industrie om Europa waterweerbaarder te maken en de doelen uit het 8ste MAP te halen.
Read full response

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius), Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and

22 Jan 2024 · Zero pollution in the water sector, with focus on PFAS challenges

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič), Lukas Visek (Cabinet of Vice-President Maroš Šefčovič) and

22 Jan 2024 · Zero pollution in the water sector, with focus on PFAS challenges

Meeting with Esther De Lange (Member of the European Parliament)

16 Nov 2023 · Water related files

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

26 Oct 2023

Vewin welcomes the Directive but expresses disappointment regarding the weakening of the legal framework from the European Commission's (EC) original plans. The legislation was initially intended to address the consequences of soil degradation in alignment with the objectives of the EU soil strategy. What remains, however, is a directive that primarily establishes a framework for soil monitoring. Vewin views this Directive as a cautious initial step towards promoting healthy soils and consequently, ensuring high-quality groundwater across Europe. Nevertheless, the direct link between the directive and groundwater quality and quantity is missing. Vewin perceives this as a missed opportunity because research conducted by KWR (refer to the attached document) demonstrates that healthy soil can significantly enhance groundwater quality and quantity through various soil processes, such as chemical conversion of contaminants. Healthy soil not only improves water quality and quantity but also contributes to the drinking water supply. Vewin urges policymakers to incorporate the significance of groundwater and the correlation between soil and groundwater into the objectives outlined in Article 1 of the Directive. Considering that 60-70% of European soils are unhealthy, it can be argued that Member States' actions at their respective levels have not been effective. Therefore, EU-level intervention in soil management is justified. Moreover, this is not the first EU-level legislation dealing with soil. For instance, the authorization of active substances present in pesticides falls under EU jurisdiction. In summary, Vewin fully supports the EC's approach regarding the subsidiarity principle in this context. Regrettably, the current monitoring process does not include groundwater quality monitoring. This omission is unfortunate because the EC states that monitoring outcomes determine whether member states should take action when they fail to meet the criteria set by the directive. If the directive does not include groundwater quality as a criterion, even though unsustainable soil management affects groundwater quality, a member state is not obliged to act. Another missed opportunity is that the EC does not establish targets or deadlines for the actions that member states must take when soil fails to meet a criterion. A soil declared 'unhealthy' does not necessarily have to be restored to a 'healthy' state in the subsequent monitoring round. Vewin calls on policymakers to define targets or deadlines for measures when soil fails to meet a criterion under Articles 9 and 10 in areas designated by the Water Framework Directive for water abstraction intended for human consumption. Vewin appreciates the EC's proposal for legislation on soil remediation at sites posing a risk to public health. Member states are required to remediate soil at these sites until they no longer pose a risk to public health. However, the EC has made both the risk-based approach and the standards non-binding. Each member state has the discretion to define sites posing a risk to public health and set their own standards. This represents a missed opportunity, especially considering the findings of the research conducted by KWR (refer to the attached document). Vewin urges policymakers to prioritize areas designated for water abstraction intended for human consumption when applying the risk-based approach to soil remediation to ensure their protection. Furthermore, the Directive must guarantee that soil remediation adheres to DWD (Drinking Water Directive) standards in locations where contaminants pose a risk to the drinking water supply.
Read full response

Dutch Water Authorities warn against over-stringent taxonomy criteria

2 May 2023
Topic — The consultation defines sustainable investment standards for water management and circular economy activities.
Message — DWA argues that waste water treatment criteria should not be used as a stringent measure affecting access to finance. They claim phosphorus recovery targets are currently unfeasible and lack a functional market for the recovered material.123
Why — Relaxed standards would allow Dutch water authorities to access green financing despite technical non-compliance.4
Impact — Environmental groups and water ecosystems lose protections against the deterioration of local water bodies.5
Read full response

Meeting with Mohammed Chahim (Member of the European Parliament, Shadow rapporteur)

28 Apr 2023 · CRMA and UWWTD

Meeting with Anja Hazekamp (Member of the European Parliament, Shadow rapporteur)

2 Mar 2023 · sustainable use of plant protection products

Meeting with Esther De Lange (Member of the European Parliament)

1 Mar 2023 · Files related to water - APA

Meeting with Anja Hazekamp (Member of the European Parliament, Shadow rapporteur)

15 Feb 2023 · water quality

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

2 Feb 2023
Topic — The EU is revising the list of chemicals and pollutants regulated in water.
Message — 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.12
Why — Targeted source control measures would help avoid additional treatment efforts at the pipe.3
Impact — The pharmaceutical industry would be forced to reimburse costs for advanced wastewater treatment.4
Read full response

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

Vewin welcomes this consultation and wishes to comment the following in general: The polluter-pays principle (PPP) is a basic principle of European policy making and defined in article 191.2 (TFEU). The main goal is to avoid that, by externalising the cost of pollution to other parts of society (water service providers, public authorities, health care systems, consumers/tax payers), polluting products and services can be offered at competitive prices, hence hampering the development of more environmentally friendly alternatives. The experience of Dutch drinking water companies shows that the PPP is not applied in the case of surface- and groundwater pollution. This situation leads to substantial extra treatment costs and, hence, negatively affects the affordability of drinking water services although they are considered as essential services according to EU law (CERD) Non-application of the PPP: EU water law defining standards for drinking water companies and non-application of the PPP: The WFD stipulates in its article 9.1 that Member States shall take account of the principle of recovery of the costs of water services, including environmental and resource costs, in accordance in particular with the polluter pays principle. Member States largely fail to implement this article. Drinking Water Directive: The 2020 revision reviewed the water quality standards and lowered the thresholds for a number of contaminants to better protect human health. As source control measures are so far wholly inadequate to comply with these thresholds, the (remaining) treatment costs (pesticides, nitrate, PFAS) have to be entirely borne by the drinking water suppliers leaving the polluters out of the game. Other relevant EU water-related law and non-application of the PPP: REACH and PFAS restriction This regulation does not contain any PPP clause linked to the putting on the market of chemicals although their authorisation may cause substantial follow-up costs for society, including for drinking water service providers. IED: The Commission proposal lacked extended producer responsibility requirements when it comes to pollution from the installations covered by this directive. Nitrate directive: The contamination of groundwater by excessive fertiliser use is a cause for extra treatment of raw drinking water in order to comply with the parametric values set in the DWD and the Groundwater Directive. EU legislation does not hold the farmers concerned financially liable. SUR: In 2022, the Commission proposed a revised text in the form of a regulation. It does not implement the PPP, although many drinking water companies apply extra treatment in order to comply with the DWD. Application of the PPP: Revision of the Urban Wastewater Treatment Directive: The draft revised directive includes an EPR scheme to finance quaternary treatment at urban wastewater treatment plants to remove pollutants from human pharmaceuticals and cosmetics that cannot or only partially be removed by current treatment processes. The co-legislators still need to approve this proposal which is a prerequisite to financing the additional treatment step. Relevant supporting mechanisms of the PPP: Vewin recognizes the need for supporting mechanisms in order to file accountability upon polluters. A more digitalized Europe is needed for PPP to be applicable. Therefore, we welcome, the Data Act, Taxonomy and CSRD. Conclusion EU law and its enforcement must ensure that polluters cover the costs of extra treatment required to produce drinking water in order to comply with regulatory requirements for the pollutants concerned. Use the Water Framework Directive and the Drinking Water Directive as a starting point to identify polluters and in which directives the PPP can be applied (IED, pesticides directive, etc.). The PPP is the best policy available to make polluters co-responsible for surface and groundwater quality, otherwise quality standards will not be met.
Read full response

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

14 Sept 2021 · Water pollution - PFAS

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

The Zero Pollution Action Plan under the EU Green Deal rightfully focuses on the prevention of pollution first, based on the precautionary principle; principles enshrined in the TFEU. The prevention of pollution at the source has to include accelerated, concrete action under the REACH Regulation to prevent harmful substances from negatively impacting surface and ground water quality, including drinking water resources. This is necessary not only to reach the environmental goals of the EU Green Deal, but also the goals of the Water Framework Directive. Protection of drinking water resources must be a top priority to avoid expensive and energy-intensive extra treatment by drinking water suppliers, in line with the Water Framework Directive (WFD) Art. 7(3). Water operators, authorities and other stakeholders have been raising concerns about persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM) substances as they can still be detected decades after their withdrawal from the market. Their intrinsic properties pose serious long-term risks for the quality of drinking water resources. Therefore, PMT and vPvM substances should be swiftly classified as substances of very high concern (SVHC) under REACH, as PBT substances already are. Furthermore, the review of REACH should close the knowledge and regulatory gaps, and prohibit the continued release of PMT/vPvM substances and other hazardous substances to the environment. PFAS The rapidly increasing number of PFAS on the market, 5,000 approximately, requires a group approach (regulation by class) to avoid the long-term pollution of our aquatic environment. Water consumers should not bear the extra treatment costs of drinking water to meet the strict PFAS parametric values stipulated in the new Drinking Water Directive (DWD). While recognizing and supporting the efforts made by some Member States and the Commission on the PFAS Action Plan and preparations of a restriction dossier for PFAS substances for non-essential uses, it has become increasingly clear to water operators that a complete ban of PFAS substances is essential. Also with regard to the EFSA opinion of September 2020, which indicates that PFAS pose a threat even at ng/l concentrations, and given the fact that these substances are extremely hard to remove even with advanced drinking water purification techniques, we call for a complete ban of these substances under REACH. Subsequent approval of PFAS for essential uses can be restrictively envisaged, provided the appropriate risk assessment provisions and management measures are put in place. We support the IIA policy option for reforming the restriction process by extending the generic risk approach (GRA) to all chemical substances so that they are regulated according to the intrinsic hazards they pose. REACH explicitly takes into account the risks posed by indirect exposure of humans via the environment through consumption of food, drinking water and inhalation of air, which are influenced by releases of substances into the environmental compartments of air, water and soil. We advocate for an adjustment of the risk characterisation, so that it also comprises a general life cycle assessment of the effects of releases on water quality – especially if relevant to drinking water resources - and on the possibility to achieve the goals of the WFD and the DWD. We also support the regulation of combination effects of priority chemicals and to include this in the authorization process of chemicals in coordination with the WFD, the Environmental Quality Standards Directive and the Groundwater Directive.
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The Association of Dutch Water Companies (Vewin) and the Dutch Water Authorities would like submit the following comments to the Draft Regulation on the technical screening criteria. The core activities of water services (water supply and waste water management) are per se activities that contribute to the protection of the environment and human health and the achievement of the UN 2030 Agenda for Sustainable Development Goals (SDGs). As such, water services are essential services and services of general (non-economic) interest and cannot be considered a commercial sector like any other. It is problematic that the criteria set in 5.1 and 5.2 for leakage levels – the ILI method – are not based on the recently renewed Drinking Water Directive (DWD) provisions and deviate from it. The new DWD recognises the freedom of Member States to choose the appropriate method and to use other methods than the ILI. It is therefore not acceptable nor legally sound to only refer to the ILI. The criteria set in this Delegated Regulation could trickle down into future legislation and regulation without the proper political scrutiny and discussion. This is a fundamentally incorrect procedure. In addition, the current level of leakage and energy consumption must be taken into account when setting criteria. The higher the current sustainability level, the more difficult it is to make any further progress. The 20% reduction criterion in 5.2 is a disproportionately heavy requirement for companies that already score well. Furthermore, for energy consumption, the question of whether green/renewable energy is used or not must also be taken into account. Energy policy should not hinder the primary task of treating waste water, which would lead to negative effects on public health, a clean environment and biodiversity. The energy consumption of waste water treatment plants (WWTPs) is relatively high. In the short term it is not easy to reduce the energy consumption and options are limited. However, a number of possibilities do exist to make the energy consumption more sustainable through the use of renewables such as biogas and wind, solar and aquathermal energy. Almost half of the Dutch WWTPs’ energy consumption is already being generated sustainably at the plants. Through the national climate agreement, this production will increase considerably with the goal of reaching energy neutrality in 2025. Perhaps this should be taken up as an alternative to strict energy efficiency targets. Innovation will eventually have to provide a climate neutral and circular WWTP. But even then it will require a considerable energy consumption, which is even expected to increase with stricter treatment obligations. In addition, the Association of Dutch Water Companies (Vewin) and the Dutch Water Authorities would like to refer to the reaction paper of EurEau. EurEau represents 34 national associations of drinking water and waste water operators from 29 European countries.
Read full response

Response to Revision of lists of pollutants affecting surface and groundwaters

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 protecting human health and the environment. This initiative to revise lists of surface and groundwater pollutants should be based on Art. 191.2 TFEU and its principles: the precautionary principle, the principle that preventive action should be taken and that environmental damage should, as a priority, be rectified at source, and the principle that the polluter should pay. Given the various pathways through which pollution reaches the environment, water resources protection can only be effective if preventive action is taken and a source-control approach is implemented. The latter is also instrumental to achieve a truly circular economy for water, the zero pollution ambition and climate neutrality by 2050. That is why we support coherence of all EU legislation with the Green Deal strategies. To ensure the supply of high quality drinking water the protection of surface water and ground water resources from pollution is paramount. This is recognised in the WFD, whose objectives should be mainstreamed in other sectoral policies. The wording of Art.7.3 WFD is clear but not yet implemented: “Member States shall ensure the necessary protection for the bodies of water identified for the abstraction of water for human consumption or intended for such future use, with the aim of avoiding deterioration in their quality in order to reduce the level of purification treatment required in the production of drinking water”. The revision of the lists of pollutants should fully align with the ambition of the Chemicals Strategy for sustainability and the Zero Pollution Action Plan. Thus, groups of substances and mixtures should be regulated according to a hierarchy of pollutants based on criteria such as CMR, PMT, PBT and EDC, and the related ECHA work, giving priority to those pollutants (or their metabolites/degradation products) that are relevant for drinking water resources protection and for the protection of ecosystems. We expect that new Drinking Water Directive parameters are considered when revising the water resources protection legislation (EQSD, GWD). It is fundamental, however, that sectoral legislation (pesticides, biocides, pharmaceuticals, cosmetics, detergents and other chemicals and agriculture legislation) contribute to water policy objectives. At the same time the Commission should speed up the implementation of the measures proposed in the Strategy on Pharmaceuticals in the Environment so that pharmaceutical residues pollution is controlled as much as possible at source. We welcome the intention to consider PFAS as a group of substances under the Priority Substances list: for these substances we support a strict restriction, banning all non-essential uses. We are available to engage further with the Commission and Member States on the identification of other substances. We would support a wider revision of the EQSD in order to take into account mixtures and the effect-based monitoring. Concerning Annexes I and II of the Ground Water Directive, we support the inclusion of the 10 PFAS substances and other substances (pharmaceuticals) identified by Member State authorities. We would also favour the inclusion of the “Sum of 20 PFAS” and “total PFAS” parameters (new Drinking Water Directive) to ensure consistency. In the last-resort case where water service providers need to implement additional costly treatments in order to remove micropollutants and microplastics to fulfil legal requirements and in order to preserve the affordability of water services, the extra-treatment costs have to be covered according to the polluter-pays principle through various tools, including extended producer responsibility (EPR) schemes.
Read full response

Response to Pharmaceutical Strategy - Timely patient access to affordable medicines

7 Jul 2020

Dutch Water Authorities (DWA) notes that the Strategy recognises that the way environmental risks are addressed needs to be improved, but that it regrettably fails to address these risks in the overall goals and specific objectives. Pharmaceutical substances are one example of micropollutants that can directly or indirectly enter the water cycle through many pathways. Once in the water cycle, they can pose a risk to drinking water resources and aquatic ecosystems. The wide use of pharmaceuticals in human and veterinary medicines has led to increased concentrations in many environmental reservoirs such as soils, sediments and waterbodies. Concentrations are likely to increase as populations age and grow, and climate change will worsen the water pollution by pharmaceutical residues as at times of drought concentrations will be higher. The Strategy should, in line with Green Deal objectives – in particular its zero pollution ambition, contribute to reducing the environmental impact of pharmaceuticals. Green Deal (GD) must guide actions The roadmap only links to selected parts of the GD, the Industrial Strategy. The Commission committed however to streamlining all GD elements to the full range of EU policies. This Strategy must link to the future strategies to achieve zero pollution and sustainable chemicals, and the Circular Economy Action Plan, given the impact of pharmaceuticals on resource recovery options of water operators. Adopt a true life cycle approach The roadmap claims to cover the whole life-cycle of pharmaceuticals but does not include the waste phase (disposal, excretion). A truly holistic approach cannot exclude the impact of pharmaceuticals on the environment. Measures to address this impact should be based legally also on Art. 191(2) TFEU, i.e. the precautionary principle, the control at source principle and the polluter pays principle. The Strategic Approach to Pharmaceuticals in the Environment (PiE) must become a recognised element of this Strategy It is disappointing that the PiE strategy of 2019, that recognises the need for a holistic life cycle approach, is hardly even mentioned although it contains a number of policy recommendations for the full pharmaceuticals value chain. The Environment Risk Assessment (ERA) must be strengthened ERAs should be conducted for all active substances, even those approved before 2006, and consider their environmental impact on the quality of surface/ground water bodies, incl. drinking water resources. Results of ERAs must be considered in cost-benefit analyses in the authorisation process. Environmental data on the presence and impacts of pharmaceuticals (as well as their metabolites, degradation and transformation products), mixture effects, environmental behaviour such as degradability, are to be made fully public and transparent throughout the EU, as OECD recommends. Restrict over-the-counter sales of high-risk pharmaceuticals For pharmaceuticals that have a negative impact on the environment, prescription by physicians should be compulsory, as OECD recommends. This applies especially to high-risk pharmaceuticals, such as antibiotics and persistent, bio-accumulative and toxic pharmaceuticals. Support the development of green pharmaceuticals The Strategy should support efforts to develop pharmaceuticals that are non-hazardous or that quickly degrade into non-hazardous substances. Green Public Procurement and Ecolabels should be implemented to enable informed choices by prescribers and patients. Extended producer responsibility (EPR) must apply A full life cycle approach means producers remain responsible for their products even after the use phase. To this end, funding mechanisms, such as comprehensive EPR schemes, should be set up to avoid that other actors, including waste water treatment plants, have to bear the financial burden of preventing the release of pharmaceuticals in the environment.
Read full response

Response to Chemicals strategy for sustainability

19 Jun 2020

The Association of Dutch Water Authorities and Association of Dutch Water Companies (Vewin) welcome the intention of the European Commission to finally establish a Chemicals Strategy for sustainability. We agree on the choice of Art.191 TFEU as a legal basis of the Strategy and we believe it is a good first step to move towards a zero pollution ambition for a toxic-free environment, in synergy with the Zero Pollution Action Plan for air, water and soil. We would like to see an ambitious and coherent Chemicals Strategy that considers the whole life-cycle of chemical substances from their initial production, their use up and until their safe and sustainable disposal. We support and promote “safe-by-design” chemicals, with specific attention to degradability in and removability from water. According to Art.191 TFEU the precautionary principle should be applied, as well as the principle that preventive action should be taken and that environmental damage has to be rectified, as a priority, at the source, and polluters should pay. We strongly support ECHA’s work, supporting member states, or following requests from the European Commission, leading to the identification of substances as Substances of Very High Concern (SVHC) as well as their efforts to regulate PMT substances (i.e. GenX). We second the call of the Council of the EU on the need for a PFAS action plan with a view to phasing out all non-essential applications. In general, where less harmful alternatives to substances exist, these should as a rule be preferred. Industry should be stimulated to set up positive lists with substances that are safe to use, also in a circular economy. Companies that place (potentially) very harmful substances on the Union market should track-and-trace volumes and emissions of these substances throughout the entire chain. This will enable authorities and companies to detect ‘leakages’ and perform necessary mitigation measures and provides valuable information on the cumulative environmental exposure. Controlling hazardous chemical substances at the source is the most sustainable option, since once these substances enter the water cycle, they are difficult to control and expensive to remove through extra treatment. Removal from drinking water and waste water should be seen as a remedy of last resort. Additional treatment would not be in line with the Green Deal climate targets as enhanced technologies would be needed entailing more energy consumption and CO2 emissions. We also believe that an ambitious Chemicals Strategy based on source-control is a pre-condition for the development of a true circular economy for water services, finally recognising waste water as a resource when it comes to nutrient recovery, reclaimed water reuse and sewage sludge recycling. In the event that drinking water and waste water treatment are the necessary option to minimise the negative impact of specific chemicals on human health and the environment, the polluters should pay through mechanisms such as EPR (Extended Producers Responsibility) schemes or environmental taxes. These should cover the costs associated with extra-treatment that would otherwise have to be borne by citizens through their water bills.
Read full response

Response to Climate Law

6 Feb 2020

The Association of Dutch Water Authorities represents the interests of the 21 regional Dutch Water Authorities, who are by law responsible for managing water barriers, waterways, water levels, water quality and all urban waste water treatment in their respective regions. They strongly support the ambition of the European Commission to work towards a climate neutral Europe. Dutch Water Authorities experience the negative effects of climate change in their daily work. They witness more and more extreme weather events, such as high tides, cluster rains, and periods of drought. Adaptation to climate change therefore plays a big role in their activities and investments. Cross-border cooperation and coordination in relation to climate adaptation is very important and could be improved. The revision of the EU climate adaptation strategy under the EU Green Deal is therefore very welcome. Focus solely on climate adaption makes little sense when the causes of climate change are not tackled at the same time. Climate change mitigation is for that reason crucial. This is why Dutch Water Authorities apply a very ambitious climate and energy policy for their assets and water management practices. They produce renewable energy and contribute to the circular economy by recovering resources in the process of urban waste water treatment. This is why they consider the waste water treatment plants as water, resource and energy factories (https://www.efgf.nl/english). By making use of the public assets, the water authorities not only meet their own energy needs, but also contribute to renewable energy needs of the region. Several years ago they decided on the aim to become energy neutral in 2025 and are well on their way towards reaching this goal. To underline this ambition, the Dutch Water Authorities, signed together with the National government, provinces and municipalities, the so-called national climate agreement including a minimal ambition of 49% reduction of CO2 in 2030, CO2 neutral in 2050. For more than 10 years Dutch Water Authorities take serious measures to reduce their CO2 emissions and produce renewable energy. The element ‘water’ provides society with a great potential of renewable energy. Currently, Dutch Water Authorities for example produce more than 100 million m3 Biogas from sewage sludge. Moreover, the Water Authorities increasingly use their own assets like waste water treatment plants and pumping stations for the production electricity from solar and wind . Another promising energy source is thermal energy (heat and cold) from surface water and (treated) waste water,. Extracting heat from the surface water during the summer, reduces the risk of algal blooms and botulism.
Read full response

Response to Revision of the Drinking Water Directive (RECAST 2017)

29 Mar 2018

Commission Proposal DWD recast – Feedback Vewin: * Vewin welcomes the position taken by the Commission to hold on to the high level of protection provided for by the Directive regarding drinking water standards, including the continuation of the precautionary principle as leading principle for setting drinking water quality standards. * Vewin strongly supports the establishment of the long-awaited link between the Drinking Water Directive and the Water Framework Directive (and its daughter Directives) which clearly states the MS’ responsibility for protecting drinking water resources. This is a crucial step in achieving policy coherence and coordination within EU water legislation. * Vewin welcomes the further introduction of the risk-based approach (RBA) adding to what already has been laid down in Annex II in 2015. It is a positive development that both the hazard assessment of water bodies (including the catchment area) and the risk assessment of the domestic distribution system now complement the supply risk assessment, with room for MS to further determine the details. However, there should be a general obligation for MS to ensure a clear and balanced distribution of responsibilities regarding the RBA, tailored to the national institutional and legal framework, bearing in mind the principle of subsidiarity. * The proposal deletes the provisions for derogations (current Art. 9). Although Vewin would welcome a simplification of the process, the complete deletion of the legal instrument of derogations leaves MS and water suppliers with the situation that temporary exceedances can no longer be embedded in a legal framework. In addition, Vewin expresses its concern with the deletion of Art. 6, paragraph 2 and the deletion of the exception for notification to consumers in case of trivial non-compliances. Vewin believes the proposed changes constitute a too rigid system leading to legal and practical problems, and that provisions are lacking on how MS should act in case of temporary exceedances and non-compliances which cause no immediate risk to human health. * The proposal does not provide for a solution for the well-known harmonization problems concerning the quality assurance of products and materials in contact with drinking water (current Art. 10). Vewin also notes that the proposal now only refers to construction products and materials in the domestic distribution system, leaving out products and materials used in the water supply system of the water supplier. Vewin calls for the inclusion of a legal, harmonized baseline in the Directive for health requirements for products and materials in contact with drinking water. * Vewin notes that some of the requirements on information to the public (Art. 14 and Annex IV) are going beyond the scope and the objectives of the DWD. These requirements should focus on water quality and the protection of human health as determined by Art. 1. Other aspects such as cost structure, investment decisions, waste water collection and treatment and leakage rates should not be included but left to MS (subsidiarity). * Vewin does not support the deletion of the indicator parameters. They are important to link drinking water quality with the quality of drinking water resources. The monitoring frequency of all parameters should be risk-based. The attached paper further explains the points above.
Read full response

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

10 Oct 2017 · Research and Innovation in the Water sector

Response to Evaluation of the impact of the CAP on climate change and greenhouse gas emissions

7 Jul 2017

As association of Dutch water companies (Vewin), we fully support the proposed evaluation of the impact of the CAP on climate change and greenhouse gas emissions. It is important to make the agricultural sector more sustainable and resilient to climate change and to use the CAP as an instrument in order to achieve this. Although we underline the need to reduce CO2 emissions from agriculture whole-heartedly, it is certainly not the only challenge deriving from climate change wherein the CAP can play a role. Water is a crucial element for both climate mitigation and adaptation by the agricultural sector and also inevitable to reach the goals of the CAP. Achieving and preserving the right quality and quantity of both surface water and groundwater is important for the agricultural sector, but this will be hampered due to climate change. We would therefore like to recommend the Commission to also make water an integral element in this fitness check but also for the plans on the future CAP after 2020. We foresee an intensification of agriculture practices with a growing demand for irrigation. The extension of the vegetation period and decreasing precipitation during that period will also negatively affect the European water resources. Furthermore, there will be an increase of extreme weather events like rain storms, hailstorms or droughts may lead to crop failures or even ruin the entire standing growth of crops. This will cause a reduction of absorption of fertilisers by plants, or the fertilisers to remain in the plant residues, which may result in massive nitrate pollution of groundwater. All these developments clearly show that the reaction by the agricultural sector to climate change will certainly have an effect on the water resources in the EU. Therefore we believe that the future CAP should be used to reduce the undesirable consequences of these developments to the minimum. This can be achieved by better coordination of CAP measures with all existing and future EU water legislation, such as the WFD, Nitrates directive and the Drinking Water Directive. The CAP measures could for example be more linked with the water- and ecological goals of the WFD. Furthermore, deterioration of water bodies due to farming practices will cause increased efforts and costs for the production of drinking water. CAP measures to prevent this contribute directly to the implementation of article 7 of the WFD.
Read full response

Response to Strategic approach to pharmaceuticals in the environment

23 May 2017

Vewin, the Association of Dutch Water Companies, welcomes this opportunity to react to this Roadmap. Pharmaceutical products are essential to our society’s health and their use is likely to increase in the future due to a growing and ageing population. The issue of pharmaceutical residues, as well as emerging substances and priority substances that end up or that are already present in the environment and surface and ground water, is of the highest concern to Vewin. Residues of these pollutants are found in European waters, including drinking water resources. Pharmaceutical residues can pose environmental risks and are a cause for concern for the production of drinking water. The urgency of a European strategic approach therefore increases by the month. Hence, Vewin is disappointed with the lack of progress of the Commission on this file. Regardless of several earlier announcements of the publication of the strategy, the process has been characterised by repeated delays over the past few years. We strongly urge the Commission to take the necessary steps to adopt the strategy within the shortest possible timeframe. According to Vewin, the strategic approach should consist of a number of concrete measures to reduce pharmaceutical residues in the environment and water resources. Essentially, it should contain an approach with actions along the whole life cycle of a pharmaceutical product, so that environmental damage is rectified at the source: - Design level: the development of green pharmacy for example. - Authorisation level: In the authorisation procedure full account should be taken of the environmental risk assessment, with the protection of water resources as one of the criteria in the assessment. In determining the environmental impact of a pharmaceutical product the goals of the Water Framework Directive in terms of water quality and the task for Member States to avoid deterioration in quality of water resources (art. 7.3 WFD) should be taken into account. - Post-authorisation level: e.g. monitoring of impacts on the aquatic environment of pharmaceuticals - Marketing level: e.g. more extensive use of ecolabel - Hospital level: special treatment of wastewater - Health care professionals’ level: prescriptions and training - Household level: make consumers and patients more responsible, e.g. regarding proper disposal of pharmaceuticals - Wastewater treatment plants level - Drinking water level Actors at these levels should all take ownership and accept responsibility. The Netherlands is currently developing a so-called ‘product chain approach of pharmaceutical residues in water’ (Ketenaanpak Medicijnresten uit Water) in which all actors from the production to the prescription, the use and the disposal of pharmaceuticals and the purification of (waste) water are involved. This could be an example for the European strategic approach. Vewin believes that the public availability of data related to the environmental impact of pharmaceuticals, for example but not limited to the environmental impact assessment conducted on medicinal products prior to the authorisation, should be an important part of the European strategy. This environmental impact should also be taken into account in the authorisation process of pharmaceuticals. As pharmaceuticals can be authorised either via a European procedure or via national procedures, it is very complicated to find representative data on the environmental impact of pharmaceuticals. Furthermore, for most pharmaceuticals that were authorised before 2006, no such data is available. According to Vewin, it is important in this regard that: - These data are made publically available, preferably at a European level - For new pharmaceuticals that are based on active substances authorised before 2006, an environmental impact assessment should also be conducted - Data on the environmental impact of pharmaceuticals should be easier to find.
Read full response

Response to Revision of the Drinking Water Directive

24 Mar 2017

Regarding the revision of the Drinking Water Directive (the ‘Directive’) the Association of Dutch Water Companies (Vewin) holds the view that the Directive has been and still is a well-functioning European legal instrument contributing to the supply of wholesome and clean drinking water throughout the EU. The Directive should be kept in place and further improved, as was also concluded by the recently finalised evaluation of the Directive. Regarding the 4 key topics the Commission addresses in the section on ‘objectives and policy options’ Vewin would like to stress that: 1) the precautionary principle should be kept as a leading principle in setting drinking water quality standards of Annex I of the Directive and for environmental quality standards for source water. This could be made more explicit in the inception impact assessment document. 2) Vewin welcomes the elaboration of policy options for the introduction of integrated source-to-tap Risk-Based Approaches in the Directive. This elaboration should include considerations of subsidiarity and flexibility at Member States’ level to leave room for approaches tailored to the legal and institutional framework in Member States. 3) the revision of the Directive should include a sound legal basis (health and hygienic requirements) for the harmonised acceptance of materials and chemicals in contact with drinking water, taking full account of the work on the so-called ‘four Member States Common Approach’. In addition, Vewin would like to stress the need for better integration of the protection of drinking water resources in the River Basin Management Plans of the Water Framework Directive (WFD). The revision of the Directive should include the introduction of a cross-reference with the WFD, in particular its Article 7, the Groundwater Directive and the Priority Substances Directive. This could be made more clear in the inception impact assessment. Regarding the consultation strategy, Vewin stresses that it is important that stakeholders from the drinking water sector will be again meaningfully consulted, also after the publication of the impact assessment and the policy options, thereby assisting the Commission in achieving the objectives set out by the Commission in this inception impact assessment.
Read full response

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

24 Nov 2016 · innovation on Water