ERM Coalition
ERM
The ERM Coalition is a network of associations of drinking water suppliers in the large European river basins of Rhine+Ruhr, Danube, Elbe, Meuse, Scheldt.
ID: 689730746555-77
Lobbying Activity
Response to European Water Resilience Strategy
26 Feb 2025
The European River Memorandum Coalition (ERM Coalition) of drinking water suppliers associations represent 170 water suppliers and 188 million people that depend on clean drinking water in the river basins of Rhine (IAWR, AWBR, ARW, RIWA-Rijn) and Ruhr (AWWR), Danube (IAWD), Elbe (AWE), Meuse (RIWA-Meuse) and Scheldt (RIWA-Scheldt). The ERM Coalition welcomes the EU Commissions Call for Evidence on the European Water Resilience Strategy. Drinking water suppliers in the ERM Coalition are convinced that a future-proof drinking water supply requires a comprehensive protection of drinking water resources. Their common understanding is laid down in the European River Memorandum (ERM), https://en.iawr.org/timm/download.php?file=data/docs/aktuell/european-river-memorandum-2020-en.pdf and the European Groundwater Memorandum, https://en.iawr.org/timm/download.php?file=data/docs/lit_memoranden/europeangroundwatermemorandum_2022_en.pdf. Besides the two memoranda, the ERM-Koaliton asks for consideration of its positions which can be found in the pdf attached: 1. State-backed Transformation of Conventional Agriculture as Key to Water Protection and Elementary Soil Functions 2. Position of the ERM Coalition on the Polluter Pays Principle fitness check of its application to the environment 3. Integrated water management revised lists of surface and groundwater pollutants 4. Revision of the EU general pharmaceuticals legislation 5. Position of the ERM Coalition on the Proposal for a Regulation of the European Parliament and of the Council on the Sustainable Use of plant protection products 6. Position of the ERM Coalition on the revision of the Industrial Emissions Directive (IED) and the new Industrial Emissions Portal (IEP) Regulation
Read full responseMeeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and Internationale Arbeitsgemeinschaft der Wasserwerke im Rheineinzugsgebiet
2 Dec 2024 · EU water policy
Meeting with Beatrice Covassi (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and
15 Nov 2023 · Public Hearing - Soil Monitoring Law
Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and
15 Nov 2023 · Soil Health Law
Response to Revision of lists of pollutants affecting surface and groundwaters
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, Belgium, Bulgaria, Croatia, Czechia, France, Germany, Hungary, Luxembourg, the Netherlands, Romania, Slovenia, Slovakia. Drinking water suppliers in the ERM Coalition are convinced that a future-proof drinking water supply requires a comprehensive protection of drinking water resources. Their common understanding is laid down in the European River Memorandum (ERM) https://en.iawr.org/timm/download.php?file=data/docs/aktuell/european-river-memorandum-2020-en.pdf and the European Groundwater Memorandum (EGM) https://en.iawr.org/timm/download.php?file=data/docs/lit_memoranden/europeangroundwatermemorandum_2022_en.pdf. Both memorandums are designed as guidelines for legislation at European level, meaning in this context: Set ERM target values as Environmental Quality Standards (Priority Substances list). Set EGM intervention values as Groundwater Quality Standards (for substances listed in the annex of the Groundwater Directive). ERM target values: For anthropogenic (non natural) substances, the ERM sets the following target values (maximum values) per individual substance 1.0 µg/L Evaluated substances without known effects on biological systems 0.1 µg/L Evaluated substances with known effects on biological systems (except if toxicological findings require an even lower value, e.g. for genotoxic substances), 0.1 µg/L Non-evaluated substances that cannot be removed sufficiently by natural procedures 0.1 µg/L Non-evaluated substances that form non-evaluated degradation/transformation products EGM intervention values: The European Groundwater Memorandum sets intervention values that are half of the corresponding target values set in the ERM for surface water bodies. This is due to time-delay for passage of the unsaturated zone in soils as well as slow due to low flow velocities and poor degradation in groundwater bodies which makes trend reversal difficult. A higher intervention value of up to 0.5 µg/L in groundwater bodies for an anthropogenic substance can only be accepted for the exceptional case that the substance and its degradation products have been toxicologically fully evaluated, have accordingly no effects, and have additionally been shown not to form critical or non-evaluated transformation products during common drinking water treatment processes. The following List of Micropollutants in major European River Basins shows a considerable number of substances that exceeded the ERM target value 2020, often not only in their maximum but even in their mean value. According to EU Primary Law (Art. 191 TFEU) the situation has to be rectified at source by additional efforts by upcoming legislation including the revision of lists of surface and groundwater pollutants. As new products (esp. industrial chemicals, pesticides, biocides, pharmaceuticals) are constantly entering the EU internal market, a revision of the lists of surface and groundwater pollutants is required every 3 years.
Read full responseResponse to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
21 Dec 2022
The ERM Coalition strongly supports the inclusion of PMT (persistent, mobile, toxic) and vPvM (very persistent, very mobile) substances as new hazard classes in the CLP Regulation to fully address persistency, mobility and toxicity. This is an overdue milestone to also protect human health and drinking water supply. PMT/vPvM substances must not enter drinking water resources. Such protection is required by European Primary Law, Art. 191 TFEU and the Water Framework Directive, Article 7.3. Including PMT/vPvMs will show EU´s global leadership in protecting public health and ensuring safe, sustainable and affordable drinking water supply in the future. EU leadership will continue to be well-received by the international community, such as through the UN GHS. The ERM Coalition of drinking water suppliers associations represent 170 water suppliers and 188 million drinking water consumers 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, Belgium, Bulgaria, Croatia, Czechia, France, Germany, Hungary, Luxembourg, the Netherlands, Romania, Slovenia, Slovakia.
Read full responseResponse to Introducing new hazard classes–CLP revision
14 Oct 2022
The ERM Coalition strongly supports the proposed Delegated Regulation of the Commission to amend the CLP Regulation and include PMT and vPvM substances as new hazard classes. This is an overdue milestone to protect human health from their unpredictable, long-term, toxic effects. We very much welcome recital 8 and 9 as well as proposed chapter 4.4. on Persistent, Mobile and Toxic (PMT) or Very Persistent, Very Mobile (vPvM) properties as well as related amendments in Annex II and Annex III.
Including PMT/vPvMs will show EU´s global leadership in protecting public health and ensuring safe, sustainable and affordable drinking water supply in the future.
The ERM Coalition of drinking water suppliers‘ associations represent 170 water suppliers and 188 million drinking water consumers 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, Belgium, Bulgaria, Croatia, Czechia, France, Germany, Hungary, Luxembourg, the Netherlands, Romania, Slovenia, Slovakia.
Read full responseResponse to Sustainable use of pesticides – revision of the EU rules
18 Jul 2022
ERM Coalition of drinking water suppliers' associations represent 188 million people in major European river basins depending on clean drinking water.
Effective protection of drinking water resources is essential for public health and future well-being of EU citizens. The European Union’s primary law (Art. 191 (2) TFEU) requires rectifying environmental damage at the source of the pollution which in this context is the application of pesticides/plant protection products (PPP).
The EU Commission's proposal now provides an overdue, well elaborated step in the much-required direction. From the point of view of the ERM Coalition of drinking water suppliers, there is no space left for trade-offs: The Commission’s SUR proposal is essential for preserving the potability of tap water in the future. Potable tap water also has to be seen as a core element of prosperity.
It’s now up to the AGRIFISH Council (Ministers of Agriculture) and the European Parliament (EP) to adopt the Commission’s proposal to prevent future biodiversity loss as well as to acknowledge the requirements of future drinking water supply.
Transparency on the application of pesticides/PPP is required both by competent water authorities responsible for monitoring the Water Framework Directive (WFD, 2000/60/EC) and drinking water suppliers.
Member States are requested to allocate a budget to support farmers in their transition to sustainable farming without pesticides/PPP. Member states are recommended to follow the model of Denmark and introduce a pesticide tax to finance transition and discourage the use of chemical pesticides, including an increase of levies with their toxic load (cf. UBA press release of 23/06/2022).
The feedback is based on the following:
The revised Drinking Water Directive (2020/2184) requires the supervising authorities, in cooperation with the drinking water suppliers, to carry out an appropriate risk analysis and risk management. But the required risk management cannot be done by them due to a lack of authority. It can only be done by the regulator (AGRIFISH Council and EP) in the current SUD revision.
The SUD revision will be crucial to achieving the key targets for pesticide reduction by 50 % of the use and risk of chemical pesticides in the Farm to Fork (F2F, EP resolution of 20 October 2021) and Biodiversity strategies and the Zero Pollution Action Plan (chap. 2.3) as key elements of the European Green Deal and the General Union Environment Action Programme to 2030 of the EP and of the Council (DECISION (EU) 2022/591 of 6 April 2022).
Additional requirements for SUR ratification result from the severe, ongoing lack of WFD implementation and its provisions to i) prevent deterioration of the chemical status of all bodies of groundwater used for the abstraction of drinking water (Art. 4.1) and ii) to reduce the level of purification treatment in waterworks (Art. 7.3). However, the European Parliament in its resolution of 12 February 2019 (P8_TA(2019)0082) on the implementation of the SUD – correctly – „regrets the fact that the deterioration of water resources has increasingly led to additional treatment by drinking water operators in order to ensure that water intended for human consumption complies with the pesticides limits as enshrined in Council Directive 98/83/EC on the quality of water intended for human consumption, with the costs being borne by consumers, not polluters;“ (Nr. 29). Costs being borne by consumers is not in line with EU’s primary law (Art. 191 (2) TFEU) enshrining that the polluter should pay. The European Parliament furthermore recommends that use of agro-chemical substances „be prohibited in soils potentially draining into groundwater“ (Nr. 65).
The current generation is not allowed to deprive future generations of intact drinking water resources. Already today, the protection of their drinking water is an urgent concern of the population, cf. European Citizens’ Initiative (ECI) “Save Bees and Farmers”.
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