European Federation of National Associations of Water Services
EurEau
EurEau represents national associations of water and wastewater service providers across Europe.
Lobbying Activity
Meeting with Nathalie Berger (Director Internal Market, Industry, Entrepreneurship and SMEs)
21 Jan 2026 · Revision of Public Procurement legislative framework
EurEau urges Taxonomy alignment with EU water legislation
2 Dec 2025
Message — EurEau requests that Taxonomy criteria be better aligned with the EU acquis to avoid establishing more demanding requirements than existing legislation. They advocate for differentiated energy and leakage thresholds that account for diverse local geographical factors. Additionally, they suggest harmonizing activity descriptions across different climate and environmental objectives to ensure regulatory consistency.123
Why — This alignment ensures water utilities can access sustainable funding without facing unfair discrimination.45
Impact — Rural or topographically challenging regions lose investment due to structural biases in energy metrics.6
European water services demand inclusion in EU civil protection regulation
3 Nov 2025
Message — The organization requests that drinking water and wastewater services be explicitly included in the regulation's scope as critical infrastructure. They call for clear references to water services in key articles, compatibility with existing risk assessment processes, and simplified funding access through a single contact point.123
European Water Federation Urges EU to Recognise Wastewater Resources as Strategic
3 Nov 2025
European water services urge explicit infrastructure funding in EU budget
28 Oct 2025
Topic — EU long-term budget proposals for cohesion, agriculture, fisheries and security funding 2028-2034.
Message — The federation requests explicit provisions allowing funding for water infrastructure in territorial service objectives. They want water funding mainstreamed across climate and security objectives, mandatory inclusion of local water providers in decision-making, and support for absorption capacity.123
European Water Services Urge Recognition in EU Health Crisis Planning
28 Oct 2025
Topic — EU plan for coordinated prevention, preparedness and response to cross-border health threats.
Message — The association requests that water supply and wastewater treatment services be incorporated into the Union's health crisis framework as essential prerequisites for effective prevention and response. They ask for policy alignment with existing legislation and the embedding of water sector representatives in EU and national health preparedness structures.123
Water industry warns against weakening pesticide safety checks
14 Oct 2025
Message — The organization opposes reducing scrutiny of pesticide renewals, arguing that 10-year re-evaluations are essential safeguards. They want authorities to fully consider new scientific evidence of risks before approving substances.123
Why — This would protect them from rising treatment costs caused by pesticide pollution.4
Meeting with Veronica Manfredi (Director Environment)
1 Oct 2025 · EurEau position on REACH revision
European water sector urges broader market access for recovered fertiliser nutrients
18 Sept 2025
EurEau urges EU to prioritize climate-resilient water services
4 Sept 2025
Message — The organization asks the EU to recognize water services as essential drivers of climate adaptation. They request a focus on protecting water resources and aligning investments with climate projections.12
Why — This would secure increased public funding and streamline investments for necessary infrastructure upgrades.34
Response to Mini omnibus for defence
28 Jul 2025
EurEau is the voice of Europes water sector. We represent 70,000 drinking water and wastewater operators from 33 countries in Europe, from both the private and the public sectors. MOBILISING UNIONS RESOURCES TOWARDS DEFENCE The mini omnibus for defence marks a significant step toward enhancing the EUs defence capabilities. By proposing to revise existing funding instruments, including the Digital Europe Programme, Horizon Europe, the European Defence Fund, Connecting Europe Facility, the Strategic Technologies for Europe Platform (STEP), the Commission aims to mobilise EU funding in support of a more resilient and capable defence ecosystem. A key element of this proposal is extending the scope of the STEP Regulation and include a fourth strategic sector thereby covering all defence-related technologies and products. Importantly, the proposal draws in this respect on critical infrastructure protection identified in the White Paper on EU Defence as a priority capability area. WATER UTILITIES ROLE IN DEFENCE RESILIENCE The Critical Entities Resilience Directive (CERD) concerns providers of essential services, like water supply and sanitation, that play an indispensable role in maintaining vital societal functions and economic activities in the internal market. The water utility operators, in this respect, can be designated as critical entities. This acknowledgement opens a crucial window of opportunity to consider the foundational role of these essential utilities as critical infrastructure in the context of defence preparedness and resilience. Water supply and wastewater systems underpin the daily functioning of society and are at the same time indispensable to the operation of military bases, hospitals, logistics centres, and other critical nodes of defence. In times of military conflict or crisis, including cyberattacks, sabotage, and similar malicious threats, their disruption could have a severe impact on military readiness and civil protection alike. Furthermore, with the increasing hybridisation of threats the security and resilience of water utilities must be seen not as peripheral, but as core to EUs defence capability. This is not merely a matter of utility infrastructure maintenance. Strategic investment in water utilities supports the broader objectives of the EU defence policy: autonomy, resilience, and interoperability. For example, ensuring water supply and wastewater systems are cyber-secure, physically protected, and energy-resilient or self-sufficient directly contributes to defence-related operations continuity. Moreover, many water operators serve dual civilian-military users and are already integrated into international, national and local emergency preparedness frameworks. Enhancing their ability to fulfil this dual role and strengthening synergies between civil protection and defence is essential and in line with the EUs Strategic Compass. FUNDING FOR WATER UTILITIES ENHANCES DEFENCE CAPABILITIES Given that the Commissions legislative proposal foresees flexibility in identifying eligible projects within the expanded STEP scope, as well as other existing funding instruments addressed in this proposal, it is both timely and appropriate to argue for a more explicit inclusion of investments in water utilities. Such recognition would operationalise the White Papers principle of protecting critical infrastructure. Against this backdrop, the proposed revision of STEP and other relevant funding instruments thereunder should explicitly allow for investments aimed at improving water utilities, both in terms of security and operational continuity, like for example in: ~ Cybersecurity ~ Physical Security ~ Energy Supply Security ~ Crisis Management and Communication Systems ~ Stockpiling ~ Climate and Hybrid Threat Resilience Measures ~ Emergency Water Supply Capabilities
Read full responseEurEau urges inclusion of wastewater in EU bioeconomy strategy
18 Jun 2025
Topic — This initiative proposes a circular, climate-neutral bioeconomy to boost European competitiveness.
Message — EurEau asks the EU to clarify that resources recovered from wastewater and sewage sludge are part of the bioeconomy. They want strict requirements for hazardous substances entering sewers to protect recoverable biomaterials. They also propose setting a minimum share for phosphorus from organic sources in fertilizer rules.123
Why — These measures would improve cost competitiveness and facilitate easier market access for recovered materials.45
Impact — Industrial polluters would face stricter controls on hazardous substances entering the sewer system.6
Meeting with Jessika Roswall (Commissioner) and
27 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”
Water sector urges reporting delays but warns on chemicals
26 Mar 2025
Topic — The initiative aims to simplify EU sustainability reporting by reducing required company data.
Message — EurEau supports a two-year delay and higher reporting thresholds to ease administrative burdens. They urge the Commission to maintain strict criteria for pollution prevention to avoid greenwashing toxic chemicals. They emphasize that simplification must not dilute the effectiveness of environmental policies.123
Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)
20 Mar 2025 · Water Resilience
EurEau demands simpler procurement and wastewater sector inclusion
6 Mar 2025
Message — EurEau calls for including all wastewater and drinking water contracts under a single directive to ensure consistency. They suggest prioritizing environmental and social criteria over the lowest price to improve long-term efficiency. Additionally, the federation seeks digital tools and shorter timelines to speed up essential utility investments.123
Why — Unified rules for all water services would significantly reduce administrative workloads.4
Impact — Individual local suppliers in small markets could lose their current market dominance.5
Response to European Water Resilience Strategy
28 Feb 2025
EurEau supports the Commissions intention to establish a Water Efficiency First Principle to accompany the upcoming Water Resilience Strategy. Faced with increasing climate pressures on water availability, the EU needs to mainstream water efficiency across all sectors as a tool to reduce overall freshwater consumption and protect drinking water supply. Achieving water resilience requires involvement from all of society, not just water professionals. While the revised Drinking Water Directive (DWD) includes measures to reduce water losses in drinking water distribution systems, such water saving objectives are lacking for many other economic sectors. The goal of reducing water consumption should be mainstreamed into all sectoral policies. The binding environmental performance limit values for water introduced by the revised Industrial Emissions Directive (IED) provide a template for sector-specific water efficiency targets. Similar goals should also be set for water-intensive sectors not covered by the IED through the development of Best Available Technique documents showing what is achievable, while specific water efficiency targets are set at the relevant local or basin level, in line with the subsidiarity principle. As the largest freshwater consumer in the EU (59%), the agricultural sector has the biggest potential to improve Europes overall water efficiency. Adapting crop selection, farming practices and irrigation techniques to local water availability and climate conditions would contribute significantly towards reducing overall water consumption. More treated wastewater should be reused for irrigation in line with the Water Reuse Regulation. Targeted CAP subsidies as well as a more systematic implementation of the cost recovery principle enshrined in the Water Framework Directive (WFD) could provide financial incentives for change. For all sectors, it is essential to ensure that water efficiency results not only in productivity gains but also in lower water consumption overall. In this sense, the Commission should present the Water Efficiency First Principle not as a goal in itself but as one of the tools to build Europes water resilience. Water-saving measures should be combined with public information campaigns, targeted investments and an effective implementation of the cost-recovery principle to reduce freshwater consumption across all sectors. This should be coordinated at the relevant geographic level and closely connected to the River Basin Management Plans. Access to drinking water is a human right, and any water efficiency policy should strive to guarantee a secure supply of drinking water to all EU residents, including in times of drought. The Water Efficiency First Principle should enshrine the provision of drinking water to households as a priority for all water allocation regimes and drought management plans at the local and basin levels.
Read full responseMeeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen)
13 Feb 2025 · EurEau presented on the water-food nexus and Europe’s water resilience strategy
Meeting with Majdouline Sbai (Member of the European Parliament, Rapporteur)
21 Jan 2025 · Echanges sur la révision du règlement Détergents
Meeting with Michal Wiezik (Member of the European Parliament, Rapporteur for opinion)
15 Jan 2025 · Water resilience aspects
Meeting with Jessika Roswall (Commissioner) and
14 Jan 2025 · Water Resilience
Meeting with Elisa Roller (Director Secretariat-General) and Svenskt Vatten and Bureau Brussel Vewin - Unie van Waterschappen
10 Jan 2025 · PFAS in water
Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur)
13 Nov 2024 · Water pollutants
Water services group urges caution over manure-derived fertiliser proposal
15 May 2024
Topic — The Commission proposal would allow more recovered manure fertilisers under the Nitrates Directive.
Message — EurEau demands a detailed impact assessment and rules ensuring new fertilisers replace existing ones. Protecting water bodies must stay at the heart of the legislation.123
Why — Preventing nitrate pollution reduces the need for expensive water treatment infrastructure.4
Impact — Water consumers suffer as they ultimately pay for treating agricultural pollution.5
Meeting with Michael Bloss (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and
2 May 2024 · Green Industrial Deal
5 Apr 2024
EurEau is the European federation of water services. We protect public health by providing wholesome drinking water and the environment by treating wastewater for safe discharge. We welcome the Commissions decision to define biodegradability criteria for polymers contained in fertilisers as a necessary step towards minimising the use of non-degradable polymers, which cause microplastic pollution of soils, with a risk of contaminating surface water and particularly groundwater resources through soil. The mention in recitals to documents 3a that the study undertaken by the Commission ensured that the methods are representative of the diversity of soil types across the EU is encouraging, as is the explanation that criteria were set with the aim of preventing accumulation of non-degraded polymers in aquatic environments and soil. However, the criteria set in the two Annex 3b documents do not appear to match this ambition. In aquatic environments especially, pass criteria are set at less than 50% degradation (even considerably less for FP over 2 months) after 12 months. The assumption made in draft Act 3a on coating agents that the polymers are not supposed to reach aquatic environments gives no proof or guarantee that leaching does not, in fact, take place. While labelling requirements to maintain buffer strips are a necessary minimum measure, it is not realistic to expect that they will constitute a strong enough guarantee on their own. In soils, meanwhile, the target for 90% degradation is set after 48 months. Concretely speaking, this would mean that new polymer-containing fertilisers would be applied at a much faster rate (at least once a year) than the existing polymers are breaking down (taking up to 4 years), likely leading to accumulation. We recommend, at a minimum, aligning the criteria in all the draft Delegated Acts (including 3a/3b) with the more stringent criteria laid out in Regulation 2023/2055. We strongly welcome the requirement, for CMC 9, that neither the polymer nor its degradation by-products shall have adverse effects on the environment, particularly on groundwater bodies. However, the draft Acts specify neither test methods nor validity criteria to assess this. We call for analyses to check compliance with this point to be included in the tests required under the draft Acts.
Read full response25 Mar 2024
EurEau is the European association of water service providers with 38 national member organisations in 33 countries. The current INSPIRE directive (annex III) specifically includes utility facilities such as sewage and water supply in its scope. Ensure the security of critical infrastructures While EurEau supports efforts to increase the access of environmentally relevant spatial data to the public, EU legislation must ensure the protection of critical infrastructures / essential services to prevent malicious acts and protect peoples health and the environment. Hence, restrictions must be maintained regarding public access to information on water abstraction points, underground water utility networks and production / treatment facilities. The annex to Directive 2022/2557 on the Resilience of Critical Entities identifies drinking water and waste water operators as critical entities. They have to identify and overcome vulnerabilities in their systems. Unlimited public access to geospatial data on their infrastructures would certainly be identified as a vulnerability. With a view to ensuring policy coherence, article 13 of the current INSPIRE directive must be maintained and clarified in a way that geospatial data of critical infrastructures managed by the sectors listed in the annex to directive 2022/2557 should not be made publically accessible. We recommend a careful pondering of the justified public interest in accessing geospatial data versus the equally justified need to protect critical infrastructures in a worsening security environment. This could be summarised in the recitals to the revised INSPIRE directive. Avoid duplication with other EU legislation EurEau supports the objective of the INSPIRE directive to provide relevant data about the soil, groundwater- and surface water quality. However, duplication in reporting requirements must be avoided. EurEau invites the Commission to evaluate policy coherence in terms of data provision and reporting requirements with regards to the following directives: Water Framework Directive, Groundwater Directive, Urban Wastewater Treatment Directive, Nitrates Directive, Sustainable Use of Pesticides Directive, and the Drinking Water Directive, in particular, its article 8. Goal of the revision EurEau supports the goals of the revision including the move to a user-centric system. Clearly, water operators are also users of these data (bathing water, groundwater quality and levels, drinking water resources, etc.). Refocusing the scope of the INSPIRE Directive on environmental data may be sensible to avoid duplication with other data networks. However, the term environmental information would need to be clearly defined. Including all aspects covered by directive 2003/4/EC would trigger a significant (financial) burden for information providers and go beyond the INSPIRE scope.
Read full responseWater services demand better enforcement of EU Nitrates Directive
7 Mar 2024
Message — EurEau argues that the directive requires better implementation and enforcement to address diffuse pollution from agriculture. They insist that the legislation's primary purpose must remain the protection of water resources. The group also advocates for mandatory use of tools for nutrient management.12
Why — Stronger controls at the source would reduce expensive treatment costs for water utilities.3
Impact — The agricultural sector faces stricter mandatory requirements and higher costs for nutrient management.4
Water services urge BPA ban to protect drinking water resources
26 Feb 2024
Message — EurEau strongly supports the initiative to ban BPA and other bisphenols in food contact materials. They advocate for comprehensive control at source measures to prevent human exposure and environmental contamination. They also emphasize ensuring materials in contact with drinking water do not jeopardize safety standards.123
8 Feb 2024
EurEau, the European Federation of National Associations of Water Services, welcomes the Delegated Regulation supplementing Regulation (EU) 2020/741 with regard to technical specifications of the key elements of risk management, which should facilitate the development of risk management plans for water reuse projects. Nevertheless, we would like to share some concerns and suggestions (included in the attached file) which we believe would improve the drafting and implementation of risk management plans to ensure safe water reuse projects while further promoting water reuse (too complicated risk management plans could discourage water reuse projects).
Read full responseMeeting 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 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
Response to Managing EU climate risks
12 Jan 2024
EurEau reaction to the Call for Evidence on Societal Resilience Managing EU Climate Risk The ability to reduce climate risks is essential to maintain societal resilience. Clearly, Europes climate crisis is first of all a water crisis. With water being essential for sustaining human life, agriculture, economic activity and many recreational activities, responding to the negative impacts of climate change means first, and foremost, resolving Europes water crisis. Several countries, in particular in the Mediterranean, see a trend towards lower annual precipitation. Central and Western European countries experience prolonged drought periods. All regions suffer from an increasing number of extreme rain events with disastrous flooding. Furthermore, rising sea levels can lead to salt water intrusion into aquifers and surface water bodies. The knock-on effects on public water supply, agriculture, industry, and energy generation can be very serious. Given the fact that there will be no resilient societies without achieving water resilience, water should be considered as a key pillar of its own right. EurEau sees the forthcoming European Climate Risk Assessment report as a valuable tool to inform and guide political decisions, develop long-term strategies and steer investments. The EU, its Member States and regions must create a framework that defines clear targets, allocates responsibilities through strong governance, and ring-fences long-term financing. EurEau supports EU-level action to supplement and strengthen national, regional and local action, including at the level of river basins. However, EU-level action should encourage, rather than limit, flexibility in adopting regional or local solutions. It will be crucial to encourage solutions that work with nature (nature-based solutions) rather than against it, for example by re-establishing the natural water retention and storage capacity of soils and wetlands. All sectors must contribute to mitigation to increasing water scarcity caused by climate change, particularly through water efficiency measures in agriculture and industry, but also for example in setting rules for the design of new buildings. Furthermore, measures must be taken to mitigate the impact of climate change on the pollution of water resources, in particular by preventing the release of hazardous substances at the source. The European Commission will present its Water Resilience Strategy in March 2024. Every human activity affects the water cycle, both in terms of quality and quantity. Therefore, it is of the utmost importance that silo thinking is avoided and this strategy becomes the sound pillar of measures to manage EU climate risks. In this context, the output of the ATG Water Scarcity and Drought (Common Implementation Strategy of the Water Framework Directive), and in particular, the recently published European Drought Risk Atlas (https://op.europa.eu/en/publication-detail/-/publication/21a1984a-7478-11ee-99ba-01aa75ed71a1/language-en) and the European Drought Impact Database (EDID) (https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/b07186de-0e6d-4acc-a511-2f54559aba8e/details) should be used.
Read full responseMeeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur)
24 Nov 2023 · Urban Wastewater Treatment Directive
Response to Drinking water - procedures and methods for testing and accepting final materials
15 Nov 2023
Article 2 Definitions Def. 16: It should be clear that all substances includes organic substances not on the positive lists, as they are not expected to be present in drinking water at levels exceeding 0,1 µg/l and inorganic constituents in cementitious materials Def. 18: The definition should not include the type of material because microbial growth is not limited to organic and cementitious materials, it can occur on other materials as well Annex I - §2.2.3.b & Annex III - §2.2.3.b Starting substances that are not on the positive list should not be allowed in organic materials or cementitious materials, even if their migration rate is not exceeding 0,1 µg/L and these are not classified according to REACH and CLP regulations These provisions are loopholes that will reduce the confidence that drinking water suppliers can have in the legislation based on article 11. There is a contradiction between article 11 and Annex V of the DWD. Article 11, 4. says that The European positive lists shall contain the only starting substances, compositions or constituents that are authorised for use [...]. The possibility to use other substances than those on the positive lists is introduced in the Annex but is excluded in the main text Annex III Fly ash can be added to concrete for cementitious materials and up to 5% residual carbon is allowed in fly ash. The amount of unspecified organic substances that are unintentionally added to concrete with fly ash could be as high as the addition of intentional added substances that are on the positive list. Therefore fly ash should be considered to be an organic constituent of cementitious materials Annex I §2.2.1 Values of 0,02% for RG1, 0,05% for RG2 and 0,1% for RG3 should be removed. All substances intentionally added in a product should be declared without thresholds Annex I §2.2.4 Tables 2 & 3 LOD (Limit Of Detection) should be changed to LOQ (Limit Of Quantification) Annex I §2.2.4 Tables 3 & 4 The large difference of MTCtap between primary aromatic amines and secondary amines is not justified: some of these secondary amines are also aromatic. Moreover, secondary amines can lead to nitrosamines especially in case monochloramine is used as disinfectant. The lower of the two MTCtap should be retained The LOQ for nitrosamines should be lowered to 10ng/L, in line with drinking water parametric values in some Member States Annex I Chapter 3 As a general comment, the year of publication of an EN standard should not be mentioned as these standards could be revised in the future Annex I Chapter 4 Table 6 Per the Precautionary Principle, the MTCtap should be set at 0,1 µg/L. Act 1 states that The acceptance methodology should be based on a reasonable worst-case risk assessment of each relevant substance. An approach such as the Threshold of Toxicological Concern recommended by EFSA should be used. This applies to both identified substances without a known MTCtap and unidentified substances. For the sum of unidentified substance it is advised to set the MTCtap at 0,5 µg/L Annex I Chapter 4 §4.3.1 & Annex III §4.3.1 The pass/fail criteria for TON, TFN is set at 8.0 for the 3rd migration period or for the 9th migration period. This criteria is less severe than the one used by some Member States, e.g. Denmark where the criteria is set at = 1.0 for the 3rd or 9th migration periods Annex II Chapter 3 - §3 & 4.2 The reference to the dynamic rig test method described in EN 15664-1 should be included, as it is in Act 1 Annex III Chapter 3 - §3.1 The testing conditions should refer to EN 14944-1 and 14944-3 for experimental conditions Annex III Chapter 3 - §3.2.2 Refer toEN 15768, similarly to organic materials Annex III Chapter 3 - §3.2.3 Refer to EN standards for TOC, odour, flavour, colour, turbidity, as with organic materials Annex III Chapter 3 - §3.3 Refer to CEN/TR 16364, similarly to organic materials
Read full responseMeeting 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 Establishing harmonised marking to be used for products in contact with drinking water
13 Nov 2023
EurEau represents Europe's drinking and wastewater sector. We encompass 37 national water services associations including public and private operators from 32 countries. Together we promote the access to safe and reliable water services for Europes citizens and businesses, the management of water quality and resource efficiency through effective environmental protection. Article 2: The marking does not refer to the Drinking Water Directive. "Suitable for drinking water" doesn't indicate the reference or justification. The text could be replaced with a reference to the Drinking Water Directive. If the text is replaced with the Directive's reference (Directive (EU) 2020/2184), no translation will be needed. Annex - §1: The proposed symbol seems unpractical to affix to many types of products. The symbol consists of three picture elements: the twelve stars, the tap and the glass. A simpler symbol, for example just the glass, will just as effectively show that a product is suitable for drinking water.
Read full responseMeeting with Martin Hojsík (Member of the European Parliament, Rapporteur)
13 Nov 2023 · Soil Health Law
Response to Drinking water - methodologies for establishing and amending the European Positive Lists
10 Nov 2023
EurEau represents Europes drinking and wastewater sector. We encompass 37 national water services associations including public and private operators from 32 countries. Together we promote the access to safe and reliable water services for Europes citizens and businesses, the management of water quality and resource efficiency through effective environmental protection. Annex I Introduction Definitions Inorganic constituents of cementitious materials are not regulated in the acts. Since the concrete industries are rapidly changing and are looking for alternatives to Portland cement clinker as binder for concrete there is need for a regulation of alternative binders such as slag, fly ash, silica fume, volcanic ashes and others. The regulation of materials in contact with drinking water should include inorganic constituents of cementitious materials. Annex II Table - 2.5.2 Composition of metallic materials The manufacturing process should be taken into account on a relevant level of details. The manufacturing process is not always the same even when the composition of the metallic material is the same. Annex V - Section 1 - No standard information or testing Add substances for which EFSA has published a scientifically based opinion on tolerable daily intake to the list of cases when no standard information or testing is required. Annex V Section 2 Part 1 - §1.4 The principle "the higher the migration, the greater the amount of data required" should be substituted by the precautionary principle and an approach like the TTC recommended by EFSA. If Ctap < 2.5 µg/L and the toxicity of the substance is high, the first approach could not guarantee that the data generated to fulfill the information requirements are adequate for risk assessment. (See EFSA Guidance https://doi.org/10.2903/j.efsa.2019.5708 ) Annex V - Section 2 Part 1 Tables 1 to 3 In tables 1 to 3, migration concentration limits are defined at 2,5 µg/L and 250 µg/L. It should be clarified how these limits were defined. Some substances can have toxicological effects others than mutagenicity and genotoxicity at concentrations lower than 2,5 µg/L. PFAS are a good example of immunotoxic compounds with a low migration concentration from materials, certainly below 250 µg/L. The migration concentration cannot define the toxicological properties to be provided. All substances should be evaluated according to the same toxicological properties and their migration concentration limit should be defined according to their toxicity. Annex VI Section 1 - §3 The draft ECHA guidance document on the drinking water directive (Guidance on the Drinking Water Directive. Volume I: Methodologies for testing starting substances, compositions and constituents for use in the manufacture of materials or products in contact with water intended for human consumption. Draft Version 1.1) requires Mutagenicity studies, not Genotoxicity studies. Table 4 (p78) in Chapter 6.3 of this document mentions Mutagenicity studies in case of Low migration tier Ctap < 2.5 μg/l. But point 2.4.1 says "If the Ctap < 2,5 µg/l and screening genotoxicity tests are negative: MTCtap = 2,5 µg/l". Annex VI Section 2 Part 2 - § 2.4.2 Technical detail to be corrected: The ALF factor should be set at 0,1, similarly to Chapter I.4 in Annex 6, where a specific migration limit divided by 20 is used (0,1/2= 1/20)
Read full responseResponse to Drinking water - establishing the European Positive Lists of starting substances
10 Nov 2023
EurEau represents Europes drinking and wastewater sector. We encompass 37 national water services associations including public and private operators from 32 countries. General comment EurEau supports the full ban of all PFAS uses, including all PFAS starting substances in Annex I Table 1 of the Annexes of Act 2. There are at least 14 PFAS in the EUPL list. Some compounds (for example EUPL 0757, 0752 in Annex I Table 1 of the Annexes of Act2) have these characteristics: 1. technical function is not monomer 2. not having a harmonized classification under REACH- No data available The TOTAL PFAS parametric value under DWD is 500 ng/L. For the interim period before total ban of PFAS, it must be noted that accepted migration cant cause exceedance of the parametric value in drinking water. The Draft Act 4 Annexes Annex I. 2.2.3 Acceptance of starting substances allows migration up to 100 ng/L, which too much to comply with e.g. the PFAS requirement in drinking water. Unless and until a full ban is in place, per- and polyfluoroalkyl substances should be systematically tested due to their widespread dissemination in the environment, since PFAS are a major issue in EU and should be considered as an obliged migration parameter to be tested. (See OECD Portal on Per and Poly Fluorinated Chemicals) Recital 1 The Recital states that Sacrificial anodes, membranes and ions exchange resins are water treatment chemicals and/or filter media and are covered by Article 12, therefore they are excluded of the scope of Article 11. Membranes and ion exchange resins should not be considered as treatment chemicals and/or filter media. These materials are produced by polymerisation processes including monomers and other additives. Moreover, updated EN-standards to test membranes (EN 12873-4:2021) and ion exchange resins (EN 12873-3:2019) as products intended for use in contact with drinking water are available, membranes and ion exchange resins should not be excluded from the scope of article 11. This restriction should be deleted and membranes and ion exchange resins should be included in the scope of all these Acts. Recital 3 It should be clarified how the Member States should provide the information that is needed to determine the allocation factor. Article 3 Water services are continuously buying materials from the market for their investments and operational needs. They often purchase these materials and reagents with contracts spanning several years and use the resulting stocks for many more. Therefore some of these materials that will be bought before the date of entry into force of this Act (31 December 2026) may be used after the end of the transition period (31 December 2030). The Act should clarify that the authorization applies only to products and materials purchased after 2026, so that existing stocks of materials and spare parts constituted before 31 December 2026 do not have to go to waste after 2030. Annex 1 Table 1 All substances should first be assessed according to REACH and CLP legislations before the first publication of the positive lists. For example, tetrafluoroethylene is categorized as Carcinogenic 1B according to the REACH regulation 1907/2006. We observe that some PFAS (e.g. EUPL 222) do not have the same Maximum Tolerable Concentration as others substances of the perfluoro- and polyfluorocarbon group (PFAS). First, all PFAS substances should be considered as a group of chemicals where all individual substances must be considered equally. Next, all PFAS should also be assessed in priority before the positive lists will be published. We are in favor of a full ban on PFAS taking into account that some Members States apply more stricter parametric values than the European parametric values for drinking water In general, any substance with a significant health danger should be removed from this list before its first publication.
Read full responseResponse to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')
10 Nov 2023
EurEau represents Europes drinking and wastewater sector. We encompass 37 national water services associations including public and private operators from 32 countries. Together we promote the access to safe and reliable water services for Europes citizens and businesses, the management of water quality and resource efficiency through effective environmental protection. Recital 4 It is stated that the Commission should be empowered to request the Agency to prepare and submit an application. It is not clear what process will initiate a request from the Commission to the Agency and does it mean that a national public authority cannot submit an application ? Recital 8 Recital (8) states that Sacrificial anodes, membranes and ions exchange resins are water treatment chemicals and/or filter media and are covered by Article 12, therefore they are excluded of the scope of Article 11. Membranes and ion exchange resins should not be considered as treatment chemicals and/or filter media. Membranes and ion exchange resins are produced by polymerisation processes including monomers and other additives. Moreover, updated EN-standards to test membranes (EN 12873-4:2021) and ion exchange resins (EN 12873-3:2019) as products intended for use in contact with drinking water are available. EurEau considers that membranes and ion exchange resins evidently fall under the scope of article 11. To avoid misunderstandings the following phrasing could be used: Membranes and ion exchange resins are produced by polymerisation processes including monomers and other additives therefore they are in the scope of Article 11. Chapter III Article 3 - §6 The text should specify whether a competent authority can ask for an application covering several starting substances, compositions, organic constituents, nanoforms or entries. Chapter III Article 6 Who constitutes interested parties should be specified.
Read full responseMeeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and
28 Sept 2023 · Soil Health Law
Meeting with Manuela Ripa (Member of the European Parliament, Rapporteur)
20 Sept 2023 · Detergents Regulation
Meeting with Maria Arena (Member of the European Parliament, Shadow rapporteur)
18 Sept 2023 · Detergents
Response to Revision of EU rules on textile labelling
11 Sept 2023
EurEau welcomes this initiative. The revision should be used to steer textile consumption patterns in a more sustainable direction by increasing transparency on environmental impacts and, hence, make sustainable practices more visible. Textile life cycles strongly affect the quality and quantity of water resources. Consumers need more reliable, verifiable and standardised information on these impacts in order to make informed choices. Therefore, textile labels and digital product passports should comprise the following additional information: Release of hazardous substances: Production, transport, use, cleaning and end of live of textiles may release hazardous chemicals to urban waste water and the environment, including persistent substances such as PFAS, and other textile additives such as antibacterial silver. Consumers should be informed about the following: Clear indications on biocides used in textiles. Theoretically, this is already required by Article 58 of Regulation 528/2012 (Biocidal Products Regulation (BPR) but, in practice, it is hardly done. The labelling requirements of the two Regulations should be coordinated to avoid duplication. The European Commission is committed to phasing out all non-essential PFAS uses. Some textile producers have already stopped their use while others lag behind. With a view to encouraging innovation, labelling should inform consumers on the application of PFAS on textiles. Labels should include information on all other hazardous substances that may be released from textiles during their life cycle (dyes, preservatives, metals, flame retardants etc.). Source of microplastics: Synthetic textiles may release microfibres throughout their lifecycle. The washing of synthetic textiles alone releases 18,50046,200 tonnes of microfibres/year in the EU (https://ec.europa.eu/environment/marine/good-environmental-status/descriptor-10/pdf/microplastics_final_report_v5_full.pdf). It is estimated that around 35% of microplastics in the oceans originate from synthetic textiles (Boucher, Friot Primary Microplastics in the Oceans: A Global Evaluation of Sources, 2017). More than 1,900 fibres are shed per washing cycle and garment (Browne, Crump et al Accumulation of microplastic on shorelines worldwide: Sources and sinks, 2011). Urban wastewater treatment plants may act as a pathway for microfibres to the environment despite the fact that the can reach removal efficiencies of up to 99% (Enfrin, Dumée, Lee Nano/microplastics in water and wastewater treatment processesorigin, impact and potential solutions 2019). However, expecting the final barrier between human activities and nature to solve this problem is against the Control-at-Source principle, unsustainable and hampering nutrient and resource recovery from wastewater and sewage sludge. Producers/importers should therefore be required to inform consumers on the quantity of microfibres released from synthetic textiles over their full life-cycle based on a harmonised test method. Highly water-intensive sector 2,700 litres of fresh water are needed to make a single cotton t-shirt, (https://www.europarl.europa.eu/RegData/etudes/ATAG/2020/656296/EPRS_ATA(2020)656296_EN.pdf), enough to meet one persons drinking needs for 2.5 years. Although most of this water use occurs outside Europe, we should press for the sustainable use of scarce fresh water resources world-wide. Using the label to indicate the amount of water needed to make a piece of textile may positively influence peoples purchasing choices.
Read full responseEurEau urges realistic leakage targets in EU water taxonomy
3 May 2023
Message — EurEau requests more flexible leakage reduction targets and alternative indicators to the Infrastructure Leakage Index. They also seek to include biosolids application in circular economy investment rules.12
Why — Adjustments would prevent well-performing water utilities from being excluded from green investment opportunities.3
Impact — Environmental protections may weaken if projects causing water body deterioration qualify as sustainable.4
Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)
2 May 2023 · Urban wastewater treatment
Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur)
16 Mar 2023 · Recast of the UWWTD
EurEau demands longer deadlines and producer-funded wastewater upgrades
22 Feb 2023
EurEau urges stricter chemical standards to protect drinking water
21 Dec 2022
Message — EurEau supports classifying persistent and mobile substances as hazardous to facilitate their eventual phase-out. They advocate for more ambitious mobility criteria and a ban on industrial discharges into urban sewer systems.123
Why — Preventing these chemicals from entering water sources reduces the technical and financial burden on water treatment facilities.4
Response to European Critical Raw Materials Act
25 Nov 2022
EurEau wishes to comment on this initiative as follows: Political context: The inclusion of resilience and security in the analysis of the criticality of raw materials is welcome. We strongly believe that public health protection should be added. All sectors covered by the forthcoming Critical Entities Resilience Directive, including drinking water and waste water services, should be covered by the Act. This is not only a matter of policy coherence but, given current supply disruptions, an urgent matter of ensuring the continued delivery of these services. Problem the initiative wants to tackle: The low diversification of supply sources is indeed problematic. However, the interdependencies between sectors and their repercussions on the delivery of essential services need to be considered, too. The current legislative framework is indeed not supporting the circularity of critical raw materials. The proposed approach focusses on (mineral) raw materials sourced in third-countries. It must also address the impact of high energy (gas) prices on production processes within the EU that are part of the value chain for raw materials required for the delivery of essential services. Objectives and policy options: The criteria to determine strategic critical raw materials should comprise the continued delivery of essential services, as defined by the Critical entities Resilience Directive. This requires an analysis of their respective supply chains, potential interdependencies with other sectors and related risk factors. For example, if one sector suspends production due to supply disruptions or excessive energy costs, but critical entities depend on a by-product of this production process, then the delivery of the essential service is jeopardised. Likewise, the necessary reduction of fossil fuel use may affect the recovery of critical raw materials. As a matter of example, most processes to recover phosphorous from the ashes of sewage sludge incineration use acidic leaching. The acids are often by-products of other industrial processes, mainly from the treatment of sulphur-containing gasses in the petrochemical industry. Depending on the quality of the sulphur produced, the major part is then converted into sulphuric acid, which is the largest bulk chemical in the world with a production of more than 150 million tons/p.a. Of this, about 60% is used for the production of phosphoric acid and phosphate fertilisers, another 10% for the production of TiO2 pigments, and the remaining 30% for numerous purposes including the production of coagulants (metal salts) used in the water sector. As fossil fuel use will decrease over the coming years, ensuring the availability of acids needed for phosphorous recovery and technical agents for the water sector is critical. If the Act wants to improve the circularity of critical raw materials, it must trigger the revision of certain EU legal acts. For example, regulation (EU) 2019/1009 (Fertilising Products Regulation) should set a minimum share of phosphorous from organic sources in fertilising products. This share should increase over time.
Read full responseEurEau backs mandatory digital records for pesticide use
2 Nov 2022
Message — EurEau urges the Commission to adopt the digital recording rules immediately without reducing their scope. They request that records be stored for ten years to allow for long-term water quality tracing. Additionally, they advocate for training programs to assist farmers with the transition.123
Why — Digital data simplifies risk management and helps water suppliers identify contamination sources faster.45
EurEau backs new hazard classes to protect drinking water
18 Oct 2022
Message — EurEau supports classifying persistent and mobile substances as hazardous to facilitate their phase-out under REACH. They advocate for stricter mobility criteria and banning industrial discharge of these chemicals into urban sewers.12
Why — Stricter source controls reduce the presence of hard-to-remove chemicals in drinking water resources.34
Impact — Industrial companies would face bans on releasing specific hazardous substances into sewer networks.5
Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)
20 Sept 2022 · Industrial Emissions Directive
Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)
16 May 2022 · Water policy and the zero pollution ambition
EurEau demands mandatory recycled nutrient blending in fertilizers
26 Apr 2022
Topic — This consultation addresses the EU’s plan to reduce nutrient pollution from nitrogen and phosphorus.
Message — EurEau regrets the lack of revision for the Nitrates Directive and CAP plans. They suggest introducing compulsory requirements to blend recovered nutrients in all mineral fertilisers. They also recommend strong control at source to prevent pollutants entering waste water.123
Why — Stricter agricultural rules would reduce the purification costs for water utility companies.4
Impact — Mineral fertilizer companies would face higher costs due to mandatory blending rules.5
Response to Revision of EU rules on Gas
1 Apr 2022
The wastewater services sector currently produces biogas that can be upgraded into biomethane. In some Member States biogas is mostly upgraded to biomethane for injection into the gas network. There is significant potential, and more recently growing necessity, to ramp up the volume of biomethane and biogas produced by wastewater service providers.
Despite this potential and necessity, in some Member States barriers have been put in place (or remain) for biomethane discharge into grids or are taxed excessively which has jeopardised the deployment of renewable gas production.
As more and more on-site renewable electricity production is deployed by water service providers in the coming years and decades, it is in some water services highly likely that the production and supply of this renewable electricity will exceed the water service providers’ own demand. This will present an opportunity for water service providers to use this excess renewable electricity to produce renewable Hydrogen. This potential for future hydrogen production at wastewater treatment plants (WWTP), is an exciting opportunity and this option should remain open. Early mover demonstration projects will need supports and incentives.
To achieve the targets for the decarbonisation of the gas sector it is necessary to remove existing regulatory barriers and create the conditions for this to take place in a cost effective manner.
EurEau supports the provisions in the proposal of Regulation on the internal markets for renewable and natural gases and for hydrogen. In particular, we stress the importance of the following articles.
Art. 3: General Principles
Gas markets should be operated by promoting the integration of the energy market. Renewable electricity, biogas and biomethane, heat, renewable hydrogen and other forms of energy produced at the WWTP need an affordable and seamless pathway into the energy market.
Thus, we support that market rules shall enable the decarbonisation of the natural gas and hydrogen systems, including by enabling the integration into the market of gas from renewable energy sources and by providing incentives for renewable energy generation, energy efficiency and GHG emission abatement.
Art. 6: Third-party access services concerning hydrogen network operators
Green Hydrogen has the potential to be produced by water service providers whereby excess renewable electricity produced on site can be used to produce renewable Hydrogen. This Hydrogen will displace the need to use natural gas and can be used onsite or injected into the gas network pipeline.
In order to allow the future integration of hydrogen into the hydrogen grids, we support that network operators shall offer their services on a non-discriminatory basis to all network users.
Art. 8, 18 and 33: Ensure and promote access to the gas grids for renewable and low carbon gases
The promotion of biomethane as an alternative to natural gas requires to ensure access to the gas grids removing the existing barriers.
We therefore support that LNG and storage system operators shall, at least every two years, assess market demand for new investment allowing the use of renewable and low carbon gases in the facilities, and transmission and distribution system operators shall ensure firm capacity for the access of production facilities of renewable and low carbon gases connected to their grid.
Art. 16: Tariff discounts for renewable and low carbon gases
The incentives for biomethane production and injection are necessary to booster the substitution of fossil gases. EurEau supports the discount policies for renewable and low carbon gases at entry points from production facilities, interconnection points and from entry and exit points at storage facilities.
Further reading:
EurEau Position paper on Energy and GHG emission reduction objectives for the European water sector under UWWTD
https://www.eureau.org/resources/position-papers/5815-position-paper-on-climate-mitigation-in-the-uwwtd/file
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
16 Mar 2022
EurEau is the European federation of water services representing drinking water and waste water operators from 29 countries. We welcome the initiative of the Commission to propose a Soil Health Law in order to provide a comprehensive EU legal framework for soil protection which will grant the same level of protection as for water and air.
All the aspects considered in the impact assessment are key for protecting soil health. Having in mind the strong nexus between soil and water, we particularly support:
1. adequate integration and coordination of soil and water management
2. measures that can contribute to reducing nutrient losses by at least 50% without deterioration in soil fertility
3. requirements for the sustainable use of soil so that its capacity to deliver ecosystem services is not hampered
4. monitoring and reporting on the condition of soil
5. options to identify, register and remediate contaminated sites, and to apply the polluter pays principle
6. the development of indicators for soil health and a strict range of values
7. reporting on the progress in managing soil contamination
Healthy soils for protection of drinking water resources
Unhealthy soils and their continuing degradation have adverse effects on drinking water resources. EurEau emphasises the important roles of soil to adsorb and withhold substances from water. Healthy soils are therefore essential ecosystems for the water sector in delivering valuable natural functions such as water purification and infiltration, nutrient regulation and pest control. If they are not compacted they also contribute to safe percolation and groundwater recharge. The Soil Health Law should include concrete objectives to support the protection of drinking water resources, improves groundwater and surface water quality and quantity and thereby contributes to reaching the WFD objectives. This requires among others reducing agricultural emissions from fertilisers and pesticides, remediating contaminated sites, address at source diffuse soil contamination by atmospheric deposition and waste disposed on land and take preventing measures.
Healthy soils for climate resilience
Soils are vital for rainwater management. An uncompact soil with sufficient organic matter is a buffer for the water system, prevents soil erosion, increases the rainwater filtering capacity, reducing drought and flood sensitivity and thereby contributing to climate change resilience. Therefore, restoring the pervious function of soils is crucial. Peatland and wetland help to fill aquifers for overcoming dry periods and can reduce spills of untreated waste water from sewers during heavy rains.
Restoring organic soils will also help meeting the climate neutrality objective as they capture and store carbon.
The Soil Health Law should enshrine the interdependence between water and soil. It should support developing knowledge on the positive role healthy soils play in reducing diffuse pollution to water, mitigating and adapting to climate change.
Biosolids to restore soils
As mentioned in the roadmap, a large portion of EU soils suffers from bad physical and/or chemical conditions that increase erosion and reduce fertility and biodiversity. Sewage sludge, resulting from the treatment of urban waste water, consists mainly of water, carbon, nutrients and some residuals (trace elements, metals). Appropriate treatment transforms sewage sludge into biosolids which help to restore soils in good condition. By recycling carbon and nutrients and therefore reducing the need for chemical fertilizers, biosolids also contribute to the Green Deal ambitions. To do so, the 86/278/EEC Directive, currently under evaluation might need to consider a wider range of parameters and enlarge its scope to other uses than agriculture to help land restoration. EurEau agrees that this has to be done based on robust scientific evidence with the overall objective to improve quality of soil by applying good quality biosolids on land.
Read full responseResponse to Review: Restriction of the use of hazardous substances in electronics
14 Mar 2022
EurEau welcomes the revision of the RoHS directive which should lead to a clearer scope and simplified, but effective processes to phase out hazardous substances and protect public health and the environment.
EurEau believes that the directive should not be maintained as it stands limiting changes to certain non-legislative measures.
The impact assessment should show whether it is better to revise the RoHS directive or include the provisions in REACH or the Sustainable Products Initiative.
Whatever the legislative tool, the following should be taken into account:
• Both the ‘Scope’ and the ‘Definitions’ need to be improved and clarified. After years of use, drinking water and waste water operators still do not know whether disinfection units using mercury-based UV low pressure and medium pressure discharge lamps are included in the scope or are considered as ‘large-scale fixed installation’.
• The wording of the ‘exemptions’ is often confusing leaving doubts whether a specific application is covered and, if this is the case, by which of the exemptions.
• The future provisions should adopt a holistic approach. Instead of limiting the amount of a hazardous substance per EEE, it should look at the required performance to fulfil a certain function. As a matter of example, the limitation of mercury content in UV discharge lamps to 15 mg may mean that one large and efficient lamp is replaced by several small ones with a higher total mercury content.
• The future requirements should facilitate the proper disposal or, whenever possible, the circularity of the hazardous substances in the uses covered by exemptions. Many European countries already regulate the circular economy of mercury-added products efficiently, for example through take-back obligations and the recycling of used low pressure discharge lamps.
• Provisions should be introduced related to recycled material and critical raw materials.
• The provisions for spare parts should be improved.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
21 Feb 2022
The European Commission is looking at revising the Waste Framework Directive in order to improve recycling and reuse of wastes and products and to specifically address oil wastes.
EurEau, the European Federation of Water Services, represents waste water services providers who can recover a lot of materials from urban waste water treatment streams. The key issue for the sector is properly recycling these materials, as the Waste Framework Directive today does not create the conditions for securing a market for secondary resources. Waste water contains a huge variety of resources besides the water itself, e.g. phosphorus, nitrogen and many micronutrients, carbon/organic matter and chemically-bound energy. Waste water operators therefore urgently need an End-of-Waste status for good quality materials recovered from waste water treatment streams in order to unleash the huge potential and facilitate access to a proper market. It is important that the ‘good quality’ of the reused waste is in focus, instead of the origin of the waste. We have collected examples on this market in factsheets for certain products (https://www.eureau.org/news/606-valuing-our-recyclable-materials). There is also a large potential to recover more products in the future, with financial support of this sector that is very active in research and innovation.
Some issues also arose in certain Member States, in which separate collection is also applied for the waste treatment. In these Member States, sewage sludge is not allowed to be mixed with biowaste, for example, to produce biogas or compost. This creates a barrier for the production of renewable biogas or organic fertiliser. Mixing sewage sludge and biowaste improves the digestion process and produces more biogas than digesting both wastes separately. In certain regions, mixing wastes, collected separately to ensure traceability, to produce biogas or compost is the only viable solution to reach the critical size of the installation. It is therefore be crucial to explicitly allow the mixing of waste with similar characteristics, as long as they have been collected separately and that the quality of the individual waste does not hamper the quality of the final product. For the latter, the implementation of control at source of contaminants entering sewer systems should be reinforced in order to guarantee the quality of sewage sludge. For more details, EurEau published a Briefing Note on sewage sludge management (https://www.eureau.org/resources/briefing-notes/5629-briefing-note-on-sludge-management/file).
This principle should specifically apply to vegetable oil waste from restaurants and households that are improperly disposed into sewers which can lead to blockages, also known as fatbergs. It results in environmental burdens due to the overflow of untreated waste water into water courses, but also in high maintenance costs for water operators and ultimately for the water consumer. It is therefore of utmost importance that vegetable oil waste is disposed of in proper containers with the view to increasing recycling as recommended in the roadmap.
Finally, in order to better assess the fraction of waste that is effectively recycled or reused, it is crucial to have the right monitoring. The data collected needs to reflect the nature and the volume of waste collected, treated, recycled and reused. It is the only way to take the right decision regarding waste streams and avoid barriers due to a lack of information. For example, in France, the absence of data on sludge and biowaste ratio in co-composting nearly led to the ban of co-composting as some stakeholders were arguing that there was not enough biowaste to co-compost sludge. More accurate data on the nature and volume of waste collected will help to find the optimal recycling streams for certain waste, define appropriate targets and therefore rationalise investments.
Read full responseResponse to Ecodesign requirements for water pumps (review)
18 Feb 2022
EurEau is the European Federation of Water services representing both drinking water and waste water service providers. We are therefore very involved in the use of water pumps and aware of the different constraints for using such pumps in practice.
We support that energy-efficient technologies play an important role in achieving climate policy goals. With the EU Ecodesign Directive (2009/125/EC) and its implementing regulation 547/2012, the energy consumption of water pumps has already been reduced significantly.
The energy efficiency of pumps is a major concern for drinking water service providers as energy is an important part of the operation costs. The energy consumption associated with drinking water pumps is inevitable to providing sufficient water pressure to our customers and during the production process. Water has to be pumped up in sufficient quantities, and processed through a series of purification steps, which are designed to optimise energy use. However, water quality gets always the priority on energy savings.
Pumps are generally optimised for energy consumption, given their task and even the least efficient have high energy efficiency standards. Some types of pumps like tank emptying pumps are low energy consuming because of their short operating time. The possible energy savings on these pumps are very limited. A stringent Directive may indirectly put pressure on water operators to replace pumps earlier in their life-time. In addition to unnecessary investments putting the affordability of water services at risk, the GHG emissions due to the production phase may not be compensated by the small energy saving of its operation. On the positive side, competition pushes manufacturers to produce pumps consuming less, especially with an increasing electricity price.
Moreover, water services providers are often implementing an environmental management system to control and reduce their ecological impact. They are working continuously to improve their energy efficiency, using the most energy-efficient products available on the market if necessary.
The extended product approach of pumps offers the opportunity to achieve significantly higher efficiencies with a coordinated pump system rather than with individual components not achieving their individual performance after assembly. Speed control can unfold its energy advantages whenever the optimum operating range of a water pump or a group of water pumps is adapted to the system load. However, speed control is not recommended for operation at only one operating point or for very short operating intervals. Speed control also results in more complex pumping systems, which create additional risk of failure. With restricted budgets, the redundancies of pumps - crucial for the resilience of the service - may be reduced. It is also difficult to adapt an existing installation and often requires a completely new one. The overall impact, both financial and environmental, might therefore not be positive for the end-user.
The burden associated with the introduction of an energy label for water pump units should be supported by the manufacturer and not by the water service providers. It is also important that the label reflects the operational conditions and are based on a clear, transparent and sound methodology that can be understood by end-users.
EurEau supports the requirements for the circular economy. The GHG emissions generated during the manufacturing or dissembling/disposal of a water pump are important for GHG accounting of drinking water operators. Therefore, we support regulations that encourage manufacturers to provide information accordingly, promote innovation and reparability. Manufacturers should be able to obtain certificates of origin for raw materials and semi-finished products to certify that they have been extracted and manufactured under ecological conditions and respect human rights.
Read full responseResponse to Measures to reduce microplastic pollution
22 Dec 2021
EurEau wishes to comment as follows:
- The provisions of Article 192.2 (TFEU) must be respected.
- The lack of harmonised test methods should not delay action, as there is ample evidence of microplastics in all environmental compartments.
- The EU has so far failed to tackle MP at source. The legal acts, this initiative wants to link with, are ‘end-of-pipe’ directives (UWWTD, SSD, GWD, EQSD). The proposed control-at-source measures for MP are insufficient.
- The initiative largely ignores the Green Deal by focussing on technical feasibility and enforcement instead of starting from EU ambitions on climate, zero pollution, circular economy, soil health, etc. It tackles symptoms, leaving the root causes (fast fashion, excessive car use) untouched.
Source control measures for MP must have priority to protect the water cycle from MP contamination. All by-products from waste water treatment should be available for re-use in-line with circular economy goals.
- While waste water treatment plants (WWTP) remove 80-99% of MP from the water phase, a substantial share is transferred to the sludge. In certain locations, this may jeopardise the recycling of nutrients and other materials, and lead to incineration as the only option, causing additional CO2 emissions. This contradicts the Green Deal.
- Combined sewers: MP may be directly released to surface water during overflow events. EurEau supports the COM’s intention to reduce combined sewer overflows through the UWWTD. However, overflows are part of the system and necessary to reduce urban flood risks. They cannot be avoided completely.
Tyre wear particles (TWP):
- TWP are a larger MP source than synthetic textile fibres.
- Separate sewers: TWP from road run-off may be released directly to surface water. Installing and maintaining gully filters everywhere would be an expensive and unsustainable measure.
- Nature-based solutions along road sites reduce/avoid storm water in sewers by leading it to ponds/rain gardens etc. In the light of climate change. EurEau supports such measures.
Textiles:
- The obligation to equip washing machines with MP filters is only acceptable if the technology prevents any subsequent fibre spills in the urban water cycle (rinsing in sinks).
- To our knowledge, ‘technologies to avoid mixing MP with sludge in WWTP’ do not exist and seem extremely difficult to develop. This solution is not sustainable.
Plastic pellets:
Greater control around the use, handling and management of pellets is required to implement source control measures. See for example PAS 510:2021.
EPR:
- The European Court of Auditors criticised the poor application of the polluter-pays principle (Special Report 12/2021). Encouragingly, the Commission considers EPR to finance downstream measures.
- If action needs to be taken along the value chain, polluters should bear the costs. For the water sector, this includes road run-off filters and changes to sludge disposal management.
- EurEau conducted a study covering EPR for TWP and plastic textile fibres.
(https://www.eureau.org/resources/publications/eureau-publications/4380-deloitte-eureau-report-extended-producer-responsibility-modules-1-2-3/file)
Economic impacts:
- WW operators / municipalities face massive costs if they have to bear the burden of avoiding MP release to the environment (treatment of road run-off, sludge disposal management, MP waste disposal).
- Additional treatment at the WWTP would cost 1.84-7.6 billion €/y without any significant reduction in overall MP emissions.
Environmental impacts:
- Sewage sludge is used in many EU regions to increase the carbon content in soils (EU Soil strategy). Even more of them use recycled phosphorous and nitrogen as fertilisers from organic sources. This initiative must lead to lower MP content in sludge and so as to keep land applications open as a sustainable disposal route.
- The protection of drinking water resources must become an objective of this initiative.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Nov 2021
EurEau welcomes the Proposal for a revised Renewable Energy Directive (RED III) but regrets it doesn’t specifically address the water sector, despite its contribution to the renewable energy targets and climate policies: generation of electricity from hydraulic turbines and from on-site wind mills/solar panels, biogas from sewage sludge, electricity and thermal energy from sewage sludge mono-incineration, heat pumps and thermal energy from wastewater.
Biogas produced by the water sector can be consumed on site through cogeneration of heat and electricity or upgraded to biomethane for injection into the gas network or for vehicle fuel, becoming an alternative for transport, building and industrial sectors. Besides, the renewable energy produced in the water sector could be transformed into renewable hydrogen.
The emissions of GHG from biogas production may lead to a trade-off between energy recovery and climate neutrality. The link between the RED III, the Energy Efficiency Directive (EED) and other climate regulations should be strengthened.
The definition of biomass in the RED II 2018/2001 should be modified to duly recognise sewage sludge as a source of origin of biogas: “(24) biomass means the biodegradable fraction of products, waste and residues from biological origin from agriculture, including vegetal and animal substances, from forestry and related industries, including fisheries and aquaculture, as well as sewage sludge from waste water treatment and the biodegradable fraction of waste, including industrial and municipal waste of biological origin;”
The cost-efficient recovery of energy from the water cycle enhances renewable energy production and circular economy; is aligned with RED III objectives in terms of targets and potential deployment of renewable energy; and improves the EU energy independence while minimising pollution. This justifies the development of support schemes to address the unequal renewable energy generation in the EU and to reach the highest cost-efficient renewable energy generation potential in the urban water cycle. This support should include regulatory aspects ensuring access to the energy grids for integration of renewable energy production in the energy system. Funding should cover innovation on renewable hydrogen production at WWTPs.
We welcome the measures to support and improve the Guarantees of Origin and the Union Database. Using credit guarantees to reduce the financial risks associated with Power Purchase Agreements (PPA) might generate market distortions, so PPA should remain a market instrument.
Barriers have been raised for electricity and biomethane discharge into grids and unjustified taxation has jeopardised the deployment of the renewable generation. This should be considered in the Proposal and in related legislation. The European state aid framework should be adjusted to ensure economically viable use of biogas without additional energy tax burdens.
The water sector could contribute to the targets on district heating and cooling: thermal energy can be recovered from effluents in WWTPs or from incineration of sewage sludge.
Biomethane from WWTPs could contribute to the Proposal’s targets for the transport sector. Sewage sledge is included as advanced biofuels in Annex IX-A. However, the additional costs of upgrading biogas to biomethane need increased financial support.
The Taxonomy delegated act on climate mitigation discourages the use of biogas as sustainable vehicle fuel due to the “tailpipe principle”, which may result in reduced investments in biogas production facilities and in the upgrading of biogas to vehicle fuel. The EC should apply the technology-neutral well-to-wheels principle on emissions and consider the entire life cycle of both fuel and vehicles. The tailpipe principle should be changed from “the vehicle has zero direct (tailpipe) CO2 emissions” to “the vehicle has 75% less CO2 emissions calculated as well-to-wheels principle on emissions”.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
18 Nov 2021
EurEau welcomes the Proposal for a Directive on energy efficiency (recast) (EED) and supports the role of circular economy and the life cycle approach.
Water operators are moving towards energy neutrality, combining high energy efficiency and generation of renewable energy. The EED and the renewable energy directive (RED) must accompany and support this process, considering GHG emissions, as the link between both directives and climate policies is relevant to ensure sustainable investment decisions in the water sector.
Water operators are minimising their energy consumption through different measures. However, there are elements beyond their control with a substantial impact on energy consumption: topography, population density/growth, climate change, new quality requirements for drinking and waste water. General targets would disadvantage those who have implemented far-reaching projects, and further measures could impact water tariffs and might not be technically feasible or economically justifiable.
The aim of the water sector is to protect public health and the environment. Water operators may need to introduce additional treatment to reach new quality requirements despite this may lead to more energy consumption. Many water operators expect significant economic and population growth in the coming decades that will increase the demand for existing plants and may require new plants. Some regions will have to increase water reuse to cope with climate change impacts, but this is an energy intensive process. Hence, the generation and use of renewable electricity and/or bio-gas and bio-methane will be important when reducing GHG emissions.
We would recommend not introducing a specific energy saving target for the water sector and expressing the energy efficiency of water services not in kWh/m3 or other units, but in terms of achieving individual cost-effective saving potential identified through energy and GHG emission audits, setting a baseline at facility level from which energy savings can be deducted.
Recognising the need for the target for a final energy consumption reduction for the public sector, a specific saving target for the water sector would not be realistic, since its contribution will depend on the level of energy efficiency already achieved (and the cost effective savings potential) and the need for additional treatment steps to meet regulatory requirements.
Further clarification would be needed to determine which water operators belong to the public sector and which buildings would be covered. This is not easily deductible from the definition of “public bodies”, given the different governance and management models of water services. The term ‘enterprise’ brings confusion on the entity to which the energy consumption threshold would apply. We suggest using facility or utility as more appropriate terms for the water sector. The UWWTD, which is expected to set energy-related requirements, is better placed to address energy efficiency of the wastewater sector as it will address all operators whereas the Proposal only refers to public bodies or enterprises.
We support the mandatory energy audits for the largest energy users but energy efficiency and GHG emissions requirements should be defined in the revised UWWTD. The EED should clearly specify that these requirements only apply to energy users not covered by sectoral EU legal acts.
We stress the importance of considering the energy consumption breakdown per treatment step when identifying cost-effective savings potentials and determining GHG emissions, avoiding energy efficiency improvements that increase GHG emissions.
Considering the current lack of investments in the water sector, further achieving energy efficiency in the water sector requires important investments that should benefit from EU sustainable funding, for example through access to the LIFE Clean Energy Transition sub-programme 2021-2027.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
18 Oct 2021
EurEau welcomes the initiate to establish ‘clear definitions and overarching principles applying to both BBP and BDCP’, clarify ‘the measurement method and labelling of BBP’, and clarify ‘definitions, applications and criteria for BDCP, as well as the role of testing, labelling and certification to ensure effective biodegradation.’
There is an urgency to avoid green-washing by manufacturers and confusion among consumers. The latter might indeed think that BBP and, even more so, BDCP are ‘natural’ and easily degradable products that can be littered in public spaces or disposed of through toilets.
If this happens, they can clog sewer pipes and block pumps, hence causing significant extra costs to waste water operators. At the same time, such blockages are also damaging to the environment as they may lead to the spilling of untreated waste water through combined sewer overflows (CSOs). Incidentally, these spills represent a non-negligible pathway of plastic products to rivers and seas.
Labelling must ensure consumers are aware of the appropriate disposal route for these new categories of materials. For avoidance of doubt, the labelling must also include
- A well visible ‘DO NOT FLUSH’ logo
- An indication of the time and conditions needed for degradation.
Read full responseResponse to Revision of INSPIRE regulations - interoperability of spatial data sets and services
10 Sept 2021
While EurEau supports efforts to increase the access of environmentally relevant spatial data to the public, the EU legislation must ensure the protection of critical infrastructures / essential services to prevent malicious acts and protect people’s health and the environment. Hence, restrictions must be maintained regarding public access to information on water utility networks and production / treatment facilities. We explicitly support the retention of the exemption of access to data from critical infrastructures under article 13 (1) of the INSPIRE Directive for the sake of maintaining public security. Access to data from critical infrastructures would have adverse effects on public security. It is imperative that the security of critical infrastructures remains assured also in the future. In any possible revision of the current INSPIRE Directive, we therefore advocate to keep the exception for public security which comprises critical infrastructures irrespective of ownership or organisation in the Member States.
EurEau supports the objective of the INSPIRE directive to provide relevant data about the soil, groundwater and surface water quality. However, duplication in reporting requirements must be avoided.
EurEau invites the Commission to evaluate policy coherence in terms of data provision and reporting requirements with regards to the following directives: Water Framework Directive, Groundwater Directive, Urban Wastewater Treatment Directive, Nitrates Directive, Sustainable Use of Pesticides Directive, and the Drinking Water Directive, in particular, its article 8. And the same regarding the recent and upcoming initiatives in the field of EU digital policies, e.g. Open Data Directive, Data Governance Act, Data Act, European Approach to Artificial Intelligence, GreenData4All, etc.
Read full responseResponse to RoHS exemption for the use of mercury in other discharge lamps for special purposes
12 Jul 2021
The current exemption 4(f): "Mercury in other discharge lamps for special purposes not specifically mentioned in this Annex" should continue to cover the UV disinfection of drinking water and treated waste water to permit compliance with the Drinking Water Directive, the Water Reuse Regulation and the Bathing Water Directive.
With this in mind, EurEau calls on the European Commission to include a new exemption 4(f)-V for a five year period: “Mercury in low and medium pressure discharge lamps emitting light mainly in the ultraviolet spectrum for disinfection and treatment of drinking water and waste water” (OPTION 1 in attached file, preferred option).
Alternatively, the wording of exemption 4(f)-IV could be specified to: “Mercury in low, medium and high pressure discharge lamps emitting light mainly in the ultraviolet spectrum” (OPTION 2 in attached file, second option).
This addition will also remove the current contradiction between the explanatory memorandum of the draft Delegated Directive (Chapter 3, page 3) referring to “4(f) –IV: Mercury in lamps emitting light in the ultraviolet spectrum” and the annex referring to “4(f) -IV Mercury in high pressure sodium vapour lamps emitting light in the ultraviolet spectrum”.
Justification of the EurEau position.
Mercury-based UV low and medium pressure discharge lamps are widely used across Europe for disinfection and treatment purposes, both for drinking water to comply with the Drinking Water Directive (2184/2020/EU) and for waste water under the Water Framework Directive 2000/60/EC, the Bathing Water Directive 2006/7/EC and the Water Reuse Regulation 2020/741.
Disinfection of potable drinking water is essential for the protection of public health (for the inactivation of Protozoa such as Cryptosporidium and viruses such as Adenovirus), and as set out below, no commercially viable alternative is available today.
The characteristics of these lamps are unique, efficiently delivering the correct wavelength of UV light which denatures the DNA, damaging the genetic material of target microorganisms and protozoa which, if untreated, can harm human health. UV disinfection technology is chemical-free and easy to operate, it is suitable for small and large utilities, and has relatively low energy consumption and produces an insignificant amount to none disinfection by-products.
To illustrate the prevalence of this technology, 75% of Finnish drinking water is treated with UV disinfection. Also other countries rely mainly on this technology, i.e. the Netherlands, Luxembourg, Germany and Austria. And this trend is currently intensifying.
As to waste water, disinfection is necessary to ensure the safety of bathers and comply with the Bathing Water Directive. Moreover, treated waste water used for irrigation purposes (Water Reuse Regulation) needs to be free of bacteria to protect the consumers of crops.
Research and innovation activities for non-mercury based UV alternatives are ongoing but they are not commercially viable yet.
For disinfection and treatment in the water sector, UV lamps based on LED technology are not sufficiently developed, due to poor performance and problems with the emitted spectrum.
Water services are looking forward to LED-technology or other viable non-mercury alternatives, although we assume that at least another 10 years of development will be needed to develop LED UV lamps. A three-year extension is clearly insufficient and causes increased investment insecurity.
With regards to the disposal of end-of-life UV lamps, these lamps are taken back for recycling by the manufacturers as part of the service contract or as part of the UV lamp device certification scheme, e.g. Austria, Switzerland and Liechtenstein. A closed cycle without any environmental pollution is thus possible. In other countries, UV lamps are safely disposed in compliance with Waste Electrical and Electronic Equipment Directive and hazardous waste regulations.
Read full responseMeeting with Virginijus Sinkevičius (Commissioner) and
17 Jun 2021 · To discuss European Green Deal and Zero Pollution Ambition from the angle of protecting water resources.
Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
31 May 2021
EurEau is the European association of water service providers with 34 national member organisations in 29 countries.
~ The zero-pollution ambition from the European Green Deal delivered the Chemicals Strategy for Sustainability. One of its objectives is to better protect the environment against hazardous chemicals.
~ Drinking water suppliers 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.
~ EurEau supports the review of the Hazard Classification, Labelling and Packaging of chemicals (CLP) to amend the absence of classification and labelling for hazardous products currently outside the scope of the existing CLP regulation, in order to prevent the continued release of PMT /vPvM substances and other hazardous substances into the environment.
~ Protection of drinking water resources – groundwater and surface water bodies – must be the 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).
Hazard classification and labelling must be based on the extension of the generic risk approach.
In line with article 191.2 of the TFEU, any sustainable chemicals strategy must start from rigorous control-at-source measures and fully apply the Precautionary Principle.
For this reason, EurEau supports the extension of the generic risk approach (GRA) to all chemical substances so that they are regulated according to the intrinsic hazards they pose.
The hazard based approach should permeate the classification and labelling of CLP. This hazard approach is aligned with the measures, included in the Objectives and Policy options in the CLP IIA, i.e. “introduction of new hazard classes (such as endocrine disruptors, EDS)” and “the obligation to provide information of hazards on the label for products currently outside the scope of CLP”. New hazard classes should cover EDS, PMT and vPvM substances.
Combination effects must be determined.
EurEau supports efforts to determine and regulate the combination effects of priority chemicals and to include this in the authorisation process of chemicals. We also support the need highlighted in the IIA for clarifying “the obligations to classify mixtures and complex substances”, considering the combination effects. Close coordination with the work under the WFD, the Environment Quality Standards Directive and the Groundwater Directive is necessary.
Read full responseResponse to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
29 May 2021
EurEau is the European association of water service providers with 34 national member organisations in 29 countries.
~ Drinking water suppliers 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.
~ EurEau supports the review of REACH to close the knowledge and regulatory gaps, in order to prohibit the continued release of PMT/vPvM substances and other hazardous substances to the environment.
~ Based on the EFSA opinion of September 2020, EurEau calls for a complete ban of PFAS substances under REACH.
~ Protection of drinking water resources must be the 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).
Extension of the generic risk approach.
In line with article 191.2 of the TFEU, any sustainable chemicals strategy must start from control-at-source measures and apply the Precautionary Principle.
EurEau supports 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 Drinking Water Directive (DWD).
PMT/vPvM substances must be regulated.
The IIA policy option for reforming the restriction process includes extending the GRA to restrictions to PBT/vPvT. EurEau calls for the addition of mobility (included in the IIA to define the likely environmental impacts) and for the swift definition of PMT and vPvM substances as substances of very high concern under REACH. The intrinsic properties of PMT/vPvM pose serious long-term risks for the quality of drinking water resources.
PFAS pollution requires group restriction.
EurEau strongly supports the use of group restrictions. 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 DWD.
The PFAS Action Plan and the Commission Staff Working Document on PFAS (14/10/2020) should lead to the phase out of all non-essential uses. We support the restriction process initiated by NL, DE, DK, SE and NO, and call for this process to be expedited.
However, based on the EFSA opinion, 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, EurEau calls for a complete ban of these substances. Subsequent approval of PFAS for essential uses can be restrictively envisaged, provided the appropriate risk assessment provisions and management measures are put in place.
Combination effects and Essential uses.
EurEau supports 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. We welcome the IIA policy option to make operational the concept of ‘essential use’ when developing restrictions, providing a common definition of non-essential uses according to the Montreal Protocol.
Read full responseResponse to Evaluation and revision of the general pharmaceutical legislation
21 Apr 2021
EurEau welcomes the European Commission intention to evaluate and revise the pharmaceuticals legislative framework, as anticipated in the Pharmaceuticals Strategy, and in particular the resolve to address environmental issues and AMR.
Pharmaceutical residues represent one of the many examples of contaminants of emerging concern 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.
We believe that the pharmaceuticals legislation should contribute to the Zero Pollution ambition of the EU Green Deal since the Commission committed to mainstreaming Green Deal strategies into legislation in a coherent way.
The Pharmaceutical Strategy for Europe and the attached legislative tools must therefore go hand in hand with the Zero Pollution Action Plan on air, water and soil, as well as with the objectives of the Chemicals Strategy for Sustainability and the those of the Circular Economy Action Plan given the impact that pharmaceutical residues may have on the quality of reclaimed water and sewage sludge.
Therefore a truly holistic approach to the life cycle of pharmaceuticals should be taken. The measures to address the environmental impact of pharmaceuticals should follow art. 191(2) TFEU.
As recommended by the OECD (November 2019), mitigation efforts should prioritise source-directed and use-orientated measures.
That is why we share the Commission’s views that the Strategic Approach to Pharmaceuticals in the Environment (PiE) is an important milestone and should be fully taken into account in the legislative review of the pharmaceuticals legislative framework.
EurEau fully supports a legislative framework that favours the development of “greener” pharmaceuticals that are non-hazardous or quickly degrade into non-hazardous substances. Green procurement should be implemented and the public sector should take the lead.
The Environmental Risk Assessment should be conducted for all pharmaceuticals for human use, even those approved before 2006 and consider their impact on the quality of surface and ground water bodies, including drinking water resources.
The creation of hazardous transformation products or metabolites during drinking water and waste water treatment as well as during the treatment of sewage sludge must be investigated within the ERA. The consideration of the ERA in the risk-benefit analysis should become compulsory in the authorisation process.
Environmental data on the presence and toxicological impacts of APIs, their metabolites, degradation and transformation products (including cocktail effects) in water and their environmental fate (degradability, long-term potential activity) should be made publicly available across the EU.
Pharmaceutical substances should be environmentally classified: the experience of the Stockholm County Council regarding environmentally classified pharmaceuticals could serve as a best practice.
We support the Commission’s intention to consider advertising, marketing and prescription practices of pharmaceuticals having a negative environmental and AMR impact. An eco-label should be put in place following the environmental classification of medicines; packages should contain smaller doses of medications, as to avoid the risk that unused drugs be disposed inappropriately by households and environmentally hazardous drugs should not be sold over the counter, but only under prescription.
A full life cycle approach means that producers remain responsible for their products even after the use phase. To this end, funding mechanisms, such as comprehensive Extended Producer Responsibility schemes, should be set up to avoid that other actors, including water operators and the consumers, have to bear the financial burden of preventing the release of pharmaceuticals in the environment. The polluter-pays principle must not be replaced by the water consumer-pays principle.
Read full responseResponse to Bathing water quality – review of EU rules
1 Apr 2021
EurEau sees the Bathing water directive (BWD) as an important Union act to protect citizens’ health.
Effectiveness
The BWD is largely effective as shown by high levels of national implementation, improving bathing water quality and wide public recognition. Data quality control could be improved.
Efficiency
Implementation costs are largely proportionate to benefits with urban waste water treatment plants (UWWTP) bearing a substantial parts of them.
Coherence
The BWD is largely coherent with related Union acts. It complements the UWWTD and the WFD/MSFD with specific requirements to protect the health of bathers.
Relevance
The BWD is still relevant, also regarding recent policy developments incl. the Green Deal. It has been a driver in countries, where tourism is an important economic activity, to invest in the waste water infrastructure with the aim to avoid combined sewer overflows responsible for short-term pollution events. This role is still relevant.
EU added value
Regulating the quality of bathing waters at EU level is sensible.
General
EurEau supports the WHO recommendations and calls on the Commission to implement them in the revised BWD.
Scope
The BWD should continue to protect human health and not address environmental aspects as this would cause duplication with directives 2000/60/EC and 2008/56/EC. The definition of “bathing site” needs strengthening.
The inclusion of recreational water uses in the BWD scope is not supported:
1. The WHO study did not cover this extension, so a new study would be needed.
2. Current standards are related to bathing implying high exposure to risk factors. Other uses imply different exposure levels, hence, all indicators would need to be re-calculated for other users.
3. Monitoring requirements would sharply increase, as almost all water bodies (except most harbours) may be used for recreational purposes and this (almost) throughout the year. The notion of “bathing site” would lose its relevance.
4. Costs for UWWTP would increase substantially:
- Much longer disinfection periods;
- Many more UWWTP would have to set up disinfection.
- Deep outfalls designed to protect swimming on bathing sites would need to be redesigned to protect recreational uses in other areas.
Protection level
EurEau supports the WHO conclusion that “current evidence does not support the inclusion of a viral indicator as a regulatory parameter within the BWD” due to insufficient evidence and issues regarding detection and standardised analytical methods. Research should continue.
Cyanobacteria / dinoflagellates can be relevant in specific locations. In order to reduce burdens, risk assessments could determine the need for monitoring in line with WHO recommendations (for ex. via satellite: https://www.smhi.se/en/theme/monitoring-algae-from-satellite-1.11923). WHO guidance should enable Member States to choose which parameters to monitor (biovolume, chlorophyll-a, phycocyanin, transparency, toxin concentration). On-site indications of high cyanobacterial hazards are supported.
New parameters on emerging pollutants (e.g. microplastics, pharmaceuticals) are not supported, as they would duplicate directive 2000/60/EC and its daughter directives (see Technical Guidance for deriving EQS, version 2018). According to current knowledge, emerging pollutants in bathing waters are an environmental issue rather than a health protection issue for bathers.
Sampling frequencies
Frequencies could be increased in line with WHO recommendations. The number of samples should be fixed per month (and not per bathing season) to take account of different lengths of bathing seasons according to climatic conditions. An increased monitoring frequency will reduce the statistical effects of short term pollution events and give a more realistic picture of the water quality.
Economic impacts
Additional costs may not only occur through more testing, but also additional treatment or other requirements for waste water operators.
Read full responseResponse to Mercury – review of EU law
26 Mar 2021
The Regulation on Mercury, implementing the Minamata Convention, and addressing also dental amalgam, should be seen in the light of the EU Green Deal and its relevant Strategies such as the Zero Pollution Action Plan for a non-toxic environment and the new action plan on the circular economy.
Mercury is identified as a Priority Hazardous Substance in the Water Framework Directive, it is persistent, bio-accumulative and toxic. For this reasons, to protect the aquatic environment, the EQS Directive sets Environmental Quality Standards for mercury.
According to the ‘State of Water Report’ by the EEA in the 2nd River Basin Management Plans (2015-2021) only 38% of surface water bodies (e.g. rivers, lakes and coastal waters) were reported to be in good chemical status; 46% of water bodies failed to achieve good chemical status; and for 16% of surface water bodies their status is unknown. Mercury is one of the few substances responsible for a widespread failure to achieve good chemical status with 24 countries reporting water body failures for mercury. Some countries, such as Sweden, report that all of their surface water bodies are failing to achieve good status due to mercury, because of atmospheric deposition from incineration of coal, waste, iron works but also from emissions from crematoria due to amalgam fillings.
Across Europe mercury is also responsible for failure to achieve good chemical status in the highest number of water bodies: out of a total of 111,062 surface water bodies, 45,973 are not achieving good status for mercury equating to about 41% of all surface water bodies in Europe. If the widespread pollution by ubiquitous priority substances, including mercury, were omitted, the proportion of water bodies failing to achieve good chemical status would fall to 3%.
In order to protect water resources and move towards a non-toxic environment, EurEau consistently advocated for a phase out of dental amalgam.
Furthermore, in the future, the levels of mercury in sewage sludge from waste water treatment will decrease and it will be possible to reuse the resultant high-quality sludge as a source of nutrients in a true circular economy. Since the quality of sludge in most Member States is improving over time, the relative importance of the pollution linked to mercury from dental amalgam is increasing, and is now a major source of mercury to many, if not most, wastewater treatment plants in the EU.
The biggest source of mercury is represented by the leakage of dental amalgam from the daily erosion of teeth: this will continue if using amalgam for new fillings is not phased out. In fact in countries such as Sweden, Norway and Denmark, where the use of dental amalgam was banned in dental clinics, water operators can see a decrease – in Sweden about a 50% decrease since the year 2000 - of the level of mercury in sludge produced at the waste water treatment plants.
Mercury separators at dental care clinics just take care of a smaller part of the leakage of mercury to the environment.
For a long-term reduction the amalgam phase-out is needed.
We therefore support the findings of the study ‘Assessment of the feasibility of phasing-out dental amalgam’ carried out on behalf of the Commission by Wood-Deloitte (July 2020) that confirms the feasibility of a phase-out for dental amalgam since alternatives exist and the ban has already been adopted by several Member States.
We support the earliest date considered in the study: 2025.
Thanks to the phase out it will be possible to move to a true circular economy where sewage sludge resulting from waste water treatment will meet the quality standards to be reused.
Read full responseResponse to EU strategy for sustainable textiles
1 Feb 2021
EurEau welcomes the publication of this Roadmap. The success of the Strategy will depend on whether the EU wants a real systemic shift from low-cost ‘fast fashion’ towards high quality, more durable and sustainable textiles and closed product loops, or whether it merely addresses certain symptoms.
The Roadmap rightly calls for “coherence and complementarity” with some Green Deal initiatives, but fails to mention the Zero Pollution action plan for water, air and soil due in 2021, notwithstanding article 11 (TFEU).
Textile life cycles strongly affect the quality and quantity of water resources.
1. Production, cleaning and washing of textiles: sources of hazardous chemicals
Apart from production, routine cleaning and washing of textiles releases hazardous chemicals to urban waste water, including persistent substances such as PFAS, and other textile additives including antibacterial silver. They may contaminate sewage sludge and, hence, limit the circular economy options of waste water operators. In particular mobile substances may not be removed during waste water treatment and end up in the aquatic environment.
2. Textiles as an important source of microplastics
The washing of synthetic textiles releases 18,500—46,200 tonnes of microfibres/year in the EU (https://ec.europa.eu/environment/marine/good-environmental-status/descriptor-10/pdf/microplastics_final_report_v5_full.pdf). At world level, about 500,000 tonnes of plastic microfibres are released into oceans annually from washing plastic-based textiles (https://www.eea.europa.eu/themes/waste/resource-efficiency/textiles-in-europe-s-circular-economy).
EU waste water treatment plants (WWTP) remove most microfibres. However, this is an unsustainable solution bringing negative consequences for circular solutions for sewage sludge.
Producers/importers should be required to inform consumers on the quantity of microfibres released from synthetic textiles, and ensure a first wash under controlled conditions (microfibre filters with dry filter cake) in order to reduce life-cycle fibre release.
3. Textile production - a highly water-intensive sector
To make a single cotton t-shirt, 2,700 litres of fresh water are needed (https://www.europarl.europa.eu/RegData/etudes/ATAG/2020/656296/EPRS_ATA(2020)656296_EN.pdf), enough to meet one person’s drinking needs for 2.5 years. Although most of this water use occurs outside Europe, we should press for the sustainable use of scarce fresh water resources world-wide.
The Textile strategy must apply the Treaty (TFEU) provisions of art. 191.2 and avoid that enhancing the circular economy for textiles goes to the detriment of other sectors, such as waste water treatment.
The principles of precaution and control-at-source must apply
All contaminants of all textile raw materials must be identified when determining relevant substances. Control at source takes at least four forms:
~ The materials farmers/producers are allowed to use, coupled with pro-active advice.
~ Understanding whether producers have the technologies to achieve required values before discharge to sewers to protect WWTPs and the receiving water. Cooperation with WWTPs is key.
~ Testing that textiles do not leach out hazardous substances or release plastic microfibres in their use phase.
~ Ensuring that materials from outside of the EU are subject to the same checks.
The controls must be consistent across the EU, to maintain the level playing field.
The polluter-pays principle must apply to water resources through extended producer responsibility (EPR):
TFEU article 191.2 calls for the application of the polluter-pays principle should control-at-source measures fail. With this in mind, EPR should also apply to additional costs incurred by water operators to remove chemicals and microplastics released from textiles in waste water, drinking water and/or drinking water resources.
The “polluter-pays” principle must not be replaced by the “water consumer pays" principle.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
17 Dec 2020
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 (economic) interest and cannot be considered an industrial sector like any other. Providing water services is, however, an activity with important technical, economic, managerial and regulatory aspects - whether carried out by public or private operators.
According to the WHO, every dollar invested in water and sanitation services results in a US$ 4.3 return, due to reduced health care costs for individuals and society.
Investments in water strongly contribute to sustainable growth and the water sector is an economic activity based on capital expenditures (networks) that creates local and stable jobs. We would like to stress, however, that many European countries face challenges in renewing ageing infrastructure and the role that water pricing could play is limited due to affordability concerns.
EurEau welcomes the opportunity to comment on the draft delegated Regulation “supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives”.
EurEau shares the aims of the basic Regulation 2020/852, the focus on water protection, the promotion of sustainable water management and the protection of human health. According to article 12 of Regulation 2020/852, water supply and sanitation services are within those activities that contribute substantially to the protection of human health and the environment (under art.12.(1)).
However EurEau strongly invites the European Commission to reconsider the draft delegated Regulation and to produce a new draft in order to reflect the reality of the water sector in the EU27. Defining the sustainability of water projects should be based on Life-Cycle Assessment, energy use being only a part of such evaluation.
Under the current draft screening criteria, only very few water projects would qualify for financing while now, more than ever, we need to invest in resilient water infrastructure in order to contribute to climate mitigation and adaptation efforts, work towards the SDGs, and achieve the Green Deal objectives of a climate neutral EU society by 2050.
It is fundamental that the screening criteria are appropriate and proportionate since they will play an important role for Members states and water operators to have access to sustainable financing (EU funding in particular) and in the evaluation of the national Recovery Plan projects where a significant part of the funds should be dedicated to the resilience of water infrastructure. Furthermore, they will become a reference for the European Investment Bank and may be adopted by other International Financial Institutions.
in the document attached, we are pleased to share the main elements that need to be addressed and some suggestions for improvement while being available for further discussions to clarify or integrate our positions.
Read full responseResponse to New EU Soil Strategy - healthy soil for a healthy life
10 Dec 2020
EurEau is the European federation of water services representing drinking water and waste water operators from 29 countries. We welcome the initiative of the European Commission to propose a new Soil Strategy to improve the quality of soils in Europe, to tackle land degradation and desertification and to increase biodiversity.
Soil as a reservoir for groundwater
EurEau would like to emphasize the important role of soils in water purification and infiltration. Soils provide drinking water to a large share of the European population. The strategy should aim at protecting drinking water resources by improving groundwater and surface water quality and quantity, and thereby contribute to reaching the goals of the Water Framework Directive. This necessitates among others reducing agricultural emissions from manure/fertilizers and pesticides and remediating contaminated sites that have a serious negative impact on drinking water abstraction zones.
Healthy soils to protect water
Soils play a vital role for water management. A healthy soil with sufficient organic matter has a buffer function for the water system, making sure the sensitivity to drought and flooding is limited and thereby contributes to climate change resilience. Wetlands, peatlands and rural or urban nature-based solutions store and infiltrate rainwater. This allows filling aquifers for overcoming dry periods and avoids connection to sewers, which reduces spills of untreated waste water during heavy rains. Soils are also used to treat waste water from stand-alone or small community sanitation systems. The interdependence between water and soil should be recognised in the new strategy and should support developing knowledge on the positive role healthy soils play in further reducing diffuse pollution to water. This requires improved simultaneous monitoring of soil and groundwater quality.
Sewage sludge (biosolids) organic matter and nutrients
As rightly mentioned in the roadmap, “The Biodiversity Strategy for 2030 highlights that it is essential to step up efforts to protect soil fertility, reduce erosion and increase soil organic matter.” Sewage sludge, containing 25 to 35% of carbon, is a valuable source of organic matter and we disagree to reduce the impact of sludge on soil only to diffuse pollution while ignoring its multiple benefits.
Sewage sludge is resulting from the treatment of waste water and consists mainly of water, carbon, nitrogen (4–5% DS), phosphorus (2-3% DS) and residuals (trace elements, metals, etc)). Appropriate treatment transforms sewage sludge into biosolids which can eventually be used in agriculture.
Biosolids and pollutants control
Over the last decades, the 86/278/EEC Directive (SSD) allowed to define the quality and the conditions suitable to safely apply biosolids on land. The biosolid quality determines its possible reuse and if it does not comply with the quality requirements, it is not spread on land. The SSD is a valuable instrument that improved the sludge quality, encouraged the correct use of biosolids and allowed to safely increase soil organic matter content. The SSD is currently under evaluation and even if it is already the case in many countries, it might be necessary to consider a wider range of parameters. We insist that this must be done based on robust scientific evidence that demonstrates the negative impact of pollutants on soil and the connected environment. The overall objective should be to improve quality of soil considering also the benefit to apply good quality biosolids on land.
Biosolids and carbon sequestration in soils
By recycling carbon and nutrients (N, P and micronutrients) and by reducing the needs for chemical fertilizers, biosolids used in agriculture also contribute to climate change and the circular economy ambitions. In that sense, the overall benefit of the application of biosolids to land should be considered and not only its potential to be a source of pollutants.
For EurEau, water matters
Read full responseResponse to Protecting biodiversity: nature restoration targets
27 Nov 2020
Drinking water and waste water services have an essential mission: the protection of human health and the environment, so EurEau welcomes the opportunity to share its views on the inception impact assessment of the EU restoration targets.
We welcome the fact that the initiative is based on the art.191 TFEU. We want to stress that especially the principles enshrined in art.191.2 should indicate the path to follow: 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.
In this context we welcome the relevance granted to the Fitness check on the water legislation and we support an enhanced policy coherence in the EU legislation and Green Deal strategies.
Indeed improving the quality and quantity of water resources are both crucial for biodiversity restoration.
The protection of water resources and the resilience to climate change are crucial for securing biodiversity and good quality drinking water.
The Marine Strategy Framework Directive (MSFD) and the Birds and the Habitats Directives (BHD) with their aim to restore biodiversity and protect species in the European waters are therefore truly complementary to the Water Framework Directive (WFD).
Although the synergy between the WFD, MSFD and BHD contributed to a serious improvement of the good status of water throughout Europe, more effort is required to reach the targets and objectives of these directives. The overarching policy coordination would benefit from the interaction between the implementation processes. The evaluation of the BHD in 2016 and the fitness check on the water legislation in 2019 reached the conclusion that the legislation is broadly fit for purpose but there is room for improvement in the implementation of relevant provisions that have not displayed fully their effects.
We believe that one of the main focus points of such an action plan should be the interconnections between the implementation processes of the water legislation and the BHD, as well as greater and more efficient involvement of relevant stakeholders.
Due to different policy procedures and time schedules, the implementation process of WFD and BHD measures are not always optimally aligned, or even worse, they sometimes contradict each other.
Therefore, more efforts are needed to enhance the cohesion between the RBMPs of the WFD and the BHD Management plans.
We think that the implementation of the water directives should promote the synergy with the BHD, getting rid of the inconsistency between Article 4(7) of the WFD and Article 6(4) on the interpretation of ‘overriding public interest’.
EurEau proposes to:
~ Address the connection between the WFD and the BHD in the BHD implementation action plan and integrate findings into the WFD implementation.
~ Get rid of inconsistencies between the BHD and the WFD, especially on the interpretation of the ‘overriding public interest’.
~ Consider water bodies’ resilience to climate change to improve the objectives of the WFD.
~ Improve alignment and coordination of implementation cycles.
~ Create more synergies and connections between RBMPS and BHD management plans.
~ Improve involvement of stakeholders in the implementation processes.
Read full response26 Nov 2020
EurEau is the European federation of water services representing drinking water and waste water operators in Europe. We support the initiative of the European Commission to set the EU on a sustainable path to achieve climate neutrality by 2050 and the EU-wide, economy-wide net greenhouse gas emissions reduction target by 2030 compared to 1990 of at least 55%. The water sector is aware of its contribution to GHG emissions and is already involved in reducing them. We understand and welcome therefore the review of the so called Effort Sharing Regulation (ESR) which also covers the emissions of the water sector.
We acknowledge that the water sector has to contribute to climate change targets and de-carbonise the sector. However, we want to highlight the fact that emissions for the water sector, mentioned in the roadmap, are not clearly defined regarding which emissions are considered and it would need further clarification coupled with relevant data.
Option 1refers to “waste emissions from water treatment installations would need to be included”. It is not clear which emissions are considered here and which water treatment installation are considered. Does this cover incinerators of sewage sludge, GHG emissions of water installations in general, installations for the production of drinking water or for the collection and treatment of waste water? Option 3 clearly mentions that the methane emissions from wastewater are targeted. It is then unclear if the same emissions are addressed in both options or not. If it is the case, water and wastewater facilities have other sources of GHG emissions that should also be considered. It is crucial for us to understand how the water sector would be impacted by this change in the regulation in order to better respond to the challenge of GHG emission reductions.
Furthermore, the main piece of legislation regulating the waste water sector is currently under revision. We would therefore ask for coordination with the Urban Waste Water Treatment Directive (UWWTD) to make sure there is coherence between treatment requirements and GHG emissions. Coherence is also necessary with the Methane Strategy, the Renewable Energy Directive, the Energy Efficiency Directive and the regulation on Taxonomy to stimulate sustainable financing to reduce GHG emission in the water sector.
We also want to highlight that the sector needs a concrete, simple and EU-wide methodology to determine current emissions covering all relevant steps in waste water treatment and all significant types of emissions. This is a pre-requisite for defining a baseline and plan the reduction of emissions for the future.
As the level of treatment and the financial capacity to implement the UWWTD differs substantially between countries and regions, the capacity to implement GHG emission mitigation measures also shows significant differences. It is therefore important to adapt the reduction target to the different situations in the EU. The efforts in emission reductions already undertaken by some Member States should be taken into account.
Finally, intensive agriculture has an impact on both climate and water quality and quantity. As agriculture is a large contributor to GHG emissions, for coherence with the environmental and water acquis, we also welcome the consideration of the GHG emissions from agriculture and especially the methane emissions.
For EurEau, water matters.
Read full responseResponse to Revision of lists of pollutants affecting surface and groundwaters
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 of pollutants affecting surface and ground waters.
This initiative 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 is only effective if preventive action is taken and the source-control approach implemented: the latter is also instrumental to achieve a truly Circular Economy for water, the Zero Pollution ambition and the Climate neutrality by 2050.
That is why we support coherence in the EU legislation and Green Deal strategies.
To ensure the supply of high quality drinking water to citizens, the protection of surface water and ground water resources from pollution is paramount, as recognised in the WFD, whose objectives should be mainstreamed in other sectoral policies. The wording of art.7.3 of the WFD is clear but it is 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 on 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 (pharmaceuticals, cosmetics, detergents, pesticides, biocides 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 pharmaceuticals residues pollution is controlled as much as possible at the source.
On the Priority Substances list, we welcome the intention to consider PFAS as a group of substances: 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 the 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 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 responseResponse to Industrial pollution - revision of the European Pollutant Release and Transfer Register
26 Oct 2020
EurEau represents both drinking water and waste water service providers from 29 countries in Europe. The protection of drinking water resources is one of our major concerns and the E-PRTR should be a key contributor to it. We support the revision of the E-PRTR to better empower EU citizens with environmental data. It should focus on improving the application of the control at source principle and enhancing the circular economy. In that sense, we support all the aspects referred to in the Inception Impact Assessment.
Guaranteed access to relevant information
Information on chemical substances released in the environment should be better regulated. Currently, only a few substances of emerging concern emitted to surface waters by chemical plants or the owners of the treatment facility for industrial waste water are reported under the E-PRTR. For the good protection of water resources, E-PRTR should be extend to all Substances of Very High Concern listed under the REACH regulation that are produced or used in a chemical plant. The information should be accessible to all water suppliers or urban waste water treatment plant operators as well as regulators in a specific river basin area, in line with the Aarhus Convention.
Furthermore, most of the data for the reporting under E-PRTR is estimated, as it is not feasible nor considered practical to measure all 91 parameters. The current reporting of total annual emissions also masks peak emissions over the period which have the most acute effects on the receiving environment. This system does not deliver robust enough data to assess trends in the release of substances in the environment and the impact assessment should look at a better way of reporting that help water services to protect water resources adequately.
E-PRTR should also be more interactive in order to facilitate the access to the information. This would enable water suppliers to better predict the effects of pollutant emissions on drinking water resources, while waste water treatment plant (WWTP) operators could target their risk assessment when considering the recovery of products/materials from waste water. This information would better identify the pollution entering sewers and allow to take measures at source by removing these substances at the industrial plant before they enter the urban water cycle or the aquatic environment. Thereby, it will support the EU’s circular economy ambitions and action plan by tracking contaminants and protect the quality of waste water.
Avoiding regulatory overlaps (coherence & future relevance)
WWTP operators have reporting obligations under the UWWTD and some are also reporting under the E-PRTR. The obligation of WWTPs to report under the E-PRTR does not take into account the industrialised extent of the agglomeration, creating potential unnecessary burden for certain operators. The impact assessment should assess the coherence between the E-PRTR and data collected under the UWWTD (treatment of waste water or sewage sludge and reporting especially). The relevance of having two reporting systems should also be assessed, with a view to avoiding unnecessary monitoring cost. Therefore pollutants and reporting frequencies should be aligned with the UWWTD in order to reduce the burden for waste water treatment plant operators. Furthermore, making the existing reporting performing well should be prioritised over the extension the scope to smaller facilities.
Read full responseResponse to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil
23 Oct 2020
EurEau welcomes the opportunity to share its views on the Zero pollution action plan for water, air and soil.
We agree with the action plan be based on the 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.
Drinking water and waste water services have an essential mission: the protection of human health and the environment.
To ensure the supply of high quality drinking water to citizens, the protection of water resources from pollution is paramount, as recognised in the WFD, whose objectives should be mainstreamed in other sectoral policies (as confirmed by the fitness check).
Given the various pathways through which pollution reaches the environment, water resources protection is only effective if preventive action is taken and the source-control approach implemented: the latter is also instrumental to achieve a truly circular economy.
The most sustainable and preferred solution remains to prevent pollutants and contaminants of emerging concern (CECs) from entering the water cycle in the first place since they can directly or indirectly enter the water cycle and, once there, they can pose a risk to water resources. Current technologies used in water treatment plants are not entirely capable of removing them, although the removal of microplastics is generally good.
This is true in particular with PMT substances: we call on the Commission and Member States to define mobility as a criterion according to which substances can be restricted. The action plan for the phase out of non-essential uses of PFAS accompanying the Chemicals Strategy should be implemented swiftly.
Extra-treatment of pollutants by water operators may be part of the solution as a means of last resort according to the polluter-pays principle polluters should then bear the costs of extra treatment. This could be done for instance by developing extended producer’s responsibility schemes.
The Zero Pollution action plan should set up a hierarchy of pollutants based on criteria such as CMR, PMT, PBT and EDC, and on the relative ECHA’s work, giving priority to those pollutants (or their metabolites/degradation products) that are relevant for drinking water resources protection. At the same time it is fundamental that a life-cycle approach is considered for all pollutants emitted in the environment (water, air, soil) in order to protect ecosystems. We are available to further assist the Commission in this process.
We support coherence in the EU legislation and strategies. We expect that new Drinking Water Directive parameters are considered when revising the water resources protection legislation (EQSD, GWD). Sectoral legislation (pharmaceuticals, cosmetics, detergents, pesticides, biocides and other chemicals and agriculture legislation) should contribute to reach water policy objectives.
We think that the important, but still rarely implemented, mechanism included in the Pesticides Regulation - by which Member States shall review an authorisation, where it is concluded that the objectives of the WFD on the reduction of pollution in surface water and ground water and allowing for the reduction of the level of purification treatment necessary for the production of drinking water, cannot be met - could be replicated in other sectoral legislation.
These source-control actions are intended to limit pollutants entering the water cycle thus favouring the development of the circular economy: the less waste water is polluted, the easier it is to use reclaimed water or sludge.
The WFD adopted in 2000 aims at establishing a framework for the protection of all EU waters but 20 years later its objectives have not been reached yet: the Zero Pollution Action Plan, including the elements mentioned above, must play a role in fulfilling the WFD objectives and the protection of water.
Read full responseResponse to Setting up an Infrastructure for Spatial Information (INSPIRE) - Evaluation of the Directive
19 Oct 2020
EurEau is the European association of water service providers with 34 national member organisations in 29 countries.The INSPIRE directive (annex III) specifically includes “utility facilities such as sewage … and water supply” in its scope.
Ensure the security of critical infrastructures
While EurEau supports efforts to increase the access of environmentally relevant spatial data to the public, EU-legislation must ensure the protection of critical infrastructures / essential services to prevent malicious acts and protect people’s health and the environment. Hence, restrictions must be maintained regarding public access to information on underground water utility networks and production / treatment facilities.
The drinking water supply network is considered as essential service under Directive 2016/1148 (NIS directive) and as critical infrastructure in the European reference network for critical infrastructure protection (ERNCIP). Most Member States define the drinking water supply network as national critical infrastructure.
The European Programme for Critical Infrastructure Protection is currently under revision and might include national critical infrastructures such as drinking water supply.
The waste water network is defined as critical infrastructure in an increasing number of Member States.
The INPIRE evaluation process should assess policy coherence with European and national requirements for the protection of essential services and national critical infrastructures.
Avoid duplication with other EU legislation
EurEau supports the objective of the INSPIRE directive to provide relevant data about the soil, groundwater- and surface water quality. However, duplication in reporting requirements must be avoided.
EurEau invites the Commission to evaluate policy coherence in terms of data provision and reporting requirements with regards to the following directives: Water Framework Directive, Groundwater Directive, Urban Wastewater Treatment Directive, Nitrates Directive, Sustainable Use of Pesticides Directive, and the new Drinking Water Directive (final approval likely in late 2020), in particular, its article 8.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
16 Sept 2020
EurEau is the European federation of water services and represents drinking water (DW) and waste water (WW) operators from 29 countries.
We support the EU’s Green Deal, including its climate targets and Strategies. We call for full coherence between the EED, other energy legislation (RED), and sectoral legislation (Drinking Water Directive - DWD, Urban Waste Water Treatment Directive - UWWTD).
Meeting society’s demand for safe water services may involve energy intensive processes making energy one of the sector’s highest operational cost factors. Optimising its use has therefore been a top priority for many years. Still, the EE potential is far from exhausted. The sector accepts the need to step up efforts further with the ambition to reduce its GHG emissions in line with EU objectives.
However, if an energy-intensive treatment step is technically necessary (safety, regulatory compliance), it must prevail despite higher energy use.
EE priorities
• Reduce energy use in DW works and waste water treatment plants - WWTP: proper component dimensioning, optimise operations, preventive maintenance
• Reduce energy use in DW networks (pressure/leakage management, pumping stations)
• Use of efficient pumps in DW/WW networks and efficient plant equipment
• Reduce water quantities collected by sewers (less impervious surfaces, storm water infiltration) and prevent groundwater infiltration in sewers
• Maximise gravity transport of DW/WW depending on topography to avoid pumping
• Apply intermittent operations where possible
• Reduce energy footprint in corporate management (buildings, vehicle fleet)
• Outside the control of operators: reduce (hot) water consumption/capita
EurEau does not support specific European EE targets for the water sector but favours its integration in local energy policies. The sector needs flexibility on its way to climate neutrality.
Reasons
• Local conditions determine energy reduction potentials (type of DW source, treatment levels needed, population density, plant size, topography).
• Energy use in WWTP increases when installing resource recovery facilities or supply water for reuse (circular economy).
• New regulatory requirements or increasing pollution of DW resources or WW may trigger the installation of energy-intensive extra treatment steps. Hence, the polluter-pays principle must be applied.
• Increasing water scarcity may require the development of new, energy-intensive DW sources, including desalination.
• Energy use is not the only relevant GHG source. WW services may directly emit high GWP GHG (nitrous oxide, methane - see EU Methane Strategy). Those emissions need addressing, too.
• Regional development levels differ significantly. Solutions for large plants may not be adapted to small ones.
• The sector’s long investment cycles (40-50 years) need consideration.
• There is no market failure, as EE is already a top priority of water operators.
• No measuring unit offers a comprehensive way to reflect progress: kWh/m3 of DW/WW; GHG emissions/m3; kWh/pe; degree of energy self-sufficiency.
The EED should
• Avoid duplication with the UWWTD (in revision) and the DWD (new);
• In coordination with the UWWTD, encourage energy audits in larger WWTP to ensure awareness of EE potentials;
Financing and cost effectiveness
• EE investments may exceed the financial capacity of water operators while having slow/no pay-back.
• Policy options must be consistent with the GHG reduction calendar, the sector’s investment capacity and the lifetime of existing assets.
• The EU should authorise and support national incentives for EE investments of water operators through Cohesion Funds, the EU Recovery Fund and other financial mechanisms.
• The development of quality energy services for water operators needs support to overcome financing gaps.
EurEau supports option 2 of the IIA. Provided the above comments are taken into account and duplication with the UWWTD/DWD is avoided, option 3 could be supported.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
16 Sept 2020
EurEau is the European federation of water services and represents drinking water (DW) and waste water (WW) operators from 29 countries.
We support the EU’s Green Deal, including its climate ambitions and Strategies. We call for full coherence between the RED, other energy legislation (EED), and sectoral legislation (DW Directive, Urban WW Treatment Directive).
Meeting society’s demand for safe water services may involve energy intensive processes making energy one of the sector’s highest operational cost factors. Optimising energy use has therefore been a top priority for many years. The sector will step up efforts further with the ambition to reduce its GHG emissions in line with EU objectives. The sector already generates a large amount of RE, but significant potentials remain.
• Hydropower from turbines using appropriate slopes in the DW/WW networks.
• Biogas from sewage sludge is a storable resource. Refined, it can be injected into grids and used during peak demand / low RE production, or power vehicles.
• Heat recovery from WW through heat pumps in large sewers is promising but needs more research is required. Heat / cold recovery from DW networks is investigated.
• Energy recovery from dried sewage sludge is a mature process, but sludge drying asks as much energy as is produced through its incineration. Drying should only use waste heat.
• Solar and wind energy: Depending on site conditions, solar or wind energy can be generated.
EurEau does not support specific European RE targets for the water sector but favours its integration in local energy policies. The sector needs flexibility on its way to climate neutrality.
Reasons
• Local conditions determine potentials (type of DW source, treatment levels needed, population density, plant size, topography).
• Energy use in WWTP increases when installing resource recovery facilities or supply water for reuse (circular economy).
• New regulatory requirements or increasing pollution of DW resources or WW may trigger the installation of energy-intensive extra treatment. Hence, the polluter-pays principle must be fully applied.
• Increasing water scarcity may push energy-intensive DW processes, including desalination.
• Energy use is not the only relevant GHG emission source. WW services may emit high GWP gases (nitrous oxide, methane, see EU Methane Strategy). Those emissions need addressing, too.
• Regional development levels differ largely. Solutions for large plants may not be adapted to small ones.
• The sector’s long investment cycles (40-50 years) need consideration.
• No measuring unit offers a comprehensive way to reflect progress: kWh/m3 of DW or WW; GHG emissions/m3; kWh/pe; degree of energy self-sufficiency.
The RED should address remaining bottlenecks:
Regulatory framework
MS must establish enabling regulatory frameworks and remove obstacles to a wider RE roll-out:
• Water operators of all MS should be allowed to inject excess RE (heat, power, gas) into grids.
• Solutions to refine sewage sludge gas to grid quality need support.
• The recent French ban to add bio-waste to sewage sludge digesters is unjustifiable and reduces process efficiency. It should be removed.
• Subsidies for RE investments should not discriminate between sectors applying similar technologies.
Financing, cost effectiveness
Investments in RE may exceed the financial capacity of water operators while having slow or no pay-back.
Policy options must respect the GHG reduction calendar, the water sector’s investment capacity and the lifetime of existing assets.
The EU should authorise and support national incentives for RE investments of water operators through Cohesion Funds, the EU Recovery Fund and other financial mechanisms.
Sustainability
We support the determination of the sustainability and GHG emissions saving criteria for bioenergy based on objective LCA.
Provided the above comments are taken into account, we could support option 5 (combination of options 2, 3 & 4).
Read full responseResponse to Revision of the Urban Wastewater Treatment Directive
8 Sept 2020
EurEau is the European federation of water services and represents nearly all the waste water operators in Europe. Our members deliver waste water services to citizens across Europe. A revised UWWTD will set the context for waste water services for the next generation. Therefore we highlight key points that the impact assessment (IA) must address.
We support the inclusion of the Green Deal and the Circular Economy within the IA as our members are already working on the sustainability of waste water services, from collection to treatment, and the recovery of valuable resources from waste water.
The IA aims to assess the cost/benefit of diverse policy options by comparing them with a basic scenario. We urge the Commission to consider in this basic scenario the current investment needs to reach the full compliance with the existing UWWTD, to maintain, adapt and/or refurbish the existing infrastructure (particularly sewer systems) and to manage the infrastructure against the effects of climate change and movement and growth of the population. Otherwise the IA will underestimate the full cost of the basic scenario and mislead the comparison with the new policy options.
We highlight the need for policy coordination with other directives, especially to give clarity and justification on the scope of a revised UWWTD. Specifically the IA should investigate the interaction with emerging policies from the Green Deal and with other legislation, for example WFD, water reuse regulation, SSD, BWD, REACH and IED. The IA must consider policy coordination to ensure that waste water services of the future are sustainable, affordable, can be efficiently delivered, trusted and supported by citizens.
We insist that the IA investigates policy coordination with the WFD to specifically ensure that both the Environment is protected in a sustainable way and that WWTP can operate and increase capacity according to population growth.
We strongly suggest the IA clearly defines individual policy options and then looks at them in combination to assess their overall effect. For example, the policy to reduce energy, recover resources and reach climate neutrality should be seen in combination with the ambition to enhance treatment of pollutants.
We support the inception IA approach to take a holistic view on emerging pollutants but control at source and preventive measures must come first, with the application of extended producer responsibility as a means to finance enhanced treatment.
We suggest that the IA explores future policy options for small agglomerations lower than 2000 p.e. with respect to nutrient management and appropriate governance arrangements. This should be done in coordination with policy options for IAS.
The IA must recognise that collecting systems achieve multiple objectives (such as protecting properties from sewer flooding) and not only pollution objectives.
The IA must address discharges of industrial wastewater into collecting systems and urban WWTPs. Effective control of industrial discharges is essential to manage the quality of WWTP effluents and by-products.
We support that the IA explores the role of innovation to enhance treatment and recover resources, in conjunction with policy options responding to challenges where technical solutions have shown value for the environment and are practicable for waste water services.
Finally, we also want to highlight that the objectives set in the Green Deal have to be reached in 2035 and in 2050. These deadlines are very ambitious with regards to the challenges presented in the inception IA. The policy options and their implementation will have to be adapted to this calendar, the investment capacity of the sector and the lifetime of the existing assets.
For EurEau, water matters.
Read full responseResponse to Evaluation of the Sewage Sludge Directive 86/278/EEC
25 Aug 2020
EurEau is the European federation of water services and represents nearly all the waste water operators in Europe. We welcome the initiative of the European Commission to evaluate the Sewage Sludge Directive (SSD) after 34 years of implementation. Currently, 50% of sludge produced in Europe is used in agriculture.
Sewage sludge is an inevitable and valuable by-product of waste water treatment. The SSD is a complementary piece of legislation of the UWWTD for the good functioning of the waste water services. Today it addresses only one outlet for the sludge produced. As the production of sludge is anticipated to grow with better compliance and possible increased requirements under a revised UWWTD, it is important for operators to keep a large range of options for sludge outlets to continue operating WWTP to protect human health and the environment.
The future of sludge management will depend on a regulatory framework protecting the quality of this by-product and supporting a wide variety of reuses. There is a need for a paradigm shift around sludge that starts by not considering it as a waste but see it as a bio-resource on its own. It requires a different regulatory approach moving away from the linear waste hierarchy.
That is why EurEau supports a clear supportive legislative landscape in order to secure the different options to manage sewage sludge, ensuring also a proper protection of the receiving environment. This evaluation should include the following points:
1. The scope of the directive to regulate the use of sewage sludge in agriculture in order to protect soil, vegetation, animals and man, thereby encouraging its correct use should be re-affirmed and extended to reflect the beneficial value to agriculture of the reuse of bio-resources (carbon, nitrogen, phosphorus and micro-nutrients) and hence contribute to the circular economy.
2. Our experience of the SSD as waste water operators confirms that this directive is effective as it is straightforward to implement and of benefit to agricultural land. This should continue.
3. Looking forward, other reuses for sewage sludge will emerge, as technology and the circular economy develop. This should be encouraged by European legislation alongside maintaining the beneficial reuse of sludge in agriculture.
4. We strongly recommend that the separation between sewage sludge used in agriculture and EU waste regulations is retained and clarified. We also want to highlight the need to address policy co-ordination between the SSD and other legal instruments (mainly UWWTD and IED).
5. The SSD identifies limit values for certain heavy metals to protect soils; we wish to see this continued or enhanced where appropriate. If the evaluation process considers a wider range of parameters, we insist that this is done based on robust scientific evidence (see a non-exhaustive list of publications attached).
6. Many countries operate their own quality assurance schemes or risk management techniques for treated sludge (biosolids) used in agriculture that go beyond strict sludge quality control. The evaluation must explore these schemes and any other additional controls which are already applied over and above the requirements of the SSD.
7. We wish to see source control measures, which are absent from the scope of the SSD, explored within the evaluation process under Effectiveness, to complement measures under a revised UWWTD.
8. The evaluation must look at how sludge use in agriculture enables delivery of climate change and renewable energy generation ambitions and contributes to the circular economy.
9. The cost of the variety of sludge management options has to be taken into account in this evaluation, which the UWWTD evaluation report failed to quantify, even though it identified sludge management as one of the main cost drivers for the implementation of the UWWTD.
For EurEau, water matters.
Read full responseResponse to Revision of the NIS Directive
3 Aug 2020
EurEau welcomes the review of the NIS Directive and appreciates the possibility to input the process though the feedback to the Roadmap.
Since the NIS Directive transposition period ended in May 2018, EurEau members think it is challenging to assess the provisions and how they have worked in practice so far.
Concerning the options outlined in the roadmap, EurEau members have a preference for Option 2.
EurEau will submit its answer to the public consultation.
Read full responseResponse to Enhancement of European policy on critical infrastructure protection
3 Aug 2020
EurEau welcomes the opportunity to share its feedback to the roadmap on the proposal for measures to enhance the protection and resilience of critical infrastructure and welcomes the intention of the Commission to carry out an impact assessment on all the options under consideration.
EurEau’s members have a preference for Option 2.
We also welcome the proposal for a better coherence with the NIS Directive under option 4 and we appreciate the intention to explore synergies between the various initiatives (NATO).
Read full responseResponse to EU Methane Strategy
31 Jul 2020
EurEau is the European federation of water services and represents nearly all the waste water operators in Europe. We welcome the EU Methane Strategy initiative, which intends to reduce the manmade methane emissions by putting in place an enabling environment to cut these emissions, which contribute to climate change.
The primary responsibility of our members is waste water treatment, which includes treatment of sewage sludge; these processes emit some methane.
Our members actively produce biogas from sewage sludge under controlled conditions to stabilise the sludge, reduce the amount of sludge produced and to produce renewable energy. This methane is collected and reused for energy production at the waste water treatment plant or for municipal use if allowed. Although a small emitter relative to other sectors, some facilities may emit methane to the atmosphere from different process steps and we acknowledge the fact that the roadmap highlights that “further mitigation potential in sectors such as waste water treatment and sewage sludge treatment and use should be explored”. As the waste water sector, we support the process of identifying and quantifying the emissions of methane from waste water and sludge treatment and use. We support a sustainable waste water sector that can take measures to mitigate its impact on the environment, including greenhouse gas emissions. Horizon Europe should be one of the instruments to address the quantitative inventory of Green House Gas emissions of the water sector to map where the effort can be the most cost-effective.
We note that the roadmap mentioned the opportunity for farmers to diversify their income through biogas production. The Farm2Fork strategy mentions that “Farms also have the potential to produce biogas from other sources of waste and residue including sewage and waste water”. We insist that measures should lead to sustainable solutions, respecting the investments already made by the water sector in order to minimise the production of sludge and maximise the production of biogas. The future enabling environment, to cut emissions of methane, should allow cross-sector working to maximise the value of existing assets. Furthermore, the digestion process releases liquid matter (liquors) from the digested biomass, either from waste water or from manure that need treatment. Waste water treatment plants can treat this effluent in the biological treatment phase, which is not possible for assets that only digest biomass.
We note that the roadmap identifies monitoring and data collection for methane is needed to support future legislative action in this field. We accept that data concerning methane in the waste water treatment, sludge treatment and sludge use is currently not available, however we ask about covering the associated costs of field monitoring and data collection.
Finally, if methane is to be actively controlled by the waste water sector, we would wish to see the enabling environment co-ordinated with the relevant EU legislation i.e. the Urban Waste Water Treatment Directive and the Industrial Emissions Directive both currently under revision, the Sewage Sludge Directive currently under evaluation, the Circular Economy Action Plan, the Waste Framework Directive and the climate legislation, in order to have a holistic and sustainable approach for the collection and treatment of the waste water which takes account of methane. If methane emissions are managed through reduction targets, they should be co-ordinated with climate targets to avoid confusion.
We would like to offer our support as expert network in order to input the process and to provide all the required elements related to methane emissions of the waste water sector.
For EurEau, water matters.
Read full responseResponse to Sustainable use of pesticides – revision of the EU rules
20 Jul 2020
As the world now battles the Covid 19 pandemic, ensuring a continued supply of safe drinking water and disposal of treated wastewater that does not negatively impact the environment is central to protecting public health.
The Sustainable Use of Pesticides Directive (SUPD) aims to protect human health and the environment from the possible risks and impacts of pesticides.
This legislation encourages the reduction of pesticides application through:
• integrated pest management
• alternatives to chemical pesticides.
The SUPD obliges Member States (MS) to adopt and implement National Action Plans (NAPs) to reduce risks and impacts of pesticide use on human health and the environment. After over a decade of experience with NAPs in many countries we can conclude that it is a weak and inefficient instrument, which lacks the enforcement measures needed to reduce the risks and impacts of pesticides on water resources. Despite the strict authorisation process for plant protection products (PPP) and the rules governing their application, the contamination of water resources with PPP active substances and their degradation products continues to be one of the most pressing raw water problems encountered by water operators. The NAP process is strong in bringing stakeholders from different sectors together, it has defined ambitious targets and strong indicators, but it lacks the political and legal backing needed for effective implementation. One of the crucial shortcomings of the SUPD is that implementation of NAPs is completely given into the hands of the Member States. The revision of the SUPD should therefore introduce a mechanism which
- Defines clear targets which can be monitored and evaluated,
- Defines a clear timeframe for reaching the targets,
- Establishes a systematic approach which allows for a monitoring of actions and measures taken and for their contribution to fulfilling the targets defined
- Obliges Member States to enforce the measures needed to fulfil the targets
If the SUPD does not define clear obligations via the NAP, we believe that MS continue to misuse NAP as a “paper tiger”. This means that consumers will have to pay for extra-treatment of drinking water through their water bills, despite the wording of art. 191.2 of the TFEU. The affordability of water services will be jeopardised in the long term as we neglect the polluter-pays principle in favour of the consumer-pays principle. This end-of-pipe approach is not in line with the EU Green Deal since extra treatment will lead to increasing energy consumption and CO2 emissions as well as costly treatment residues management. It doesn’t comply with the Water Framework Directive (WFD), art.7.3: drinking water sources should be protected, to avoid deterioration in their quality and to reduce the level of purification treatment required in the production of drinking water. Therefore, the SUPD should focus on reducing the emission of pesticides to water, especially to drinking water resources. Policy measures have to contribute to achieving the goals of the WFD. Examples of actions that we believe would lead to more sustainable and responsible use of Pesticides are:
• To withdraw approvals for active substances of pesticides in case of concentrations in water resources exceeding the objectives set by the WFD and its Daughter Directives.
• Enforcing or tightening application restrictions
• Increasing funding for water protection advisors Increasing and/or making available funding to undertake catchment monitoring programmes in order to monitor and evaluate the effectiveness of measures
• Matching official advice for the farmers on best practice in terms of water resource protection with strong enforcement action.
We believe there is also scope for applying extended producer responsibility (EPR) schemes to pesticides and other micropollutants in the aquatic environment from products during their life cycle.
Read full responseResponse to EU Strategy on Adaptation to Climate Change
25 Jun 2020
EurEau welcomes the intention of the Commission to come up with a new and more ambitious climate change adaptation strategy. We support the need for further mainstreaming of adaptation considerations into EU legislation and instruments.
The tangible impact of climate change include higher temperatures and too little or too much water. Climate change directly threatens the provision of water services in Europe due to more frequent or intense periods of drought, heat waves or storms and flooding. It will have many (in)direct effects on the quality and quantity of available water resources, the operation of water infrastructure, and the management of the (urban) water cycle.
The protection of water resources should be prioritised in the new Adaptation Strategy. With a changing climate it is essential to increase the robustness of the water system by better managing and preserving our water resources. It is time for the EU to become more strategic on how to achieve this.
Safeguarding water resources with a changing climate is also essential to guarantee resilient water services. Well-functioning drinking water supply and waste water treatment is a Human Right and essential for the EU economy and the health of citizens. A special focus on the resilience and protection of water resources in the new Adaption Strategy could incentivise all levels of governments to take the right measures to develop appropriate policy supporting water operators and make necessary climate resilient investments.
While annual precipitation and total runoff increases may improve the water supply situation in some regions, the drinking water operators will have to adapt to a seasonally or intermittently reduced availability of water resources due to:
• the non-existence of alternative water sources and sufficiently flexible local abstraction facilities allowing utilities to respond to a (temporary) loss of individual abstraction types/catchment areas;
• the existence of competing water uses and their increasing significance (especially agricultural irrigation);
• higher peak demands for drinking water due to increased watering of private gardens and pool fillings.
At the same time the rising sea levels lead to the intrusion of saline water into coastal aquifers used for drinking water, as well as intrusion of saline water in sewers, impacting the effectiveness of the biological treatment in waste water treatment plants (WWTP) or impacting the efficiency of the sewage pumping stations located on low-lying coastal areas.
Waste water treatment operators will have to adapt:
• to the increasing number and intensity of heavy rainfall events ;
• to the effect of droughts on dilution in receiving water bodies of WWTP effluent.
Certain solutions may be identified in the operations of water services. For drinking water, adaptation measures focus on improving:
• Water allocation mechanisms, whilst prioritising water supply;
• Management and protection of water resources;
• Investments in abstraction, treatment and operation of the supply network;
• Sustainable use and demand of water.
For urban drainage systems and waste water treatment we see the following adaptation areas:
• Tackling combined sewer overflows;
• Preventing top much water from reaching the sewers during have rains;
• Reducing the impact of effluent temperatures on the receiving water;
• Encouraging measures for water reuse and foster the circular economy;
Wider application of blue-green infrastructures.
The adaptation capacity of water suppliers and waste water operators is also defined by general legal and political parameters, along with financing arrangements agreed locally or regionally within MS. A new EU Climate Adaptation Strategy focusing on the improved management of water resources could certainly contribute to accelerate the transition of water services towards climate resilience.
Read full responseResponse to Chemicals strategy for sustainability
17 Jun 2020
EurEau, already supportive of the 7EAP Strategy towards a non-toxic environment, welcomes the intention of the European Commission to finally establish a Chemicals Strategy for sustainability.
We agree on the choice of art.191 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. Water operators would like to see an ambitious and coherent Chemicals Strategy that considers the whole life-cycle of chemical substances from their initial production and use until their safe and sustainable disposal and supports and promotes “safe-by-design” chemicals, with specific attention to degradability in and removability from water. According to art.191 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 the 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 responseResponse to EU rules on industrial emissions - revision
21 Apr 2020
EurEau represents both drinking water and waste water service national associations from 29 countries in Europe. Protection of drinking water resources is one of our key concerns and the Industrial Emission Directive should be a key contributor to it. We support a revision of the Industrial Emission Directive in order to better implementing it, improving the application of the control at source principle, avoiding overlaps and participating to enhance the circular economy.
Reinforce the protection of water resources
IED and the related BATs should include requirements for the protection of water resources in order to avoid deterioration of the quality of water bodies and the need for increased treatment by drinking water suppliers according the precautionary principle, the control at source principle and the polluter pays principle as stipulated in article 191.2 of the TFEU.
Despite regulatory action under the IED, pollutants from industrial sources continue to be released directly or indirectly to the aquatic environment where they pose a threat to the quality of water resources. In that sense, IED and BAT/BREF documents should be a strong instrument to apply the control at source principle to industry by regulating all emissions of hazardous substances and in particular the one that cannot be removed by municipal WWTP. Additionally, it should require a set of measures for industrial waste water conveyed to the sewers of a water utility in order to
• prevent environmental hazards caused by pollutant releases from the water utility and protect downstream drinking water resources to avoid water suppliers to invest in increasingly sophisticated, expensive and energy-intensive treatment processes to remove pollutants (respect Art. 7.3 of the Water Framework Directive);
• ensure the safe, environmentally acceptable use and final treatment of sludge;
• protect the sewer network and the health of the employees of WWTP;
• prevent harm to the operation of the treatment processes for waste water and sludge;
• prevent sewer networks, treatment plants and their related equipment from getting damaged.
Implement the polluter-pays principle
The industrial activities covered by the IED and discharging their effluent into municipal sewers should be fully re-charged for the load of pollution brought to the WWTP in order to respect the polluter pays principle.
Guarantee access to relevant information
Information on chemical substances released in the environment should be better regulated. Currently, the chemical plant or the owner of the industrial WWTP is under no obligation to report on substances (of emerging concern) emitted to surface waters beyond those substances reported under by the E-PRTR. Complete registers with all chemical substances and by-products that are produced or used in the chemical plant should be accessible to all water users and regulators in a specific river basin area, in line with the Aarhus Convention. It would enable water suppliers to better predict the effects on drinking water resources. Furthermore, it enables targeted measures to remove those substances at the chemical plant before they enter the aquatic environment.
Avoiding regulatory overlaps (coherence & future relevance)
Coherence between the IED and activities covered by the UWWTD (treatment of waste water or sewage sludge and reporting especially) should be improved. More coherence is also needed between Directive on Environmental Quality Standards (Directive 2008/105/EC) and implementation of IED and sectoral BAT/BREF-documents.
IED must be aligned with the Circular Economy such that resources can be recovered and reused without the IED creating regulatory barriers. The IED must be aligned with future targets for carbon emissions under the Green Deal and create effective mechanisms to reduce industrial emissions of the climate change gases.
Read full responseResponse to Farm to Fork Strategy
16 Mar 2020
THE FARM-TO-FORK STRATEGY MUST PROTECT OUR WATER RESOURCES
EurEau welcomes the intention to develop a holistic strategy for a truly sustainable food production and consumption system. The food system will only change, if all its components move simultaneously. Hence, the strategy must lead farmers towards environmentally respectful practices, while retailers must pay fair prices to suppliers, and consumers need encouragement to reduce the environmental footprint of their diets.
EurEau supports the fact that the legal basis for the F2F Strategy includes TFEU article 191(2) (environment), according to which the Precautionary Principle, and the Control at Source and Polluter Pays Principles, particularly in relation to the impact of agriculture on water resources, must be applied.
The Strategy will have a significant impact on our water resources and, subsequently, the cost of drinking water production. It is well-known that agriculture increasingly affects the quantity and the quality of drinking water resources through over-abstraction and the intensive use of anthropogenic substances. It is unacceptable that the environmental costs of certain intensive farming practices are passed on to drinking water consumers while food prices remain artificially low.
With a view to protecting drinking water resources, EurEau calls for ambitious targets for reducing the use/risk of synthetic pesticides, increasing the land area dedicated to organic farming, decreasing antimicrobials use for farmed animals, and reducing chemical fertiliser use.
The F2F strategy must ensure consistency and coherence of the legislative framework (CAP, Nitrates Directive, Plant Protection Products Regulation, Biocides Regulation and Water legislation), proper implementation, mutual understanding and cooperation.
EurEau calls for the implementation of Articles 7(2) and 7(3) of the Water Framework Directive which are crucial for water resource quality and treatment levels required for drinking water production. The regulation of chemical substances should continue to be hazard-based only.
The F2F Strategy must promote the circular economy by creating a level playing field for water reuse for farmland irrigation and the use of recovered phosphorous from sewage sludge in fertilizers.
The F2F Strategy must take account of the conclusions of the recent European Court of Auditors report “Sustainable use of plant protection products: limited progress in measuring and reducing risks” and the Study on the impact of the CAP on water (2020), conducted by Alliance Environnement for DG AGRI.
Read full responseMeeting with Virginijus Sinkevičius (Commissioner) and
19 Feb 2020 · Water legislation in the context of European Green Deal and Zero Pollution Ambition
Response to Climate Law
3 Feb 2020
Climate change will directly and significantly affect water service operators in most parts of Europe, resulting in more frequent or intense periods of drought, heat waves or rain storms, and in more places.
Our sector’s response to climate change should encompass both mitigation (reducing the impact of water services) and adaptation (become resilient to its effects) measures.
The briefing note (sent as an attachment to the feedback) focuses on how climate change will impact on the water sector, and the ways and means to adapt to these changes based on our current knowledge.
When considering the revision of the EU water aquis in light of the EU Green Deal, the Climate Law and the Zero pollution ambition, EurEau thinks it is important that the Art. 191.2 of the TFEU is fully applied: this means that environmental damage has to be corrected as much as possible at the source and that the polluter should pay.
For instance advanced treatment processes for micropollutants exist but they are expensive, energy intensive and often substance-specific. We strongly believe that there is a need to assess more in detail the interaction between “advanced level of treatment” and “energy consumption” to avoid counterproductive measures in the context of the EU Green Deal. That is why we fully support measures that tackle the whole life cycle of micropollutants, where end of pipe treatment is only complementary to the source control approach in specific circumstances as recommended by the OECD (2019).
In order to have an overview about the extra-treatment and the increase in energy consumption please refer to the EurEau briefing on 'Treating micropollutants at waste water treatment plants': http://www.eureau.org/resources/briefing-notes/3826-briefing-note-on-treating-micropollutants-at-the-wwtp/file
At the same time, the water sector has made great strides in becoming more energy-friendly. Among the implemented solutions are reducing the energy consumption for heating, treatment, distribution and collecting of water, improving energy efficiency and the generation of energy through waste water components. There are, nevertheless, limits to these improvements. Principle factors include local configurations and finding the right balance between environmental objectives, economical feasibility and water services affordability.
More information can be found in the EurEau briefing on 'Reducing the Energy Footprint of the Water Sector', available at: http://www.eureau.org/resources/briefing-notes/3890-briefing-note-on-reducing-the-energy-footprint-of-water-sector/file
Read full responseResponse to EU 2030 Biodiversity Strategy
20 Jan 2020
EurEau is the European Federation of Water Services. We represent drinking water and waste water services in Europe from both public and private sectors.
EurEau supports the development of a comprehensive biodiversity strategy. Drinking water suppliers depend on the availability of healthy and uncontaminated water bodies. Despite measurable progress achieved under the EU biodiversity strategy to 2020, the decline in biodiversity could not be halted. The reasons are multiple and include habitat fragmentation, intensive agriculture, urban sprawl, land-use change, climate change etc. Hence, more binding measures are necessary.
Proposals for the strategy:
• It must be ensured that the protection of biodiversity is not limited to Natura 2000 areas, but becomes a general policy goal which is mainstreamed into existing legislation and forms an integral part of the 2050 climate ambition.
• Intensive agriculture accompanied by excessive uses of pesticides and fertilisers contributes to the loss of biodiversity, including in the aquatic environment. Hence, the biodiversity strategy must be closely interwoven with the forthcoming “farm-to-fork” strategy. Excessive pesticide and nutrient concentrations in water bodies do not only harm biodiversity, they also lead to substantial problems for drinking water suppliers. If they have to implement additional treatment, costs, energy use and, hence, greenhouse gas emissions increase. The link with the European Green Deal should be established.
• The mission of waste water operators is to collect and treat waste water so that it can be safely returned to the environment. However, micropollutants and microplastics increasingly find their way into waste water treatment plants. If they are removed in the treatment process, they end up in the sludge jeopardizing its recycling (for example on farmland) and triggering a push towards sludge incineration (impact on the Circular economy action plan). This will not only withhold valuable nutrients from soil but also lead to avoidable CO2 emissions (Green Deal). Advanced treatment to remove more micropollutants from waste water is very costly and energy-intensive and increases greenhouse gas emissions. In order to avoid this vicious circle, the Biodiversity strategy must be built on article 191.2 TFEU, i.e. it must start from ambitious control-at-source measures and implement the polluter-pays principle to prevent/repair damage to biodiversity stemming from the use of certain substances and particles.
On the practical side, the strategy should ensure the following:
• The Commission concluded in December 2016 that the Birds and the Habitats Directive (BHD) was fit for purpose. In December 2019, the Commission stated that also the Water Framework Directive (WFD) was broadly fit for purpose (which does not exclude its revision). In both cases, a lack of full implementation was identified as one of the key factors for not achieving all goals and targets.
• In order to avoid duplication and benefit from synergies, the BHD implementation action plan should ensure improved inter-connection between the WFD, the Marine Strategy Framework Directive (MSFD) and the BHD.
• The findings and results of the BHD implementation action plan should be taken into account in the WFD review.
• Inconsistencies between the BHD (art. 6(4)) and the WFD (art. 4(7)), especially on the interpretation of ‘overriding public interest’, should be overcome.
• The alignment and coordination of implementation cycles of these directives should be improved.
• Synergies and connections between River Basin Management Plans (WFD) and the BHD management plans should be developed.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
EurEau is the European Federation of Water Services. We represent both drinking water and waste water services in Europe. EurEau is committed to acting for the water sector to be part of the circular economy.
According to the first elements available on the New Circular Economy Action Plan (NCEAP), we are very disappointed that water is not mentioned. Even if “water is not a product like any other” as referred in the Water Framework Directive, it would be a failure for the society in its move towards a circular economy not to include water resources and water services in the plan.
Water services are already recovering various resources from their processes, including energy, organic compounds or nutrients (see our Briefing note attached). It is of primary importance that the NCEAP supports and accelerates the uptake of those products by the market (biogas, recovered phosphorus, biosolids, reclaimed water, etc.) in order to encourage and secure long-term investments while ensuring the affordability of water services. Today, many of the material recovery activities are not financially viable as the costs are higher than the prices that can be obtained on the market. In that sense, EurEau welcomes the intention of the European Commission to “foster a well-functioning and integrated internal market for secondary raw materials” and we would support further action and regulation on blending for fertilisers or biogas in order to encourage the use of good quality recovered products. Entering into a circular economy mode to recover material like nutrients need long term investments which will be decided only if they are secured by a clear and supportive legislation.
To enable the circular economy, EurEau sees that significant innovation is required. This may be in technology, business models and in the co-operation between stakeholders. The NCEAP should create space for new and presently unforeseen ways to recover and reuse resources across the value chain. EurEau agrees that the NCEAP “address the enabling conditions supportive of a more circular economy, such as innovation and investment opportunities for circular business models and enabling technologies” but under the conditions of protecting the environment (incl. climate change mitigation & adaptation) and health of citizens.
Successful material recovery requires the full implementation of control-at-source measures to ensure that waste water and water resources are not accumulating pollutants that would threaten the quality of the recovered products (mainly biosolids and reclaimed water) or would require extra treatment to ensure that the recovered product achieves the quality required by the market. It is crucial, as mentioned in the roadmap, that “minimum requirements [are set] to prevent environmentally harmful products from being placed on the market”. The use-phase of the products needs to be carefully addressed in order to prevent the release of harmful substances, like microplastics or PFAS, in the waste water infrastructure and water resources. Those products are the main obstacle to the reuse of products coming from waste water treatment plants. Strong control at source policy will guarantee the possibility for water services to recover good quality products from their facilities that can be reused safely. Moreover, it will ensure that no extra treatment is used, keeping water services affordable for all. If substances are released during the use-phase of the product and require extra treatment by water services, the Extended Producer Responsibility concept should be applied to substances, not only products, with a view to better implementing the polluter-pays principle and not putting the burden of the extra cost on water consumers.
Finally, the water legislation has been evaluated. In the next steps, it should be clear that the Water Acquis should be looked at with the view to being circular in order to support the water services in their evolution.
Read full responseMeeting with Daniel Calleja Crespo (Director-General Environment)
11 Oct 2019 · Drinking and Waste Water
Response to EU farm policy - Evaluation of its impact on sustainable management of the soil
21 Aug 2019
Soil management has a substantial impact on the quality of drinking water resources through nutrient management, pesticide use and erosion. Both surface water bodies and groundwater can be affected. The fitness check should therefore establish to what extent the CAP and the Pesticides regulation ensured compliance with article 7 of the Water Framework Directive (2000/60/EC), avoided the contamination of drinking water resources and, by doing so, prevented costly counter-measures by drinking water suppliers.
Sludges produced through the treatment of waste water are sources of organic matter and nutrients. The existing Urban Waste Water Treatment Directive (91/271/EEC) states the recycling of sludge arising from waste water treatment should be encouraged. The CAP instruments do not sufficiently enable high quality sludge from waste water treatment to be recycled and therefore contribute to the sustainable management of soils. CAP instruments do not sufficiently support or enable circular nutrient recycling. Perversely, the agricultural sector relies on non-renewable, mineral-based fertilizers derived from finite rock sources, which is not sustainable and may cause pollution and eutrophication of the water cycle.
Treated waste water can also be used in agriculture as a source of irrigation water, available locally in rural areas and already available with nutrients. We draw your attention to the forthcoming Regulation on minimum requirements for water reuse. Local recycling and reuse of nutrients from treated waste water and sludges (through both direct application and co-digestion with farm organic wastes) should form part of the evaluation / fitness check for the sustainable management of soils.
Read full responseResponse to European Partnership for a Circular bio-based Europe
21 Aug 2019
European urban waste water operators collect and treat between 23 and 38 billion litres of waste water per year. Waste water can be an important source of organic matter and nutrients which can be used as organic fertiliser and soil stabiliser, for biogas generation, for the recovery of cellulose, as raw material for bioplastics and the recovery of nutrients for reuse. Waste water can also provide an invaluable supply of irrigation water supporting food production and security and sustaining the economy in rural areas.
Despite their substantial potential, many new solutions such as cellulose recovery and bioplastics are in their early infancy as current technologies are either not mature or too expensive. Other circular solutions may be hampered through regulatory requirements and insufficient policy co-ordination at the EU-level.
The partnership could be an effective tool to overcome these bottlenecks. The waste water sector should therefore be included in any follow-up actions.
Read full responseResponse to Evaluation of the Industrial Emissions Directive
3 Dec 2018
EurEau fully supports the goals and tools of the IED. We see, however, that pollutants from industrial sources are still released to the aquatic environment where they pose a threat to the quality of water resources (see the EEA report on Status of European Waters 2018). Water suppliers are obliged to invest in expensive and energy-intensive treatment process to remove pollutants and comply with the stringent requirements of the Drinking Water Directive. One current example is the presence of PFAS in water resources used for the production of drinking water. Increasing the treatment at the level of the drinking water plant would lead to massive increases in the price for water services and will reflect in higher bills for customers. Following the precautionary principle and control at source principle as enshrined in the Treaty (art. 191.2), the authorisation and the release of such substances to the environment should be banned, restricted and controlled.
With this in mind, any permits for plants covered by the IED and the related BAT should include requirements for the protection of water resources in order to avoid deterioration of the quality of water bodies and increased treatment by drinking water suppliers (Water Framework Directive art.7.3).
Preventive measures should be taken at the source and the polluters should pay according to the extended producer's responsibility.
Read full responseMeeting with Phil Hogan (Commissioner)
27 Nov 2018 · AGRI MATTERS
EurEau Demands Stricter CAP Rules to Safeguard Water Quality
22 Nov 2018
Message — EurEau demands that the CAP aligns with water legislation through mandatory requirements rather than voluntary projects. They argue that farmer subsidies must depend on compliance with strict environmental targets.12
Why — Stronger source protection would lower the massive treatment costs currently paid by water utilities.3
Impact — Intensive farmers would lose financial support if their practices damage water quality or quantity.4
Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan), Tom Tynan (Cabinet of Commissioner Phil Hogan)
6 Sept 2018 · "Blueing” of the CAP
3 Aug 2018
EurEau, the European Federation of Water Services, welcomes the legislative proposal since we have called for it for the past decade to increase confidence in the reuse of treated waste water. The regulation is well structured and clear for implementation in Member States (MS). It does not oblige MS to reuse water as there is no need today in a number of MS. It also allows MS that want to implement it to reinforce the minimum requirements when necessary through the delivery of the permit. As to the requirements, Article 4 defines the point of compliance (PoC) at the outlet of the reclamation plant, where the performance of the treatment can be evaluated. The entire water reuse project (production, storage and distribution) has rightly to be assessed by the risk management plan described in the annex II of the regulation.
The water quality requirements described in Annex I, although demanding for the reclamation plant operator in terms of costs, are strongly oriented towards food security, ensuring a strong protection of human health.
However, we see major points to be improved to make this regulation applicable. The main drawback is the distribution of the responsibilities between involved stakeholders. The proposal is based on the “production” and distribution of the reclaimed water. We think the responsibilities over the whole water reuse system should be shared between all stakeholders (producers and users) to enforce the continuity of safety from the UWWTP to the point of use. For example, currently, only the reclamation plant operator has responsibility to assess the risks of the project. EurEau believes that this should belong to the responsible body of the reuse project (public authority, group of users, municipality, etc.).
Regarding the water quality requirements (Annex I), we think that the large scale performance proof of log reduction of biological indicators for reclamation plants providing “class A” water might be extremely difficult to obtain, especially with very diluted effluents where the concentration of coliphages or clostridium in the raw water is low. An alternative could be that the absence of the biological indicator at the effluent assumes the achievement of the validation.
Regarding annex II describing the tasks of the risk management plan, the degree of details required (for each plot, community of users, plot with the worst case, etc. ...) should be better specified as it can increase significantly the cost of water reuse.
Some of the substances listed in paragraph 5 can also originate from other products used in agriculture and, therefore, cannot be limited to possible water reuse emissions. The users of reclaimed water (or the reclamation plant operators) cannot be the only ones to be held responsible for possible risks derived from this type of compounds.
When establishing the water quality requirements, many possible barriers to limit contamination of the irrigated products have been disregarded. They include the time between irrigation and harvesting of the product or the use of surface covers that prevent the contact of reclaimed water with the crop. These systems significantly reduce the risk of microbiological contamination of crops and they should be included in the risk management plan to limit the requirements of the permit to the minimum necessary and not compromise the affordability of the water reuse project.
Considering the adaptations required for existing facilities to comply with the regulation (improving the existing equipment, changing the operation and controls and conducting the risk assessment and establishing the risk management plan and assigning responsibilities), we consider that the proposed time of one year should be extended by at least two more years for the entry into force of the regulation.
Finally, in the light of the current draught, it should be verified whether the proposal enables MS to take one-off emergency measures.
Read full responseEurEau urges CAP to prioritize protection of water resources
1 Aug 2018
Message — EurEau wants the CAP to stop funding practices that harm water quality. National plans should include specific indicators for drinking water protection. Innovation funding should target projects linking the water and agriculture sectors.123
Why — Source pollution control reduces the need for expensive purification treatments for utilities.45
Impact — Public authorities and stakeholders must pay more as EU co-financing shares decrease.6
Response to Reducing marine litter: action on single use plastics and fishing gear
22 Jul 2018
EurEau supports the proposal of the European Commission to reduce the environmental impact of single-use plastics (SUP). It is in line with article 191.2 of the Treaty regarding the application of the precautionary principle and the principles that preventive action should be taken, that environmental damage should be rectified at source and that the polluter should pay. It also complies with directive 2000/60/EC defining water as a heritage which must be protected, defended and treated as such and requiring the protection of drinking water resources and aquatic ecosystems, and the application of the polluter-pays principle.
Single use plastics and urban waste water treatment
As outlined in the proposal, certain SUP, for example wet wipes, tobacco product filters and cotton bud sticks, may end up in the sewer network due to inappropriate disposal practices.
In most cases, waste water collection and treatment plants remove SUP, but the process is costly and energy-intensive. Moreover, combined sewer overflows may lead to direct release and a part of these plastics – partially in the form of microplastics - may therefore find their way to water bodies with all the negative environmental impacts.
The Commission’s impact assessment estimates the cost of remedial action at the level of waste water collection and treatment at €7.7 billion p.a. This represents about 18% of the total turnover of the EU’s waste water sector.
Hence, apart from contradicting art. 191 of the Treaty, this solution would be disproportionate from an economic point of view and would seriously jeopardise the affordability of water services and the investment capacity of operators.
Even if waste water treatment plants (WWTP) removed all SUP it would not make them disappear. Even worse, the burden of waste disposal would be placed on waste water operators. Moreover, the mechanical forces in the sewer network (flow, friction, pumping) may lead to the continuous release of microplastics from these products (especially from wet wipes).
Hence, measures must be taken at the source and the polluter pays principle must be applied.
The impact assessment omits one highly relevant cost factor. Wet wipes regularly cause the clogging of pumps and the blockage of pipes in the sewer network. For the UK alone, the cost of clearing blockages in the sewer network are estimated at €115 million per year.
Furthermore, clogged pumps may cause sewer overflows and, thus, release single-use plastics and microplastics to the environment.
EPR schemes must include the waste water infrastructure
EurEau welcomes the Commission proposal of including wet wipes and tobacco product filters in EPR schemes and awareness raising measures, and requiring the compulsory do not flush labelling of all plastic-containing wet wipes.
Experience clearly tells us that labelling alone will not be effective, and inappropriate disposal by consumers seems difficult to control. In Belgium, wet wipes have carried a “do not flush” label since July 2016, if they fail flushability tests. However, no significant improvement was noticed in the sewer network.
The Commission proposal remains unclear as to whether the costs of waste management and clean-up of litter (article 8 on EPR schemes) includes littering into the sewer network and the actions of waste water operators to unblock the pipes and pumps and dispose of the recovered wet wipes. With a view to effectively implementing the polluter pays principle, EPR schemes must explicitly cover this littering pathway including the related environmental harm and economic damage for waste water operators. This would incentivise plastic-containing wet wipe manufacturers to develop products that respect the environment, i.e. that are easily biodegradable and dispersible and that do not release microplastics.
Read full responseResponse to Evaluation of the 2008 European Critical Infrastructure Protection Directive
27 Mar 2018
Water infrastructure, including both public drinking water distribution networks and waste water collection and treatment networks are usually local or, at the most, regional. Cross-border connections between these networks would be the extreme exception. Hence, the definition of ECI as infrastructures covering at least two Member States would not be applicable to the water sector.
EurEau therefore maintains that neither public drinking water distribution networks nor public waste water collection and treatment networks qualify as ECI and should remain excluded from the scope of the ECI directive in future revisions.
To the best of our knowledge, public drinking water distribution networks are defined as critical infrastructure, in one way or another, in all Member States. Detailed national requirements for infrastructure protection need to be followed. Obviously, the level of requirements differs between countries.
Waste water networks are classified as critical infrastructure in a number of, but not all, Member States, as security risks are generally considered to be significantly lower.
Read full responseResponse to Revision of the Drinking Water Directive (RECAST 2017)
22 Mar 2018
EurEau welcomes the revision of the DWD, as European water services strive to guarantee wholesome and clean drinking water to consumers.
Art.2 will not allow sufficient delineation of suppliers. The definition of “large supplier” should be amended as it includes rather small suppliers.
Art.5+Annex I:EurEau welcomes the update of parameters of Annex I. We want to maintain the indicator parameters. For certain parameters EurEau suggests to embrace the WHO recommendations and/or grant extra time (15 years) after the end-date for transposition, to adapt and make it possible to attain the proposed values.
Art.7:We support the introduction of the RBA, but call for a more operational approach. The way the proposal would enact RBA, raises issues in terms of responsibilities (MS, water operators, property owners), of the additional health benefits of such a high frequency of sampling for chemical parameters which tend to be quite stable and the absence of linearity between sampling frequencies and population. These aspects are only partially considered in the IA as highlighted by the RSB opinion: http://bit.ly/2tAkQOI.
See attached data considering only monitoring costs: resources could be more effectively spent in the protection of water bodies. The supply risk assessment should be carried out by all suppliers, without distinction of size, by 6 years after the end-date for transposition, and its review/update shall be carried out whenever necessary.
Art.8: EurEau supports the link between the DWD and the WFD while clearly stating MS responsibility for protecting drinking water resources.
Art.10: EurEau regrets the deletion of art.10 of 98/83/EC Dir. The introduction of a “domestic distribution risk assessment” is welcomed, but the proposed provisions don’t ensure that EU-wide hygienic requirements for materials in contact with drinking water are set also for public water supply infrastructure. We’d welcome a strengthening of the current art.10 while maintaining the link between DWD and CPR.
Art.12.3:We don’t support the deletion of current art.9 “Derogations” nor the proposal that any exceedances of values should be considered “automatically as potential danger to health”: this undermines consumers’ trust. Especially with regards to parameters where values have been set based on the precautionary principle (pesticides, or EDCs) an exceedance doesn’t cause automatically a danger to human health. The wording of art.12.3 contradicts the wording of art. 12.2. The competent health authorities should participate in the decision on when the public needs to be informed on exceedances and the subsequent remedial actions.
Art.13:We support the ambition to address gaps in the provision of tap water and to put measures in place that allow affected groups to gain access to water. The Dir. requires MS to engage with these communities to address the risks and mitigation options. We second the IA findings that individual connection to the piped system would be too costly. We support the ambition to increase access to water in places of recreation, cafes and restaurants already in place with positive effects in some MS. However, any schemes need to consider factors such as where the responsibility for maintenance, hygiene and cost coverage of these installations will lie, as this will likely be outside the remit of water suppliers.
Art.14+Annex IV:We favour transparency. More information could lead to more interest from public and policy makers. It is unclear who has to carry out the obligation to ensure that information is made available online. If this were carried out by water suppliers or by competent authorities, extra resources would be required. The IA doesn’t acknowledge it. Furthermore, we do not want to lose the focus on the information provided to consumers on water quality aspects, as in the scope of the current Dir. Annex IV (7) further definitions at Member State level will be needed for points (a), (d), (e), (g).
Read full responseMeeting with Elżbieta Bieńkowska (Commissioner) and
21 Feb 2018 · Exchange of views on current topics
Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and European Chemical Industry Council
23 Nov 2017 · Discussion on Drinking Water Directive
Response to Fitness Check of the Water Framework Directive and the Floods Directive
15 Nov 2017
EurEau welcomes the evaluation of the WFD, its ‘daughter directives’, and the FD, as well as the integrated approach pursued by the Commission in this exercise. EurEau considers the WFD not only the most important instrument for the protection of EU water bodies, but also the key to deliver sustainable water services. Over the past 15 years the WFD has ensured greater public involvement and engagement in water and environmental policy, while the FD created a framework in which flood risk is managed: both directives have established the principle of planning for environmental improvements and protection. Yet, EU citizens need a much greater understanding of the value of water, including water pricing policies and the governance of water services, namely which players are involved, who takes the decisions on how water services are managed and who is responsible for what.
EurEau welcomes the scope of the evaluation, including potential regulatory simplification and the assessment of the costs and benefits of the directives. Such an analysis should also investigate how the costs and benefits are distributed and consider the most equitable way for all beneficiaries to contribute to the financing of measures to achieve the objectives of the directives. The WFD lays down the principle of cost recovery for water services in Art. 9, including environmental and resource costs. The evaluation should look at how all users (households, industry and agriculture) contribute to the financing of the RBMPs measures. It should consider, for instance, if the abstraction of water for agricultural purposes in areas with water scarcity is subject to a price (an abstraction fee).
Furthermore to ensure the availability of this natural resource, and guarantee the human right to water, water abstraction for drinking water purposes should have priority over other uses, in the meaning of the WFD, and according to sound water ecosystem management practices.
The assessment should also explore whether stakeholders engagement and partnership working have been effective or need improvement.
As the water infrastructure in many parts of Europe is ageing, in some countries, the charges collected from the users are not sufficient to maintain and renew the systems in due time. Tariffs should be set on the basis of the investment needs of the water infrastructure so that long-term planning is allowed. For this reason the evaluation should consider whether and how policy coherence and the co-ordination of long term planning cycles with other directives have performed (EurEau attaches a position paper to the feedback on policy coordination). The fitness check should especially look at the missing links between WFD and chemicals legislation and how far the source control approach has been applied in accordance with art. 191.2 TFEU. EurEau calls on the Commission to evaluate the implementation of art.7a of the Priority Substances Directive 2013/39/EU by which any substance identified as a priority substance should automatically be re-evaluated and listed for further restrictions under the relevant chemical legislation. The Polluter Pays Principle should be extended in the WFD, to include the 'User Pays' Principle as well.
EurEau calls on the Commission to specifically evaluate the implementation of art.7.3 of the WFD in detail and assess the measures taken by Member States to avoid deterioration in water quality in order to reduce the level of purification treatment required in the production of drinking water. In view of an effective and efficient protection of drinking water resources the implementation of the WHO Water Safety Plan approach (EN 15975-2) should be envisaged to involve all relevant stakeholders in water catchment areas.
EurEau calls on the Commission to focus on better communicating the benefits of the WFD but also analyse in depth and understand in detail the causes behind the failure of water bodies to reach good status by 2015.
Read full responseResponse to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)
7 Nov 2017
EurEau welcomes the initiative of the European Commission to evaluate the Urban Waste Water Treatment Directive (UWWTD) after 26 years of implementation.
EurEau is the European association of water operators and represents nearly all the European waste water operators.
UWWTD is a central pillar of the waste water services in Europe and has successfully created a level playing field for environmental standards and economic investment by setting baseline requirements for urban waste water treatment.
UWWTD was, and still is, a powerful driver:
- to enhance the protection of European waterbodies
- to implement the polluter pays principle and to create a high value market of works and services by building and by operating numerous assets for collection and treatment of urban waste water across the EU
- to enable a better structure of the water sector in the EU, irrespective of the choice of governance models at MS level
- to increase scientific knowledge and technical innovation
- to create numerous stable jobs requiring different levels of competence and skills.
We agree that time is now to evaluate the costs and benefits of UWWTD implementation. UWWTD is one of the most expensive European directives as its implementation required heavy and long investments, that are in some places still on-going. We consider that it would be very useful to investigate the reasons for non-compliance and to carefully assess what is possible to achieve in the future, in the framework of the sustainable development goals.
We emphasize that the main issue for waste water operators across Europe is to manage, refit or renew the ageing assets that require huge and urgent investments.
We stress the need for better policy coordination by updating coherence between UWWTD and the European water laws, including chemicals regulations. This will allow that new challenges such as emerging pollutants, management of by-products in a more circular economy, adaptation to climate change, evolution towards less energy consuming assets to be sustainably addressed.
We consider that water industry has a role to play in the circular economy. Evaluation of UWWTD directive provides the opportunity to clarify and align the approach for sewage sludge, possibly through adaptation of other regulations.
We consider that financing new developments cannot only rely on increasing the water bill. Affordability of services, to keep the water environment clean and to safeguard water resources for human health, requires that the polluter pays principle be clarified in many cases and the extended producer responsibility be incorporated.
The evaluation must consider compliance with industrial waste water requirements. Industry should develop responsible solutions to reduce harmful impact of their products on the environment and waste water assets. We consider that control at source is the most sustainable way to avoid the release of many pollutants, with end-of-pipe treatment remaining the last option.
We consider that for resilient cities an early integration of the water cycle in city planning and real estate projects has to be addressed to achieve better climate adaptation by reducing urban runoff, discharges from all types of sewer networks and urban flooding or drought events.
Because of the universal nature of water we consider that EU-added value is relevant for management of water and waste water even if implementation may be achieved by locally different enforcement solutions depending on natural or human conditions.
We welcome the evaluation as an opportunity for innovation, to enable improvements in performance and efficiency of the waste water sector and creating a more sustainable & resilient approach in the future.
We have significant knowledge and expertise in waste water and rainwater collection and treatment. We look forward to sharing our expertise to support the European Commission in the UWWTD evaluation process.
For EurEau, water matters.
Read full responseResponse to Evaluation and potential revision of the EU tyre labelling scheme
14 Jul 2017
EurEau welcomes that the "evaluation and impact assessment will also examine whether information on abrasion (which contributes to air pollution and microplastics in the water supply) could be improved in a proportionate way so as to make consumers better informed on their contribution to the circular economy."
We would highlight that abrasion contibutes to microplastics in WATER RESOURCES, and not directly water supply.
Since the tyres are an important source of microplastics emitted to the aquatic environment, the labelling scheme should include microplastics emissions during normal wear and tear as an indicator.
Read full responseResponse to Strategic approach to pharmaceuticals in the environment
19 May 2017
Micropollutants are a challenge for waste water operators, whose mission is to treat waste water to ensure the protection of the environment and ecosystems, and for drinking water operators, who have to rely on drinking water resources to produce drinking water.
Micropollutants can enter the water cycle directly or indirectly via the waste water treatment infrastructure: urban and domestic waste water, industrial waste water, hospital effluents, storm water runoffs, and also through agricultural or rural runoffs and manure. Since micropollutants are not entirely biodegradable, once present in the water cycle, they can gradually accumulate and could pose a risk to drinking water resources and aquatic ecosystems.Technologies currently used in waste water treatment plants are not entirely capable of removing micropollutants.
Advanced treatment processes exist but they are expensive, energy intensive and often substance-specific: they rarely come out well in cost effectiveness and environmental performances analysis. Innovative technologies and solutions that address these drawbacks are being developed. EurEau recognises that these may provide a useful treatment solution for tackling specific micropollutants or addressing specific local conditions in the long term.The most sustainable and preferred solution however is to prevent micropollutants from entering the water cycle in the first place. Steps should be taken at various stages before they can enter the water cycle to prevent them from doing so. Their release should be addressed as a priority at the source, meaning along the different steps that precede their emission, discharge or loss into the aquatic environment. Establishing the necessary conditions that support such a source control approach is an EU wide challenge.
EurEau calls on the European institutions to:
- adopt a strategic approach to micropollutants based on the source control principle
- consider the life-cycle approach to substances when legislating
- use the ecolabel more extensively, and
- contribute to awareness-raising amongst citizens.
The Directive on Priority Substances requires the European Commission to come up with a strategic approach to pharmaceuticals in the environment (PiE). EurEau supports the adoption of such a strategic approach where actions should be taken along the whole life cycle of a pharmaceutical product (design, authorisation, marketing and post marketing) so that potential environmental damage is rectified at the source (see attached paper).
Unlike pharmaceuticals consumed by humans, which tend to end up in the aquatic environment through point source discharges associated with waste water treatment works, veterinary medicines will tend to follow a more diffuse route affecting the rural water cycle rather than urban ones. Pharmaceuticals can enter the water cycle in many ways: i) via direct application such as in aquaculture; ii) animal excretion on land which drains into the water cycle; iii) through secondary application of composted animal manures or iv) through the disposal of other solid and liquid animal wastes. Pharmaceutical residues can be found either in the form of the active compound or metabolites. EurEau considers that action is needed on different levels to reduce the presence of veterinary pharmaceuticals in the aquatic environment:
- Design level: development of green pharmacy
- Authorisation level and post-authorisation level
- Veterinarians’ prescription level: It is very difficult to foresee the actual loading of veterinary pharmaceuticals in the environment, since, contrary to medications for human use, there are no audit trails associated with prescription practices, thus there is lack of information and transparency in the current system. This lack of information is proposed to be reversed particularly in the cases of large animal populations such as big farm.
- Application level
- Good agricultural practises
Read full responseResponse to Revision of the Drinking Water Directive
21 Mar 2017
EurEau welcomes the opportunity to comment on the updated IIA on the DWD.
We appreciate the European Commission’s outlined ‘consultation strategy’ and we are available to take part in it and cooperate and share input along the impact assessment process.
EurEau would like to share the following comments on the Inception Impact Assessment:
We support a European scheme to ensure compliance with hygiene requirements of materials and products in contact with drinking water and is willing to share its ideas on how to develop art.10 via a separate contribution to DG ENV.
EurEau strongly support the study on the evaluation of Annex I by WHO.
EurEau supports the water safety planning and the risk-based approach, however we think that water operators should not be the direct addressees of the DWD obligations, due to the following reasons:
1. WHO Water Safety Plan (2004) is a holistic approach. This means all stakeholders from catchment to tap have shared responsibilities so that at the tap safe, wholesome and clean drinking water is provided for consumers. EurEau consistently supported this approach.
2. Having this basic idea of the WSP in mind, responsibilities lie:
a. with the environmental authorities, health authorities, land users, etc. and of course - but only to a certain extent - with the water utilities in the catchment area of drinking water abstractions,
b. with the water utilities, from abstraction to the point of delivery
c. with the property owner within the domestic installation
3. Given this system of shared responsibilities, once the decision to implement the WSP approach in a revised Drinking Water Directive is made, the European Commission should identify the addressees of legal provisions according to the responsibilities outlined above, under point 2. To address only one stakeholder (namely the water utilities) would fail to deliver a comprehensive implementation of the Water Safety Plans and the relative benefits.
4. Having in mind that the Drinking Water Directive addresses the Member States, the implementation of the WSP-approach in a revised legislation creates exactly the necessary frame. It is then up to the Member States, according to the subsidiarity principle, to organise how the WSP approach is applied according to the different responsibilities:
a. in the catchment area
b. from abstraction to the point of delivery
c. within the domestic installation
If the European Commission is eager to implement the WSP-approach in a revised DWD, all relevant stakeholders should be considered in the transposition phase of the DWD by Member States as addressees of the DWD, according to their responsibilities.
If only water utilities were addressed the following shortcomings occur:
1. any hazard analysis and risk assessment for the catchment area of a drinking water abstraction point done by the water utility is worthless until no reaction/measures etc. are taken and enforced by the responsible stakeholder in the catchment area (e.g. industry discharge, leaking waste water pipes, storage of liquid manure)
2. it is well known that the inappropriate use of materials and products in contact with drinking water in the domestic installation, unqualified personnel for building and maintaining the domestic installation, stagnation periods etc. can lead to deterioration of the drinking water quality on the way from the point of delivery to the tap. Raising awareness about these shortcomings, establishing of quality assurance systems etc. at the level of the property owner is urgently necessary. Besides this capacity-building at the level of the health authorities is as well needed.
EurEau will contribute in the upcoming future with a separate document on information to consumers.
Read full responseResponse to Criteria to identify endocrine disruptors for biocidal products
28 Jul 2016
EurEau represents national associations of water services in Europe who heavily rely on the confidence of their consumers in the quality of drinking water resources. Water suppliers must have access to adequate and reliable sources that are protected from contamination. The sustainable protection of source waters is essential for the supply of safe, clean drinking water that complies with the requirements set by the Drinking Water Directive (DWD), now and for future generations.
For countries where water supply relies mainly on groundwater sources, the contamination of groundwater reserves can result in loss of billions of Euros due to the loss of valuable groundwater resources and investments in connected water supply installations (abstraction, treatment and distribution).
Agriculture is considered as the greatest contributor to pesticides in surface water and groundwater used for the abstraction of drinking water. Pesticides, their metabolites and transformation products are increasingly having a negative impact on the quality of water resources, and drinking water operators have to resort more and more to extra and expensive treatment while consumers bear the costs.
EurEau advocates stringent cut-off criteria such as the assessment of endocrine disrupting properties of chemical substances in the authorisation process for all substances, which could have an impact on water resources. We believe that the ban of substances should be decided according to a hazard based approach which takes into consideration the risk of adverse impacts on water resources (groundwater and surface water).
EurEau welcomes that the Commission's draft Regulation setting out scientific criteria for the determination of endocrine-disrupting properties pursuant to Regulation (EU) No 528/2012 is focusing on the intrinsic properties of substances as opposed to non-scientific considerations such as potency. However, EurEau regrets the absence of categories proposed in option 3 of the roadmap. These categories would have ensured the application of the precautionary principle with regards to endocrine active substances and the potential risk that certain molecules could have on the quality of water resources. We encourage the European Commission to reconsider the addition of the categories I (endocrine disruptors), II (suspected endocrine disruptors) and III (endocrine active substances).
EurEau is available for any complementary information regarding the impact of the proposed definition on the quality of water resources.
Read full responseResponse to Criteria to identify endocrine disruptors for plant protection products
28 Jul 2016
EurEau represents national associations of water services in Europe who heavily rely on the confidence of their consumers in the quality of drinking water resources. Water suppliers must have access to adequate and reliable sources that are protected from contamination. The sustainable protection of source waters is essential for the supply of safe, clean drinking water that complies with the requirements set by the Drinking Water Directive (DWD), now and for future generations.
For countries where water supply relies mainly on groundwater sources, the contamination of groundwater reserves can result in loss of billions of Euros due to the loss of valuable groundwater resources and investments in connected water supply installations (abstraction, treatment and distribution).
Agriculture is considered as the greatest contributor to pesticides in surface water and groundwater used for the abstraction of drinking water. Pesticides, their metabolites and transformation products are increasingly having a negative impact on the quality of water resources, and drinking water operators have to resort more and more to extra and expensive treatment while consumers bear the costs.
EurEau advocates stringent cut-off criteria such as the assessment of endocrine disrupting properties of chemical substances in the authorisation process for all substances, which could have an impact on water resources. We believe that the ban of substances should be decided according to a hazard based approach which takes into consideration the risk of adverse impacts on water resources (groundwater and surface water).
EurEau welcomes that the Commission's draft Regulation setting out scientific criteria for the determination of endocrine disrupting properties and amending Annex II to Regulation (EC) 1107/2009 is focusing on the intrinsic properties of substances as opposed to non-scientific considerations such as potency. However, EurEau regrets the absence of categories proposed in option 3 of the roadmap. These categories would have ensured the application of the precautionary principle with regards to endocrine active substances and the potential risk that certain molecules could have on the quality of water resources. We encourage the European Commission to reconsider the addition of the categories I (endocrine disruptors), II (suspected endocrine disruptors) and III (endocrine active substances).
EurEau is available for any complementary information regarding the impact of the proposed definition on the quality of water resources.
Read full responseMeeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)
27 Aug 2015 · Circular Economy