Resources - Position papers

Directive 2022/0344 amends the Water Framework Directive (WFD) and its two daughter directives, the Groundwater Directive (GWD) and the Environmental Quality Standards Directive (EQSD).

The proposal adds pesticides, pharmaceuticals and PFAS to the priority substances lists for surface water and groundwater, and sets more flexible procedures to update Environmental Quality Standards (EQS).

EurEau welcomes the enlargement of the EQS lists as a prerequisite to providing safe and affordable drinking water services to consumers and as an effective means of protecting the environment.

If EQS are exceeded, the EU and Member States are obliged to take action to curb the emissions. EurEau requests that, in line with Article 191.2 of the Treaty on the Functioning of the European Union (TFEU), any exceedance of EQS should primarily trigger control-at-source measures.

EurEau welcomes the European Commission’s Proposal for a Directive concerning urban wastewater treatment (recast) as its more ambitious objectives will align better with the overarching UN’s Sustainable Development Goals and the European Green Deal while enhancing the governance of the wastewater sector and people’s access to sanitation. Reaching the new goals and requirements as set out in the Proposal will require mainstreaming control at source, significant investments and time.
The purpose of this position paper is to identify the key topics within the Proposal which EurEau members see as the agenda to take forward through the
amendments process, aiming at enabling an effective and efficient implementation and achievement of the Proposal’s objectives.

Enabling the circular economy for waste water services requires the alignment of a set of directives regulating the sector. The Urban Waste Water Treatment Directive (UWWTD), the Industrial Emission Directive (IED), the Waste Framework Directive (WFD) and the Sewage Sludge Directive (SSD) are key to the collection and treatment of urban waste water and subsequent treatment and re-use of urban waste water treatment sludge (UWWTS).

Water and agriculture are essential for life. However, agriculture increasingly affects the quantity and the quality of drinking water resources. EurEau insists on the proper implementation EU legislation so as to protect health and the environment.

The Fertiliser Regulation opens the door to using recovered phosphorus from sewage sludge in fertiliser products. Including treated input materials from waste water treatment plants as a component in fertilisers promotes recycling and is better for the environment.

Banning amalgam will help sludge from waste water treatment meet the quality standards to be reused in fertilisers, improving the environment.

Waste water collecting systems are a vital part of the urban environment across Europe. We recognise many opportunities to make urban environments more sustainable through the management of waste water flows and storm water. We need better coordination with other EU legislation to protect health, the environment and consumers from additional costs.

The Plant Protection Products Regulation, the Biocidal Products Regulation, and the REACH Regulation send the right signals regarding the hazard-based approach and the precautionary principles with regards to the protection of water resources. We need better coordination with other EU legislation to protect health, the environment and consumers from additional costs.

Microplastics can enter the water cycle in many ways and are not entirely biodegradable. They can accumulate and could pose a threat to our water resources and ecosystems. Control at source is essential for microplastics to prevent them from entering the environment. We need extended producer responsibility. Additional treatment steps exist which will lead to increased tariffs for consumers.

Increased treatment to provide consumers with clean water means increased consumer costs.

Phosphorus is a scarce yet vital resource. Recycling phosphorus from sewage sludge in fertiliser products promotes recycling and is better for the environment.

Cadmium in residual products from waste water treatment plants reduces their ability to be recycled and reused. By banning the use of cadmium in paints and other products, we open the doors to better recycling and better environments.

Phosphorus is a scarce yet vital resource. Recycling phosphorus from sewage sludge in fertiliser products promotes recycling and is better for the environment

Banning mercury will help sludge from waste water treatment meet the quality standards to be reused in fertilisers, improving the environment.

Recycling sewage sludge in fertiliser products promotes recycling and is better for the environment.

Plastics can enter the water cycle in many ways and are not entirely biodegradable. They can accumulate and could pose a threat to our water resources and ecosystems. Plastics need to be prevented from entering the environment in the first place. We need extended producer responsibility. Additional treatment steps exist which will lead to increased tariffs for consumers.

The efficient use of water means reduced costs for consumers and better environments for us all – today and tomorrow.