Resources - Position papers

European waste water service providers see the revision of the 1991 Urban Waste Water Treatment Directive (UWWTD) as an opportunity to develop an ambitious, innovative, supportive and straight-forward new policy framework enabling operators to meet the Green Deal goals and make waste water collection, treatment and management fit for the decades to come.

New objectives to be delivered must consider the affordability of water services. This includes the long life-cycle of waste water collection and treatment assets and their inherent inflexibility for adaptation or upgrading.

The aim of this paper is to set our general expectations and point at areas to be covered by the impact assessment. Detailed positions or notes on specific topics will be delivered in due course.

Addressing the pollution of water resources in the context of the European Green Deal with its Zero Pollution Action Plan (ZPAP) is fundamental for the continued provision of safe and affordable drinking and waste water services, whose essential mission is to protect human health and the aquatic environment.

EurEau fully supports the zero pollution ambition and calls on the Commission to put water front and centre of the plan. Industry and agriculture have an important role to play in controlling pollution and rectifying environmental damage as much as possible at the source.

The action plan should propose concrete actions rather than focussing solely on establishing monitoring frameworks and promoting digital tools. 

The water sector strongly supports the Farm-to-Fork Strategy. If fully and ambitiously implemented, it will protect water resources now and for future generations. EurEau calls for stronger policy coordination with the EU’s water-related legislation, the greening of the CAP, the effective implementation of pesticide rules, the drastic reduction of nutrient losses, more support for organic farming and the responsible use of antimicrobials. Water operators stand ready to step up cooperation with farmers in this transition process.

PFAS is a large group of very persistent chemicals that tend to accumulate in the environment and in human and animal bodies. They therefore pose a serious threat to the environment and human health. The emission of this group of chemicals needs to be drastically reduced, using the principles of control-at-source and polluter-pays. An EU-level ban on all non-essential use of PFAS is therefore necessary.

Sewer networks are a vital part of the urban environment. They provide drainage, prevent flooding of property and protect the water environment around urban areas.

We recognise many opportunities to make urban environments more sustainable through the management of waste water flows and storm water. We also acknowledge the significant financial responsibilities that are associated with making changes to the network of collecting systems.

This document provides a short reaction to and additional thoughts on the Deloitte study into Extended Producer Responsibility, accompanied by complementary information on the water services sector.

EurEau largely supports the study’s outcome. The study builds a solid case in favour of mandatory control-at-source measures, complemented, where necessary, by other mitigation measures along the supply chain and financed through mandatory EPR schemes. The study also highlights the need to adjust the relevant EU legislation, conduct a solid cost-benefit analysis of all mitigation measures and set up an inclusive process to develop fair, proportionate and effective EPR schemes

Micropollutants can directly or indirectly enter the water cycle through many means. Once in the water cycle, they can pose a risk to drinking water resources and aquatic ecosystems.
Current technologies used in waste water treatment plants are not entirely capable of removing micropollutants. The most sustainable and preferred solution remains to prevent micropollutants – including microplastics - from entering the water cycle in the first place.
We call on the EU institutions to legislate according to the source control approach, the precautionary principle and the polluter pays principle. EurEau believes that the correct use of the source control approach is instrumental to achieve a truly circular economy.

Water and agriculture are intrinsically linked. It is therefore of the utmost importance that the new CAP protects the quality and quantity of water resources through an effective conditionality mechanism.
The European Commission’s CAP proposal contains a number of elements that could contribute to more sustainable agricultural practices. However, its provisions and requirements need strengthening in order to deliver tangible results.

As the pressure on water resources continues to grow due to climate change, more attention is being paid to alternative water sources. One viable alternative water source is urban waste water that has undergone necessary treatment to avoid health and environmental risks. To this end, the European Commission presented a regulation to define the minimum requirements Member States have to comply with in order to ensure the safety of water reuse practices across the European Union.

We welcome the legislative proposal which should contribute to increasing confidence in the reuse of treated waste water. However, we see major points to be improved on to make this regulation applicable and effective on the ground.

The European Parliament's vote on the Drinking Water Directive will affect how much consumers pay for their water bills. We want MEPs to vote to save consumers money. 

EurEau supports the proposal of the European Commission to reduce the environmental impact of single-use plastics (SUP). Producers must be held economically responsible for the substantial economic damage wet wipes cause to the waste water infrastructure.

We support the underlining philosophy of the Drinking Water Directive to ensure the protection of public health and we uphold the goals the European Commission intends to achieve with the new proposal. We believe that European citizens’ trust in tap water needs to be further increased.
However various elements of the European Commission’s proposed text will have to be improved by the co-legislators to make the directive legally sound and implementable in an efficient and effective way.

The Water Framework Directive (WFD) set out a journey to achieve ‘good status’ for water bodies by 2015. The implementation of the WFD has revealed some issues, especially concerning the way the status of a water body is defined and assessed at Member State level. This position paper aims at describing the shortcomings in the tools for status assessment and the role played by exemptions, with a focus on the implications for water services in Europe. It also suggests possible solutions that could be part of the future revision of the WFD in order to uphold the main goal of the directive: the protection of European water bodies even after 2027.

EurEau welcomes and supports the EU Strategy on Plastics. EurEau also fully supports REACH restrictions regarding microplastics in personal care and cosmetic products and detergents. 

The water services sector is particularly concerned about microplastics emissions in the (aquatic) environment. Microplastics 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. EurEau advocates for the polluter pays principle and control at source measures as well as extended producer responsibility to tackle this issue. 

Customers and 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. Achieving this will help ensure access to safe and sustainable water today and tomorrow.

Clean water is a prerequisite for ensuring environmental and public health and prosperity. To achieve this we need better EU policy coordination.

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.

Decreasing water consumption is an economic challenge for water and waste water operators, since most of their costs are fixed but their income is closely linked to consumption. Given that 60-80% of the costs are fixed, measures should guarantee that all fixed costs are recovered, for example by a better tariff structure.

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.

Glyphosate is routinely found in raw water resources across Europe. We support measures taken to control the concentrations of this chemical in surface waters and in urban run-off. It is vital that consumers across Europe have access to safe drinking water. We need access to clean water resources that are free from contaminants such as microplastics and micropollutants. This protects the environment, and consumers from additional costs.