Resources - Position papers

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).

Small agglomerations have been identified as a source of pollution in the evaluation of the Urban Waste Water Treatment Directive (UWWTD). Despite that small agglomerations need to be better defined in the UWWTD, this source of pollution needs to be robustly addressed for the protection of biodiversity, ecosystems and for the protection of drinking water resources.

EurEau would like to see more guidance on monitoring and control of small or even individual systems at EU level through a thorough assessment and planning for the registration and monitoring of individual sanitation systems included in River Basin Management Plans. These elements should also be easily accessible to the local drinking water operators so that they can include them in the risk assessment and risk management of the catchment area as required in the recently recast Drinking Water Directive.

This paper explains the technical and practical implications for Urban Waste Water Treatment Plants (UWWTP) regarding the legal problems triggered by the Weser Ruling. It suggests possible solutions to look forward.

Statement on the Climate Action Technical Screening Criteria

The European waste water sector can make a big contribution to reaching climate neutrality objective by reducing Greenhouse Gas emissions and energy consumption. The revision of the Urban Waste Water Treatment Directive can create momentum to build a legal framework to address climate mitigation and the impact of waste water treatment plants. This paper presents how a tailor-made approach could generate the most optimal results.

The current directive is just being implemented, and so there is little or no experience as to how it functions in practice. Instead of revising, should the Commission focus on its effective implementation.

If the European legislators decide to proceed with the revision, they should focus on the further development of a coherent and streamlined regulatory framework for the security of network and information systems, without imposing additional and excessive burdens on industry.

At the same time, any duplication of legislation and inconsistencies with existing sector-specific and digital EU law should be avoided. The revision of the Directive should lead to a further strengthening of the preventive approach. This includes all aspects of detection and recovery by providing more and more detailed information on risks and incidents in the Member States, from national competent authorities to operators of essential services.

In the framework of new Commission policy work to protect public health and the environment, certain sectors, and in particular the chemical industry, are promoting a new ‘Innovation Principle’ next to the Precautionary Principle.

EurEau strongly supports innovation in our sector. However, we do not agree that the approach of BREFs as defined under the Industrial Emissions Directive (IED) suits the context of the UWWTD. Innovation and affordability of water services are best supported by an UWWTD which establishes output requirements with clear indications of enhanced performance requirements to achieve specific protection of the environment and public health, rather than prescribed instruments.

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.

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.

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.