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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.

Critical raw materials are key to the green and digital transitions as well as to other EU priorities such as EU resilience and security. They are essential components of green technologies, are used in digital applications, and are crucial to the defence, aerospace and health industries. To secure a sustainable supply, the European Commission has had in place a dedicated strategy since 2008 and put forward an action plan in the 2020 Communication on Critical Raw Materials. Although the action plan is on track, the current context of growing global demand and increasing geopolitical instability creates the need for increased efforts.

EurEau welcomes this Guidance document on the impact of water treatment processes on residues of active substances, enshrining the European Commission’s efforts to protect human health and the environment. The document outlines which environmental water residues have to be assessed, the identification of water treatment transformation products that are formed, and how to complete a risk assessment that includes the consumption of treated drinking water.

EurEau supports major parts of the proposed Regulation, but calls for more clarity regarding ‘off-site transfer’ management. Easy access to data is paramount to facilitate the risk management of waste water operators.

Waste water treatment plants (WWTP) larger than 100,000 PE are covered by the Regulation as it was for the E-PRTR and the list of pollutants did not change. Some provisions are added regarding diffuse pollution, which is positive, but more details are needed in order for the Regulation to be correctly applied.

EurEau welcomes the introduction of new hazard classes in the CLP regulation (ED, PBT, vPvB, PMT and vPvM). The criteria for Mobility does not follow the UBA scientific opinion and we ask for more ambitious criteria on Mobility.

The CLP Regulation ensures that the hazards presented by chemicals are clearly communicated to workers and consumers in the European Union through classification and labelling of chemicals. 

The purpose of this survey is to collect proposals to adapt the annexes of the Fertilising ProductsThe purpose of this survey is to collect proposals to adapt the annexes of the Fertilising ProductsRegulation (EU) 2019/1009 (‘FPR’) to technical progress. In accordance with Article 42 FPR, the Commission is empowered to adopt delegated acts.

You can read our table on the potential future of the CMC

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We welcome the legislative proposal of the Regulation on the Sustainable Use of Plant Protection Products (SUR), enshrining the European Commission’s Zero Pollution ambition in pesticides policy to protect human health and the environment. 

This legislative proposal heralds good news for water operators: water suppliers need water resources that are protected from pollution so that tap water remains safe and affordable, and the right to water is not jeopardised.

While the legislative proposal represents a major step in the right direction, we urge the European Parliament and the Council of the EU to embrace the change and support a European food system that protects water resources.

We regret, however, that Regulation (EC) No 1107/2009 on placing pesticides on the EU market will not be revised, since this legislation is key to restricting harmful pesticides. It must be ensured that only those substances that have no detrimental effects on human health, the environment, and more specifically, drinking water production, are allowed for use. This is not the case today. Furthermore, more attention should be paid to the possible combination effects of substances and regrettable substitutions of substances.

The proposed text meets most of the water service providers’ expectations by correcting some drawbacks of the current directive regarding the protection of water bodies. EurEau supports the general philosophy, aligned with the zero-pollution ambition, to control industrial pollution at the source. Overall, we find the Commission’s proposal goes in a very positive direction and we look forward to working with the EU institutions to make the IED an effective and robust force in protecting the environment, human health, water resources and water services’ workers.

Nutrients are chemical compounds that are essential for life. The most common nutrients include nitrogen (N) and phosphorus (P). Nutrients are found in soil, air and water, in agricultural fertilisers, in the food we consume and throw away as well as the sewage we produce. Human activities have significantly altered the natural processes which continuously cycle nitrogen and phosphorous in various (chemical) forms between different compartments of the environment. We consequently observe nutrient pollution that significantly affects public health, climate and the environment and at levels that exceed safe planetary boundaries. Nutrient pollution also has important economic consequences and puts at risk the sustainability of agriculture and fisheries in the EU.