Protection of groundwater against pollution and environmental quality standards in the field of water policy

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and Directive 2008/105/EC on environmental quality standards in the field of water policy Comments by the Swiss Centre for Applied Ecotoxicology (OZ) Authors: Carmen…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In principle, the BUND welcomes the proposals for stricter rules on air, surface and groundwater pollutants, also as an important step towards the zero-pollution ambition of the European Green Deal, i.e. a toxic-free environment by 2050. A. The following points are particularly worth supporting: A1.

Filed in German · English published by the European Commission

Pan Germany welcomes the opportunity to comment on the proposal for a Directive (2022/0344 (COD)) on amendments to the Water Framework Directive (WFD), the Groundwater Directive (GWD) and the Environmental Quality Standards (EQS) Directive.

Filed in German · English published by the European Commission

Suez considers that the European Commission has proposed an ambitious directive on integrated water management surface and groundwater. Protecting water is indeed critical for EU citizens and the environment. The new groundwater directive complements the revision of the Urban wastewater treatment directive. For SUEZ, there is clear alignment between these two topics.

In the context of the initiative on the public consultation carried out by the European Commission (EC) on Integrated Management of Water Resources Revised lists of surface and groundwater pollutants, AEPSA, Association of Portuguese Enterprises for the Environment Sector, is enclosing its comments and contributions.

Filed in Portuguese · English published by the European Commission

The VCI welcomes the opportunity to take position on the Commission proposal amending Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and Directive 2008/105/EC on environmental quality standards in the field of water policy.

Surfrider Foundation Europe welcomes the European Commissions initiative to open its proposal for a Directive amending the WFD, the GWD and the EQSD (2022/0344 (COD)) for feedback. The present proposal aims to update the lists of priority substances for surface and groundwater, along with their associated legal threshold values and their monitoring and reporting requirements.

At Teva Pharmaceuticals, our mission is to improve the lives of patients across the globe. In Europe, Teva is a strategic partner of healthcare systems, producing 96% of its European generic, biosimilar and innovative portfolio in plants across 15 European countries. As a company focused on improving the health of patients, the environment is very central to Teva, which is reflected in our commitments.

14 March 2023 Response to consultation on the revised list of surface pollutants under the Water Framework Directive (WFD) We consider it is a mistake to include silver in the PS list due to the reasoning of possible AMR development. The reason we say so is, the available data related to AMR is very much limited and the statement made in the Impact Assessment report is based on highly selective information.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

14 March 2023 Nickel Institute’s feedback on the revision of the Nickel Environmental Quality Standards The Nickel Institute1 (NI) welcomes the opportunity to provide feedback on the proposed revision of the Environmental Quality Standard (EQS) Directive and the freshwater nickel EQS. The NI does not support the revised EQS values proposed by the Commission and has the following remarks on process.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position Paper Koa Glass Co., Ltd. 1-25-27 Hirai, Edogawa-ku, Tokyo, Japan, 132-0035 14 March 2023 European Commission To whom it may concern, RE: The Inclusion of Silver in the Water Framework Directive (WFD)’s List of Priority Substances (PS) and Environmental Quality Standards (EQS) Directive We Koa Glass would like to submit our comments on the proposal to include silver in the WFD's PS list and EQS Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

STELLUNGNAHME Integrierte Wasserbewirtschaftung – überarbeitete Listen von Schadstoffen in Oberflächengewässern und im Grundwasser Vorschlag der EU-Kommission Zusammenfassung Die Europäische Kommission hat am 26.10.2022 einen Vorschlag zur Änderung der Richtlinie 2000/60/EG zur Schaffung eines Ordnungsrahmens für Maßnahmen der Gemeinschaft im Bereich der Wasserpolitik, der Richtlinie 2006/118/EG zum Schutz des…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to provide feedback on the recent Commission proposal to amend the Water Framework Directive, the Groundwater and the Environmental Quality Standards (EQS) Directives. We noted with great interest that the proposal assigns a central role to ECHA for scientific support in the identification of water pollutants and the derivation of EQS values in the future.

The proposed initiative to review the lists of surface and groundwater pollutants of the Directive 2000/60/EC identified pressing issues that need to be addressed. There were 23 new priority substances included in the proposal, including silver.

Thank you for the opportunity to comment on the Commission’s proposal to amend the Water Framework Directive (WFD) and its daughter directives. We welcome many of the proposals to update Directive 2008/105/EC (EQD) and Directive 2006/118/EC (CSD). We do not all consider the proposed amendments to the WFD to further protect against pollution to be useful. Please refer to the attached document for details.

Filed in German · English published by the European Commission

Medicines for Europe, representing generic, biosimilar and value-added medicines industries across Europe, the European Federation of Pharmaceutical Industries and Associations (EFPIA) and the Association of the European Self-Care Industry (AESGP) welcome the opportunity to submit feedback to the Commission Proposal on the Integrated water management i.e.

EARSC Statement Integrated water management – revised lists of surface and groundwater pollutants The European Association of Remote Sensing Companies (EARSC) is a trade association based in Brussels, representing the European downstream services sector. EARSC counts more than 135 members across 25 countries of Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The water management associations in North Rhine-Westphalia are public-law bodies which carry out their tasks in the provision of services of general interest on the basis of special legislation or as a water association in accordance with the Water Association Act.

Filed in German · English published by the European Commission

EARSC Statement Integrated water management – revised lists of surface and groundwater pollutants The European Association of Remote Sensing Companies (EARSC) is a trade association based in Brussels, representing the European downstream services sector. EARSC counts more than 135 members across 25 countries of Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Attached pdf summarises the EPMF comments on the recent EC proposal for amending the Water Framework Directive (WFD), the Environmental Quality Standard Directive (EQSD) and Groundwater Directive in the field of water policy.

NICOLE is the only European network combining industry, service providers and academics, formed in 1996 with an aim to bring together professionals involved in sustainable risk-based management of land and water in Europe www.nicole.org.

Feedback of the European Association of Hospital Pharmacists to the “Proposal for a Directive amending the Water Framework, the Groundwater, and the Environmental Quality Standards Directives” Protecting the environment with the highest environmental standards is essential but guaranteeing patients’ access to their therapies is paramount.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association of the European Self-Care Industry (AESGP) along with the European Federation of Pharmaceutical Industries and Associations (EFPIA) and Medicines for Europe (MfE) note positive aspects in the revision of the Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and the…

The Polycarbonate/Bisphenol A group of Plastics Europe represents the main producers of BPA and Polycarbonate in Europe. Bisphenol A (BPA) is used mainly as building block (monomer) to manufacture polymers, namely polycarbonate and epoxy resins. Polycarbonate plastic is the main use for BPA, accounting for about 70% of global BPA production.

The European Federation of Pharmaceutical Industries and Associations (EFPIA) along with the Association of the European Self-Care Industry (AESGP) and Medicines for Europe (MfE) note positive aspects in the revision of the Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and the…

The European Biocidal Silver Task Force (the EU STF) takes note of the Commission's proposal to include silver in the Water Framework Directive (WFD)'s list of priority substances. The EU STF considers that: (a) the significant costs associated with including silver in the list will far outweigh its benefits, rendering the proposal disproportionate; and (b) the proposal is unscientific and contains critical errors.

PAN Europe welcomes the opportunity to provide feedback on the Commissions proposal for the Directive amending the WFD, the GWD and the EQSD (2022/0344 (COD)) with the objective to increase the effectiveness of the legislation.

The EEB has contributed to the development of the proposal to add a range of crucial water pollutants including 24 PFAS, several pesticides and a number of pharmaceuticals to the lists of priority substances. An update that is several years overdue and which will require Member States to monitor these substances in water and make sure that environmental quality standards (EQS) are met.

Clariant, Global Product Stewardship, does not agree with the listing of a naturally occurring substance like silver to be a priority substance under the Water Framework Directive. Only substances found to pose a significant risk to or via the aquatic environment should be considered for inclusion on the priority substances list.

Environment Area Proposal for a Directive on integrated water management: observations and criticisms March 2023 Federchimica The National Federation of the Chemical Industry represents 1,450 companies for a total of over 94,000 employees; it is divided into 17 sector associations and 38 product groups and its primary objectives the coordination and protection of the role of the chemical industry operating in Italy…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Spanish Confederation of Employers’ Organisations (CEOE) and its member organisations and companies welcome the opportunity to comment on the European Commission’s proposal for a Directive amending Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on groundwater and Directive 2008/105/EC on the environment.

Filed in Spanish · English published by the European Commission

Water quality targets must be based on sound science as well as predictable and proportionate requirements to enable authorities and industry to practically measure and achieve outcomes protective of the environment.

please find attached the comments on the proposals prepared by the SCHEER and approved at their plenary meeting on 9th March 2023. I am submitting them as the current chair of the SCHEER and our comments are based on the scientific expertise in the SCHEER and the most recent mandates concerning EQS derivations.

BDI, Federation of German Industry, supports the intention to make the prioritization processes, the setting of quality standards and thresholds more transparent and efficient and to align them with other principles in order to make the best use of available expertise and data.

The Swedish municipalities and regions, SKR (sails), agree with the need for updated lists of pollutants to be monitored in surface and groundwater and the associated limit values. Existing designations need to be adapted to the current pollution picture and knowledge base, not least with regard to pollutants such as PFAS and pharmaceuticals.

Filed in Swedish · English published by the European Commission

Concawe feedback to the EC proposal “Integrated water management – revised lists of surface and groundwater pollutants” Concawe supports the process aiming at regularly reviewing the lists of priority substances and groundwater pollutants and appreciates the possibility to share its views on the proposal recently adopted by the EC in that context.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cefic takes note of the European Commission proposal to update the list of pollutants affecting surface and groundwaters and welcomes the changes to the watch lists mechanism and subsequent timeframe for implementation. Cefic does, however, call for better alignment with EU legislations, enhanced use of standard methodologies, and a better-framed role for ECHA.

Komentář Hospodářské komory České republiky k Návrhu SMĚRNICE EVROPSKÉHO PARLAMENTU A RADY, kterou se mění směrnice 2000/60/ES, kterou se stanoví rámec pro činnost Společenství v oblasti vodní politiky, směrnice 2006/118/ES o ochraně podzemních vod před znečištěním a zhoršováním stavu a směrnice 2008/105/ES o normách environmentální kvality v oblasti vodní politiky Hospodářská komora České republiky (HK ČR) se…

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Glyphosate Renewal Group (GRG) is a collection of companies seeking the renewal of the EU authorisation of the active substance glyphosate in 2023. To this end, the GRGs member companies join resources and efforts to prepare a single dossier with the scientific studies and information on the safety of glyphosate.

SSNC hereby submits its views on the Commission's proposal in an attached file. In summary: The Swedish Society for Nature Conservation (SSNC) welcomes the Commission's proposal to revise the Water Framework Directive (WFD), the Environmental Quality Standards Directive (EQSD) and the Groundwater directive (GWD).

CropLife Europe has been closely involved in the years-long stakeholder process to prepare the proposal, and accepts the approach followed for the majority of the pesticide quality standards that have been proposed. CropLife Europe supports the need to review the Directives to maintain consistency and alignment across water policy legislation.

Reaction to revised list of surfacewater pollutants, The new Directive is closely linked to the Water Framework Directive (WFD) and should contribute to the ambitions of the European Green Deal: The link with the Water Framework Directive (WFD) is essential. The WFD should remain the leading instrument in which water quality targets are set. 1. EQS contributes to improving chemical status of water quality.

The ERM Coalition of drinking water suppliers associations represent 170 water suppliers and 188 million drinking water consumers living in the river basins of Rhine and Ruhr, Danube, Elbe, Meuse and Scheldt depending on clean drinking water in 18 states including the 13 EU member states Austria, Belgium, Bulgaria, Croatia, Czechia, France, Germany, Hungary, Luxembourg, the Netherlands, Romania, Slovenia, Slovakia.

In the current draft, the three directives (WFD, GWD, EQS) are changed in one go, which contributes to the coherence between the directives. The directives are relevant to the drinking water supply insofar as they contain quality targets and monitoring obligations for groundwater and surface water.

Hazardous Waste Europe (HWE) welcomes the Commission proposals amending the WFD, EQSD and GWD. We specifically support the effort of harmonisation and coherence between the 3 texts. It should now continue with other related texts under revision and particularly the UWWTD, SSD, IED and IEPR.

VEWIN (Association of Dutch drinking water companies) Background and the import of protecting drinking water sources Medicine residues, pesticides and substances derived from industrial digeons (including PFAS) are a major risk to drinking water supply sources. Drinking water companies monitor how these substances are at their drinking water sources and include high monitoring and treatment costs.

Filed in Dutch · English published by the European Commission

We welcome the opportunity to provide comment on the Commission adoption of a proposal for amending Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and Directive 2008/105/EC on environmental quality standards in the field of water policy.

Any further changes in regulation have to serve the European Green Deal and to mainstream its key elements like the EU ‚Action Plan Towards a Zero Pollution Ambition for air, water and soil‘ and the ‚Chemicals Strategy for Sustainability‘ into all policy developments. Like this, also the lack of implementation and enforcement of the Water Framework Directive and its daughter directives can be overcome.

EEB, Europe's largest network of environmental citizens’ organisations, welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment for the revision of lists of pollutants affecting surface and groundwaters as a follow up to the fitness check evaluation of the EU water legislation.

Member of European Chemical Industry Council CEFIC Warszawa, 20.11.2020 PIPC/438/2020 Komisja Europejska DG ENV C.1 Clean Water Inicjatywa dotycząca zintegrowanej gospodarki wodnej – zmienione wykazy zanieczyszczeń wód powierzchniowych i podziemnych W związku z trwającymi konsultacjami społecznymi Komisji Europejskiej odnośnie inicjatywy dotyczącej zintegrowanej gospodarki wodnej – zmienionych wykazów zanieczyszczeń…

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to provide feedback on the Inception Impact Assessment and would like to share some recommendations on the way forward. The Non-ferrous metals industry is committed to continually improve its production performance to prevent, control, reduce and, as far as possible, eliminate its pollution to protect human health and the environment.

As a member, RIWA would like to bring the position of the Coalition of the European River Memorandum (ERM) regarding the fitness check of the Water Framework Directive and its daughter directives under attention, as well as the list of micropollutants in European River Basins found in exceedance of the target values of the ERM.

The Swedish mining and mineral industry operate under high environmental requirements and supplies metals and minerals to important value chains. Raw materials, and not least metals, are recognized as key to manage the technological transition to a climate neutral and sustainable society,” Access to resources is also a strategic security question for Europe’s ambition to deliver the Green Deal.

Inception impact assessment regarding revision of lists of pollutants affecting surface and groundwater (Ref. Ares (2020)5809213 – 23/10/2020) Feedback from Jernkontoret - The Swedish Steel Producers´ Association Contact: [name removed], Ph. D., Senior Advisor, Water, ecosystems, and sustainability. Mobile: [phone removed].

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Steel Association, EUROFER, welcomes the initiative taken by the EU Commission on the revision of lists of pollutants affecting surface and groundwater and thinks that this initiative represents a key opportunity to achieve the objectives of a zero-pollution ambition in the framework of the Green Deal.

Reaction to roadmap by the Association of Dutch Water Authorities and the Association of Dutch Water Companies (Vewin) 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 protecting human health and the environment.

A recently carried out suitability test (assessment) of the EU water legislation showed that these legal provisions are complete their purpose, according to the European Commission (COM) on its website ‘Integrated water management — revised lists of pollutants in surface water and groundwater’. The German Steel Federation (WV Stahl) supports this general assessment of the EU requirements in water law.

Filed in German · English published by the European Commission

European Commission DG Environment Clean Water Online Submission 20 November 2020 Indaver Ireland response to the European Commission Revised List of Pollutants affecting Surface and Groundwater Indaver Ireland is pleased to be afforded the opportunity to comment on this evaluation aimed at strengthening existing EU legislation for the protection of the environment and human health from the adverse effects of water…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This initiative addresses the findings on chemical pollution and the legal obligation to regularly review the lists of priority substances and groundwater pollutants which is regulated under the umbrella of the WFD and which will be further linked to the new Zero Pollution Action Plan.

Cefic supports the revision of lists of pollutants affecting surface and groundwaters based on new scientific developments and on a thorough data collection involving a proper consultation of relevant stakeholders. In this paper, Cefic would like to share its views on the above-mentioned initiative. Water Framework Directive and European legislative initiatives Cefic supports the EU Green Deal.

Nowadays, only 40% of Europe’s waters are in good ecological health. Climate change, and competing water uses closely linked to population growth and insufficient water treatment, have been some of the main challenges determining the current status of Europe’s freshwaters.

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.

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.