EurEau

EurEau welcomes the Commissions initiative to develop a Circular Economy Act. Water services are central hubs for recovering nutrients, energy, materials and water. With clear EUwide criteria, market demand and safeguards against contamination, water services can scale safe resource recovery and strengthen Europes competitiveness, resilience and climate goals.

EurEau represents Europe's water services sector, bringing together 70,000 public and private drinking water and wastewater service providers across 33 countries. The sector serving more than 550 million citizens and businesses faces a substantial investment gap, estimated at several hundreds of billions of euros across the EU. Public procurement is key for water service operators to bridge this gap.

EurEau welcomes the Proposal for a revised Renewable Energy Directive (RED III) but regrets it doesn’t specifically address the water sector, despite its contribution to the renewable energy targets and climate policies: generation of electricity from hydraulic turbines and from on-site wind mills/solar panels, biogas from sewage sludge, electricity and thermal energy from sewage sludge mono-incineration, heat pumps…

EurEau is the European federation of water services and represents drinking water (DW) and waste water (WW) operators from 29 countries. We support the EU’s Green Deal, including its climate ambitions and Strategies. We call for full coherence between the RED, other energy legislation (EED), and sectoral legislation (DW Directive, Urban WW Treatment Directive).

EurEau represents Europes drinking water (DW) and wastewater (WW) sector. It encompasses 38 national water services associations from 33 countries. With regard to the foreseen evaluation of the public procurement directives, EurEau requests to consider the following observations. - Improve efficient use of public funds.

EurEau, the European Federation of National Associations of Water Services, welcomes the opportunity to share its views, concerns and suggestions on the water related activities included in the Taxonomy Environmental and Climate Delegated Regulations.

EurEau, the European Federation of National Associations of Water Services, welcomes the opportunity to share its views, concerns and suggestions on the water related activities included in the Taxonomy Environmental and Climate Delegated Regulations.

EurEau wishes to comment on this initiative as follows: Political context: The inclusion of resilience and security in the analysis of the criticality of raw materials is welcome. We strongly believe that public health protection should be added. All sectors covered by the forthcoming Critical Entities Resilience Directive, including drinking water and waste water services, should be covered by the Act.

EurEau welcomes the European Commission intention to evaluate and revise the pharmaceuticals legislative framework, as anticipated in the Pharmaceuticals Strategy, and in particular the resolve to address environmental issues and AMR. Pharmaceutical residues represent one of the many examples of contaminants of emerging concern that can directly or indirectly enter the water cycle through many pathways.

Climate change will directly and significantly affect water service operators in most parts of Europe, resulting in more frequent or intense periods of drought, heat waves or rain storms, and in more places. Our sector’s response to climate change should encompass both mitigation (reducing the impact of water services) and adaptation (become resilient to its effects) measures.

The European Commission is looking at revising the Waste Framework Directive in order to improve recycling and reuse of wastes and products and to specifically address oil wastes. EurEau, the European Federation of Water Services, represents waste water services providers who can recover a lot of materials from urban waste water treatment streams.

EurEau welcomes the Proposal for a Directive on energy efficiency (recast) (EED) and supports the role of circular economy and the life cycle approach. Water operators are moving towards energy neutrality, combining high energy efficiency and generation of renewable energy.

EurEau is the European federation of water services and represents drinking water (DW) and waste water (WW) operators from 29 countries. We support the EU’s Green Deal, including its climate targets and Strategies. We call for full coherence between the EED, other energy legislation (RED), and sectoral legislation (Drinking Water Directive - DWD, Urban Waste Water Treatment Directive - UWWTD).

EurEau welcomes the introduction of new hazard classes in the Classification, Labelling and Packaging (CLP) proposal for a regulation 2022/0432. The classification of substances according to these classes in the CLP regulation is essential to further restrict the use of hazardous chemical substances via REACH.

EurEau welcomes the introduction of new hazard classes in the Classification, Labelling and Packaging (CLP) proposal for a regulation 2022/0432. The classification of substances according to these classes in the CLP regulation is essential to further restrict the use of hazardous chemical substances via REACH.

EurEau is the European association of water service providers with 34 national member organisations in 29 countries. ~ The zero-pollution ambition from the European Green Deal delivered the Chemicals Strategy for Sustainability. One of its objectives is to better protect the environment against hazardous chemicals.

EurEau welcomes the Commissions intention to present a Biotech Act II creating lead markets for industrial biotechnology and bio-based materials, while also ensuring sustainable biomass supply across the value chain. Water services have the potential to roll out large-scale resource recovery of biobased nutrients and materials, energy and water.

EurEau, the European Association of Water Services, welcomes the opportunity to share its views, concerns and suggestions on proposed amendments to the Climate Delegated Regulation to the Taxonomy Regulation, particularly to those addressing water related activities.

The SUPD is an important tool to reduce plastic pollution and stimulate the circular economy. The results so far are partially positive but further strengthening is necessary. Inappropriate disposal (through the toilet) of SUP, such as wet wipes, sanitary towels and other sanitary care products, is a societal challenge. Wastewater systems may act as a pathway for plastics to enter the water environment.

Drinking water and waste water services have an essential mission: the protection of human health and the environment, so EurEau welcomes the opportunity to share its views on the inception impact assessment of the EU restoration targets. We welcome the fact that the initiative is based on the art.191 TFEU.

EurEau represents both drinking water and waste water service national associations from 29 countries in Europe. Protection of drinking water resources is one of our key concerns and the Industrial Emission Directive should be a key contributor to it.

EurEau represents Europes water services sector, bringing together 70,000 public and private drinking water and wastewater service providers across 33 countries. EurEau supports the simplification of administrative burdens in environmental legislation but stresses that simplification must not go to the detriment of water resilience.

EurEau is the European association of water service providers with 34 national member organisations in 29 countries. ~ Drinking water suppliers have been raising concerns about persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM) substances as they can still be detected decades after their withdrawal from the market.

EurEau, the European Federation of Water Service Providers, welcomes the European Climate Resilience and Risk Management Initiative and its call for evidence and, in particular, celebrates its main objective: to establish a more ambitious, comprehensive and coherent EU approach to climate resilience and preparedness. The European Climate Adaptation Strategy was adopted only a few years ago, in 2021.

EurEau wishes to comment as follows: - The provisions of Article 192.2 (TFEU) must be respected. - The lack of harmonised test methods should not delay action, as there is ample evidence of microplastics in all environmental compartments. - The EU has so far failed to tackle MP at source. The legal acts, this initiative wants to link with, are ‘end-of-pipe’ directives (UWWTD, SSD, GWD, EQSD).

The wastewater services sector currently produces biogas that can be upgraded into biomethane. In some Member States biogas is mostly upgraded to biomethane for injection into the gas network. There is significant potential, and more recently growing necessity, to ramp up the volume of biomethane and biogas produced by wastewater service providers.

EurEau welcomes the European Commissions Proposal for a Directive concerning urban wastewater treatment (recast), herein after called the Proposal. Directive 91/271/EEC on urban waste water treatment (UWWTD) has succeeded in reducing environmental pollution from waste water and in enhancing the ecological and chemical status of the European water bodies.

EurEau is the European federation of water services and represents nearly all the waste water operators in Europe. Our members deliver waste water services to citizens across Europe. A revised UWWTD will set the context for waste water services for the next generation. Therefore we highlight key points that the impact assessment (IA) must address.

EurEau would like to share its feedback to the draft act for a Directive to amend Annex III of the Nitrates Directive. In the attached document you can find our concerns regarding the Commissions draft act to amend Annex III of the Nitrates Directive and its potential impact on water resources, in particular those used for abstraction of water intended for human consumption.

EurEau welcomes the review of the NIS Directive and appreciates the possibility to input the process though the feedback to the Roadmap. Since the NIS Directive transposition period ended in May 2018, EurEau members think it is challenging to assess the provisions and how they have worked in practice so far. Concerning the options outlined in the roadmap, EurEau members have a preference for Option 2.

EurEau represents Europe's water sector, bringing together 70,000 public and private drinking water and wastewater service providers across 33 countries. The Commission has sealed an overall ambitious policy direction in its Call for evidence on the future water sector digitalisation action plan.

This contribution addresses the evaluation of the BPR from the perspective of water service operators and environmental protection, drawing on operational experience in drinking water supply and wastewater treatment and monitoring of impacts on aquatic ecosystems.

EurEau welcomes this initiative. The revision should be used to steer textile consumption patterns in a more sustainable direction by increasing transparency on environmental impacts and, hence, make sustainable practices more visible. Textile life cycles strongly affect the quality and quantity of water resources.

Wastewater treatment plants recover essential nutrients (nitrogen, phosphorus, organic matter) that can replace imported mineral fertilisers and support the EUs circular economy, food security, and climate goals. However, the current FPR framework still limits market access for many safe and effective recovered products.

EurEau represents Europe's water services sector, bringing together 70,000 public and private drinking water and wastewater service providers across 33 countries. We take note of the provisions in the draft Commission Regulation on ecodesign requirements for water heaters and tanks, in particular Recital 12.

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.

EurEau is the European Federation of National Associations of Water Services and is therefore very much involved in environmental topics and welcomes the holistic nutrient management approach proposed by the European Commission in order to address the nitrogen and phosphorus cycles.

The Regulation on Mercury, implementing the Minamata Convention, and addressing also dental amalgam, should be seen in the light of the EU Green Deal and its relevant Strategies such as the Zero Pollution Action Plan for a non-toxic environment and the new action plan on the circular economy.

EurEau represents Europe's water services sector, bringing together 70,000 public and private drinking water and wastewater service providers across 33 countries. We take note of the provisions in the draft Commission Regulation on ecodesign requirements for space and combination heaters, in particular Recital 14.

EurEau welcomes the opportunity to share its feedback to the roadmap on the proposal for measures to enhance the protection and resilience of critical infrastructure and welcomes the intention of the Commission to carry out an impact assessment on all the options under consideration. EurEau’s members have a preference for Option 2.

EurEau represents both drinking water and waste water service providers from 29 countries in Europe. The protection of drinking water resources is one of our major concerns and the E-PRTR should be a key contributor to it. We support the revision of the E-PRTR to better empower EU citizens with environmental data.

Water infrastructure, including both public drinking water distribution networks and waste water collection and treatment networks are usually local or, at the most, regional. Cross-border connections between these networks would be the extreme exception. Hence, the definition of ECI as infrastructures covering at least two Member States would not be applicable to the water sector.