ZeroPM removal workshop: Pollution prevention as a pre-requisite for circular water management
Abstract
ZeroPM removal workshop day 2 presentation 7
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Pollution prevention as a pre-requisite for circular water management ZeroPM workshop, 8 October 2025
Who are we? The EEB is Europe’s largest network of environmental citizens' organisations – and the only one to work on such a broad range of issues. Our work areas Climate Economic Transition Environmental Law and Justice European Institutions and Governance Global and Regional Policies Health and Environment Nature Circular Economy Our over 190 members from 41 countries have more than 30 million individual supporters. We have 50 years of EU environmental policy expertise.
EU water quality: state of play In the year 2000 EU Member States adopted the Water Framework Directive and agreed to bring Europe’s waters to ‘good status’ by 2015. A quarter of a century later, they’re far from delivering on their legal obligations: • 29% of surface water bodies in good chemical status • 77% groundwater bodies in good chemical status References: EEA Report No 7/2024 Europe's state of water 2024
What is chemical status ? Chemical status under the WFD is assessed against a small and outdated list of pollutants and their associated quality standards, largely overlooks the effects of chemical cocktails. On 23 September, the EU institutions agreed on an update of the lists of priority water pollutants, adding more pesticides, a group of PFAS, and – for the first time – pharmaceuticals. Timeline 2026 – expected formal adoption 2027 – monitoring program 2030 – preliminary programme of measures 2033 – final program of measures 2039 – compliance with new EQS 2045 – possibility to delay compliance to this date Surface water (last updated in 2013) Annex X WFD, Annex I EQSD • 45 priority substances Groundwater (last updated in 2014) Annex 1 Groundwater Directive • Nitrates • Pesticides (individual and total generic threshold) Annex II Groundwater Directive • National thresholds
Consequences Assessment of reported PFOS biota monitoring data from seven EU Member States, comparison to current and proposed new EQS •Current PFOS EQS (9,1 µg/kg ww): Exceeded in 20-40% of cases in Sweden, Austria, France, Spain, and Germany; •Soon to be adopted new PFAS EQS (77 ng/kg ww, PFOA equivalents): More than 15% of samples in Sweden, France, Austria and Spain exceeded the proposed new EQS by 500 times or more. Results are conservative as only one PFAS assessed.
Industrial Emissions Directive Water Reuse Regulation Sludge Directive Urban Wastewater Treatment Directive Drinking Water Directive Foodstuff regulation REACH, CLP Water Framework Directive UWWTP Bathing Water Directive Environmental Quality Standards Directive Groundwater Directive
Regulatory action Recast Drinking Water Directive (adopted 2020) • Limits for ‘total PFAS and ‘sum of 20 PFAS’ Revised Industrial Emissions Directive (adopted 2024) • Tightened provisions on industrial discharges to sewers • Requirements to protect soil and groundwater extended to also include surface water and drinking water catchments Recast Urban Wastewater Treatment Directive (adopted 2024) • Micropollutant removal at selected UWWTPs by 2045 (with interim deadlines) • Producers and importers to cover 80% of micropollutant removal costs Amended WFD, Groundwater Directive, Environmental Quality Standards Directive (soon to be adopted) • Surface water: 4.4 ng/L for sum of 25 PFAS, expressed as PFOA equivalents • Groundwater: DWD ‘sum of PFAS’ = 100 ng/L for 20 PFAS
Reality check Authorities continue to grant lax permits. One recent example: • The Province of Limburg (NL) has granted the industrial wastewater treatment company CFS in Weert a permit to discharge 5 kg PFAS/year to the sewer system • The UWWTP cannot remove it -> discharged to the Meuse river • The Meuse supplies around 7 million people in Belgium and the Netherlands with drinking water • Permit contested by drinking water suppliers and civil society EEB members regularly challenge permits in court
New threat: deregulation New simplification agenda of the Commission Environmental protections risks being wiped out without impact assessment via multiple so-called omnibuses The environmental omnibus is expected before the end of the year, consultation for food & feed omnibus ongoing Almost 200,000 people responded to env omnibus consultation, urging the European Commission to prevent any rollback of EU environmental laws under the guise of ‘simplification’. Several industry actors lobby to see WFD included and weaken its scientifically backed objectives.