EUREAU initial position paper on amending Directives 2000/60/EC and 2008/105/EC as regards priority substances in the field of water policy
- EUREAU welcomes the proposal of the European Commission COM(2011) 876 final1 regarding priority substances in the field of water policy. EUREAU and its members however emphasize that for the reduction of these substances in surface water and drinking water resources, the focus should be put on source control and strict control on the authorization and use of these substances.
- EUREAU supports the list of priority substances available in the Commission’s proposal for the amendment of Directives 2000/60/EC2 and 2008/105/EC3
- EUREAU has significant concerns about the balance between the lack of data on the water environmental impact of these new substances and the potential high costs, increase of energy use and chemicals if these molecules were to be eliminated from waste water.
- EUREAU suggests not to apply EQS for pharmaceuticals at this early stage but to provide for a legal requirement for Member States to monitor these substances and develop an action program including cost-effective measures to reduce emissions and to report in the next River Basin Management Plan.
- EUREAU proposes a logical hierarchy for possible actions in order to reduce emissions at the source.
- EUREAU regrets that the list still does not provide any EQS for substances at a level relevant for drinking water resources. With regards to substances like atrazine, simazine, tri-chloroethylene and tetra-chloroethylene there is a discrepancy between the requirements of the “Priority Substances List” and the provisions of the Drinking Water Directive (98/83/EC)4.