EurEau welcomes the EU’s Chemicals Strategy for Sustainability including its toxic-free hierarchy, as published by the European Commission today. If fully implemented, this strategy will support our move towards zero pollution and circular societies. 

Control at source measures must have priority

In line with article 191.2 of the TFEU, any sustainable chemicals strategy must start from rigorous control-at-source measures and fully apply the Precautionary Principle.

For this reason, EurEau supports the extension of the generic risk management (GRA) for all chemical substances so that they are regulated according to the intrinsic hazards they pose.

Hazardous chemicals arrive in our surface and underground water resources through multiple pathways. Some compounds can still be detected decades after their withdrawal from the market and require expensive extra treatment by drinking water suppliers.

Furthermore, removing hazardous chemicals after their use phase, for example at waste water treatment plants, is neither effective nor sustainable. In particular, this applies to pharmaceuticals, endocrine disruptors and PFAS.

Combination effects must be determined

EurEau supports efforts to determine and regulate the combination effects of priority chemicals and to include this in the authorisation process of chemicals. Close coordination between chemicals legislation and the Water Framework Directive is necessary so that the objectives of the latter are mainstreamed in all sectoral policies regulating chemicals.

PMT/vPvM substances must be regulated

EurEau calls for the swift definition of persistent, mobile and toxic, and very persistent and very mobile substances as categories of substances of very high concern under REACH. Their intrinsic properties pose serious long-term risks for drinking water resources while waste water treatment plants cannot remove them completely.

PFAS pollution requires group restriction

The rapidly increasing number of PFAS on the market requires a group approach to avoid the long-term pollution of our aquatic environment. Water suppliers will have to invest in very expensive and energy-intensive treatment methods to meet the strict PFAS parametric values stipulated in the new Drinking Water Directive if increased levels of PFAS are found in our drinking water sources. With this in mind, EurEau supports the PFAS Action Plan which should lead to the phase out of all non-essential uses once these are defined, in line with Member States and the European Parliament demands.

We welcome the initiative of the Commission and the competent authorities to develop a common definition of non-essential uses according to the Montreal Protocol.

Our paper on PFAS in the urban water cycle.

Briefing note on PFAS and drinking water.

Briefing note on moving forward on PMT and vPvM substances.