COMMISSION STAFF WORKING PAPER EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT
Date: 2012-01-31
Institutions: European Commission
Subjects: dangerous substance, environmental impact, environmental monitoring, water analysis, water pollutant, water treatment

EUROPEAN COMMISSION 

Brussels, 31.1.2012  
SEC(2011) 1546 final 

COMMISSION STAFF WORKING PAPER 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Directives 2000/60/EC and 2008/105/EC as regards priority substances in the 
field of water policy 

{COM(2011) 876 final} 
{SEC(2011) 1547 final} 

 
 
 
 
 
 
 
 
Disclaimer: This executive summary commits only the Commission's services involved in its 
preparation  and  does  not  prejudge  the  final  form  of  any  decision  to  be  taken  by  the 
Commission. 

EN 

2 

   EN 

 
1. 

PROBLEM  DEFINITION 

1.1. 

Background 

The Water Framework Directive 2000/60/EC (WFD) establishes a comprehensive framework 
for the protection of surface and groundwater, setting environmental objectives including the 
achievement of good chemical and ecological status and the prevention of deterioration..  To 
meet  good  chemical  status,  water  bodies  must  meet  the  Environmental  Quality  Standards 
(EQS) set for certain chemicals – the Priority Substances (PS) - identified under the WFD as 
posing a risk to or via the aquatic environment at EU level. Some PS are identified as Priority 
Hazardous Substances (PHS) because of their persistence, bioaccumulation and/or toxicity or 
equivalent  level  of  concern.  In  addition  to  the  objective  of  good  chemical  status,  the  WFD 
requires the adoption of control measures aimed at the progressive reduction of PS and at the 
cessation  or  phasing  out  of  discharges,  emissions  and  losses  of  PHS  to  the  aquatic 
environment.  Currently,  control  measures  are  taken  at  MS  level;  at  EU  level,  measures  are 
reliant on other legislation (such as REACH, plant protection products, biocides). The WFD 
also allows for exemption from meeting good chemical status in specific water bodies on the 
grounds of technical unfeasibility, disproportionate costs or natural conditions. 

The WFD (Article 16(4)) requires the Commission to review the list of PS at least every four 
years,  and  the  EQS  Directive  2008/105/EC  (EQSD)  (Article  8)  requires  the  Commission  to 
report the outcome of its first review to the European Parliament and the Council in 2011.  As 
part of the review, the Commission has to consider inter alia the substances in Annex III of 
the Directive for possible inclusion in the list.  It is also required to identify, if appropriate, 
new  PS  or  PHS,  and  to  set  EQS  for  surface  water,  sediment  or  biota  as  appropriate,  and  to 
review the existing PS. The proposed new substances and changes to existing substances are 
expected to have an impact in the 2015 updated RBMPs1 and programmes of measures. 

The  required    review  was  carried  out  with  the  assistance  of  the  Working  Group  E  on 
Chemical  Aspects  (WG  E)  under  the  WFD  Common  Implementation  Strategy2,  including 
participation of all MS and a wide range of stakeholders3. It was a scientific/technical exercise 
involving the identification of risks from chemicals to the aquatic environment and the setting 
of EQS for them. The methodology for setting the EQS, and the EQS derived, were submitted 
to  the  Scientific  Committee  on  Health  and  Environmental  Risks  (SCHER4)  for  its  opinion. 
The impact assessment takes as given the results of the scientific/technical work. 

In the course of reviewing the PS list, possible improvements in the functioning of the EQSD 
were identified, and a possible mechanism for improving the identification of additional PS in 
future  reviews,  and  these  are  included  as  separate  sets  of  options.  The  preferred  option  is 
therefore a package of options. 

1 
2 
3 

4 

EN 

River Basin Management Plans 
http://ec.europa.eu/environment/water/water-framework/objectives/pdf/strategy.pdf 
http://ec.europa.eu/transparency/regexpert/detailGroup.cfm?groupID=371, 
"Priority Substances". 
The SCHER is one of the Scientific Committees providing the Commission with independent advice. It 
is 
at 
http://ec.europa.eu/health/scientific_committees/environmental_risks/index_en.htm   

"Sub-groups", 

information 

scientists. 

under 

More 

made 

up 

17 

of 

3 

   EN 

 
 
                                                 
1.2.  What is the issue requiring action? 

Three main issues require action:  

(i) the availability of new information about risks caused by existing PS and new chemicals. 
New chemicals are being developed all the time, so not all will have been considered during 
the first prioritisation and for those that were, new information may have become available. 
(ii) the fact that some of the  most  harmful  chemicals already  on the  PS list  or  proposed  for 
addition5  are  ubiquitous  persistent,  bioaccumulative  and  toxic  (PBT)  substances.  The 
measures already taken on those have reduced emissions very significantly. However, because 
of  their  intrinsic  properties,  widespread  use  and  common  potential  for  long-range  transport, 
some of them are still found in the aquatic environment, mostly in sediment and/or biota, at 
concentrations above the EQS, therefore entailing widespread failures of the objective of good 
chemical status. Three sub-problems need to be considered, as follows: 
• 

Presentational  issue:  the  widespread  exceedances  of  the  EQS  by  ubiquitous  PBTs 
will  hide  the  improvements  made  in  relation  to  other  substances  because  the 
chemical status of water bodies under the WFD has to be reported on the basis of all 
the PS.  
Choice of monitoring matrix between water, sediment or biota: the EQSD currently 
allows MS to choose the matrix for each PS. PBTs tend to accumulate in sediment 
and/or  biota  and  may  be  hardly  detectable  in  water  even  with  state  of  the  art 
analytical  techniques.  MS  which  apply  a  water  EQS  might  inappropriately. 
categorise  water  bodies  as  having  "good  chemical  status"  even  when  the  sediment 
and/or biota contain PS at levels that still pose a risk. 
Reduced  monitoring effort  for ubiquitous PBTs: Any changes in the environmental 
concentrations of ubiquitous PBTs are likely to occur only over the long term and a 
lower monitoring frequency and lower number of monitoring sites than normal under 
the WFD would seem justified.   

• 

• 

(iii)  the  fact  that  there  is  a  paucity  of  fit-for-purpose  monitoring  data  on  which  to  base 
assessment of exposure and thus the prioritisation of new PS in future reviews. A very large 
monitoring  database  was  compiled  for  the  current  prioritisation,  but  more  could  be  done  to 
overcome  the  vicious  circle  that  unless  a  substance  is  already  regulated,  it  is  unlikely  to  be 
widely monitored, but that if it is not monitored and the environmental concentrations cannot 
be reliably modelled either, estimation of the risk posed at EU level may not be robust enough 
to justify regulation. 

2. 

ANALYSIS OF SUBSIDIARITY 

Water pollution has a very important transboundary character. 60% of the EU territory lies in 
shared  river  basins  (EC,  2007).  The  Union’s  policy  for  controlling  the  pollution  of  surface 
waters  is  set  out  in  Article  16  of  the  WFD  which,  together  with  Article  8  of  the  EQSD, 
provides the basis for the PS list and its review. The related issues addressed in the options 
concern the functioning of the legislation. 

3. 

OBJECTIVES 

5 

PBTs included in the PS list are by definition PHS. 

EN 

4 

   EN 

 
 
                                                 
The following table presents the general and specific objectives in relation to the problems, 
sub-problems and options: 

Problem 

Sub-problem  General objective 

Specific objectives 

Consider latest scientific knowledge  
Improve knowledge (of risks and 
effectiveness of measures taken to 
reduce or eliminate emissions) 
through monitoring  
Identify new substances that cause 
risks and set EQS for them 
Improve knowledge (as 
above)through monitoring  
Improve communication of progress 
in water quality within the WFD 
implementation 
Strengthen the current legislation on 
the choice of the most suitable matrix 
for monitoring 
Reduce the administrative costs for 
MS by providing additional flexibility 
in monitoring ubiquitous PBTs while 
maintaining the effectiveness of the 
monitoring   
Provide a mechanism to improve the 
knowledge base and make future 
identification of PS more effective 

New information 
on risks to 
environment and 
human health 

Existing 
substances 

Reduce the risks to or via the 
aquatic environment posed by 
certain substances 

Specific difficulties 
with ubiquitous 
PBTs 

Proposed 
substances 

Presentational 
issues 

Choice of 
matrix 

Monitoring 
effort 

Improve the functioning of the 
EQSD 

Knowledge base 

- 

Provide adequate tools to 
improve the future 
identification of substances of 
concern to or via the aquatic 
environment at EU level. 

4. 

POLICY OPTIONS 

4.1. 

Policy options in relation to the substances 

Options 

A2 

A3a-
A3c 

B2a-
B2b 

B3a-
B3b 

B4a-
B4b 

C2-C3 

The first set of policy options refers to the inclusion of substances in Annex X of the WFD, 
the (re)determination of their status (PS or PHS) and the revision or establishment of EU-wide 
EQS for them. The options are fully based on the outcome of the expert technical work. They 
are  cumulative  on  the  basis  of  theoretically  increasing  impacts,  with  pharmaceuticals  being 
included  last  because  they  have  not  hitherto  been  regulated  under  the  WFD.  Option  A1 
represents no change to the current list. 

Option 

Substance 

Option A2: Change EQS 
and/or status of existing PS 

Anthracene 
Poly-BDE 
DEHP 
Lead 
Naphthalene   
Nickel 
Polyaromatric hyrocarbons 
(PAHs) 
   Benzo(a)pyrene 
   Benzo(b)fluoranthene 
   Benzo(k)fluoranthene 
   Indeno(1,2,3-cd)pyrene 

Biota 
EQS 
proposed? 

N 
Y  
N 
N 
N 
N 

Y  

Change from 
PS or 
identified as 
PHS? 
N 
N 
Y 
N 
N 
N 

N 

Change or 
establishment 
of EQS in 
water?  
Y 
Y* 
N 
Y 
Y 
Y* 

Y* 
Y* 
Y* 
Y* 

EN 

5 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Option 

Substance 

Option A3a: Existing-PS 
changes plus (selected) Annex 
III substances 

Option A3b: Existing-PS 
changes plus (selected) Annex 
III substances plus other new 
substances excluding 
pharmaceuticals 

Option A3c: Existing-PS 
changes plus (selected) Annex 
III substances plus other new 
substances including 
pharmaceuticals 

   Benzo(g,h,i)perylene 
Fluoranthene 
Trifluralin 
Dicofol 
PFOS 
Quinoxyfen 
Dioxins and DL-PCBs 
Aclonifen 
Bifenox 
Cybutryne 
Cypermethrin 
Dichlorvos 
HBCDD 
Heptachlor/ heptachlor 
epoxide 
Terbutryn 
17 alpha-ethinylestradiol 
(EE2) 
17 beta-estradiol  (E2) 
Diclofenac 

Change or 
establishment 
of EQS in 
water?  
Y* 
Y* 
N 
Y 
Y 
Y 
N 
Y 
Y 
Y 
Y 
Y 
Y 
Y 

Y 
Y 

Y 
Y 

Biota 
EQS 
proposed? 

Change from 
PS or 
identified as 
PHS? 

N 
Y  
N 
Y 
Y 
N 
Y 
N 
N 
N 
N 
N 
Y 
Y 

N 
N 

N 
N 

N 
Y 
Y 
Y 
Y 
Y 
N 
N 
N 
N 
N 
Y 
Y 

N 
N 

N 
N 

For existing PS, Y* implies a change in EQS greater than one order of magnitude. Other EQS 
changes for existing PS (marked only Y) are minor. 

4.2. 

Policy options in relation to ubiquitous PBTs and the knowledge base 

The  three  sub-problems  associated  with  ubiquitous  PBTs  are  addressed  by  sub-options  B2a 
and  b,  B3a  and  b,  B4a  and  b.    These  sub-options,  the  substance  options  A2-A3c,  and  the 
knowledge-base  options  C2-C3,  are  independent.  Options  B3a  and  B3b  could  apply  to  any 
PS, not only ubiquitous PBTs. 

Option 
B1: No change  
B2a: Allow separate 
presentation of 
ubiquitous PBTs 
B2b: Take ubiquitous 
PBTs out of chemical 
status 
B3a: Choice of matrix 
linked to analytical 
sensitivity 

B3b: Fixedmatrix 

Description 
No change to current functioning of EQSD and WFD 
Allow MS to present the ubiquitous PBTs separately from the rest of the PS/PHS in 
their RBMP assessments, whilst still including them in the chemical and overall 
assessment. 
Take ubiquitous PBTs out of chemical status altogether, whilst maintaining the 
obligation to monitor and report trends. Good status could be met on the basis of 
satisfying the EQS for the other PS. 
MS would be able to choose the matrix except where the available analytical 
technique fulfils the performance criteria6 in one matrix and not in the other(s), or no 
analytical technique meets the performance criteria but the technique for one matrix 
performs significantly better than the others, and there is an EQS available at EU 
level for at least the ‘best performing’ matrix. 
The choice of matrix for monitoring and compliance checking would be fixed at EU 
level for each substance. 

6 

Commission Directive 2009/90/EC requires MS to use analytical techniques that meet certain minimum 
quality  requirements  in  relation  to  the  EQS.  In  the  absence  of  techniques  that  meet  such  minimum 
criteria, the best available techniques not entailing excessive costs should be used. 

EN 

6 

   EN 

 
 
 
                                                 
Option 
B4a: Conditional 
decrease inmonitoring 
for ubiquitous PBTs 
B4b: Unconditonal 
decrease in monitoring 
for ubiquitous PBTs 
C2: Knowledge base: 
watch list without legal 
obligation 

C3: Knowledge base:  
watch list with legal 
obligation 

Description 
Reduce monitoring obligations for ubiquitous PBTs if certain specified conditions are 
met: enough information on the presence of the substance in water bodies (in 
particular in sediment and/or biota), i.e. a robust monitoring baseline. 
Reduced monitoring requirements for ubiquitous PBTs would be specified in the 
EQSD without conditions. 

Establish a voluntary mechanism for monitoring substances posing a possible risk to 
or via the aquatic environment at EU level using a "dynamic" list (with substances 
being regularly added and removed) to ensure the provision of high-quality EU-wide 
monitoring data for the prioritisation process. Around 20 substances to be on the list 
at any one time, monitored by MS at 250-300 representative sites across the EU 
according to agreed technical guidelines.  
Establish a mechanism as in C2 but with a legal obligation for MS to monitor. 

5. 

ASSESSMENT OF IMPACTS 

5.1. 

Impacts of options related to the substances 

Option 

Positive impacts 

Negative impacts 

A2 

A3a 

A3b 

A3c 

Better and more robust knowledge of the 
extent of the risks, coherence with the 
latest scientific progress, allowing MS 
and other policies to take the necessary 
measures to reduce the risks caused by 
these substances. 
Improved protection of human health and 
aquatic biodiversity. 

Potential significant costs to upgrade some 
industrial and UWWTPs (for Nickel) to 
meet AA-EQS of 2 μg/l, depending on 
local conditions. (UK estimate of 
approximately €2 billion whole-life 
investment plus attendant additional 
running costs.). Lower costs if AA-EQS set 
to 4 μg/l. 

As above plus: Additional information 
about the risk posed by the additional 
substances and about the effectiveness of 
related measures.  
Valuable data and information for 
decision making in the context of the 
plant protection product, chemicals, 
industrial emissions and waste policy. 
Additional  protection  of  human  health 
and aquatic biodiversity. 
As above plus: Valuable data and 
information for decision making in the 
context of the biocides policy 
Additional  protection  of  human  health 
and aquatic biodiversity. 

As above plus: Improved information on 
the extent of pollution by 
pharmaceuticlas, and  EU-wide EQS as 
benchmarks for deciding possible 
measures at MS level.  
Additional  protection  of  human  health 
and aquatic biodiversity. 

Depending on local conditions, potential 
significant costs to upgrade some industrial 
and UWWTPs (for Nickel). 
Additional monitoring costs of 4-9.6 
million € per year for the whole EU. 
Substitution costs for Quinoxyfen, if not in 
baseline. 

Additional cumulative monitoring costs 
(over and above Option A2) of 12-28.8 
million € per year for the whole EU. 
In addition to non-monitoring costs of 
option A3a: potential costs of substitution 
(if necessary for Cybutryne and Terbutryn, 
possibly Cypermethrin in salmon farming). 
Additional cumulative monitoring costs 
(over and above Option A2) of 15-36 
million € per year for the whole EU.  
In addition to non-monitoring costs of 
option A3b:  
Possible costs of additional UWWTP 
upgrades to remove E2 if locally required 
and not sufficient from option A2 and to 
reduce E2 emissions from livestock to 
water. 

EN 

7 

   EN 

 
 
Monitoring costs are likely overestimated for the options that include more substances as, for 
example, sampling costs increase less steeply as the number of substances increases. 

5.2. 

Impacts of options related to ubiquitous PBTs and knowledge base 

Option  Positive impacts 

Negative impacts 

B2a 

B2b 

B3a  

B3b  

B4a 

B4b 

C2 

C3 

Easier demonstration by MS of reduced 
pollution by other PS despite failures for 
ubiquitous PBTs. Legal certainty maintained by 
no change in definition of chemical status. 
Very straightforward way of allowing MS to 
demonstrate progress in reducing pollution by 
other PS.  
Improved harmonisation of the assessment of 
chemical status; better picture of the extent of 
the problem. Flexibility to quickly adapt 
monitoring strategies to new analytical 
techniques.  
High level of harmonisation of the assessment 
of chemical status and a good picture of the 
extent of the problem. Legal clarity. 

Cost savings of 0.8 to 2.9 million € per annum 
in EU.  
Cost savings of 0.8 to 2.9 million € per annum 
in EU.  
Objective of fit-for-purpose EU-wide 
monitoring data to support prioritisation likely 
to be met at least partially. 

Legal obligation would make the outcome more 
certain to meet the objective (without it, MS 
would prioritise (other) legal obligations in their 
budgets). 

6. 

COMPARISON OF OPTIONS 

No significant negative impacts identified though 
there could be discrepancies between the 
approaches taken by different MS.  

Reduced environmental protection because there 
would be no EU EQS and no driver for taking 
measures. Legal uncertainty. 
Possible limited adaptation costs for some MS 
without experience in monitoring and analysis in 
certain matrices. Lack of legal clarity if there are 
no standardised analytical methods for certain 
substances. 
Possible adaptation costs for some MS without 
experience in monitoring and analysis in certain 
matrices. Impossible to adapt quickly to new 
analytical techniques. 
No significant negative impacts identified. 

Certain undesirable trends or hotspots could be 
overlooked. 
Monitoring costs: 2 to 4 million € per year for the 
EU. Costs to develop technical specifications for 
monitoring (less than 0.2 million € per year for the 
whole EU).  
As above for option  C2, plus minor additional 
administrative costs in the European Commission.. 

6.1. 

Comparison of the options related to the substances 

As regards effectiveness at achieving the objectives, the broadest option (A3c) takes greatest 
account  of  the  latest  scientific  information  included  in  the  review,significantly  improves 
knowledge of the risks posed by all the newly identified substances, , and optimises protection 
against  them.  No  additional  measures  are  proposed  at  EU  level.    Any  necessary  measures 
would most likely be taken at local level, although actions at EU level under other legislation 
could  in  due  course  be  prompted  if  the  monitoring  information  made  this  necessary.    The 
baseline  takes  account  of  existing  measures  and  expected  decisions  under  other  EU 
legislation. 
No  disproportionate  costs  at  EU  level  are  identified.  If  disproportioante  costs  were  incurred 
locally,  the  exemptions  under  the  WFD  could  be  used  for  particular  water  bodies  if  the 
conditions set out in the WFD are fulfilled. 

6.2. 

Comparison of the options related to ubiquitous PBTs and knowledge base 

Option  Effectiveness 

0 
B1 
Options on presentation 

EN 

Efficiency  

0 

8 

Consistency 

0 

Overall 
mark 
0 

   EN 

 
 
 
 
+++++ 

+ 

++++ 

B2a 

B2b 

++ 
Avoids presentational issue although 
formally chemical status would still 
be affected by the ubiquitous PBTs. 

++ 
No major costs involved and 
reduced administrative burden for 
MS. 

+ 
Avoids presentational issue 
completely but undermines the 
objective of reducing the risks posed 
by certain substances. 

++ 
No major costs involved and 
reduced administrative burden for 
MS. 

+ 
Coherent with WFD, 
providing more 
flexibility in terms of 
presentation  
-- 
Incoherent with WFD 
and chemicals policy. 

B3b 

Options on monitoring matrix 
B3a 

++ 
Strong driver for using the most 
appropriate matrix. Contributes to 
improved knowledge of the risks of 
substances and effectiveness of 
measures. Possible to take into 
account local situation. Possible lack 
of legal certainty if no international 
analytical standards. 
++ 
Strong driver for using the most 
appropriate matrix. Contributes to 
improved knowledge of the risks of 
substances and effectiveness of 
measures. Not possible to take into 
account local situations. Legal 
certainty. 
Options on reduced monitoring 
B4a 

+ 
Reduces administrative burden and 
monitoring costs for MS.  

B4b 

+ 
Reduces administrative burden and 
monitoring costs for MS.  

C2 

C3 

+ 
Increased knowledge but likely to 
suffer important data gaps 
(incomplete coverage of MS) and lack 
of adherence to technical 
specifications due to the voluntary 
character. 
++ 
Increased knowledge and likely to 
cover all or most of the EU countries 
in a harmonised way  

+ 
Retention of some flexibility 
would allow MS to adapt to local 
circumstances and 
tradition/experience.  Moderate 
adaptation costs for some MS. 

+ 
Reinforces the role of 
Directive 2009/90/EC. 
Contributes to 
improved assessment of 
effectiveness of 
measures taken by 
other policies. 

- 
Higher adaptation costs for MS 
that have no tradition/experience 
to monitor in biota. 

+ 

≈ 
Less flexible to adapt to 
progress in analytical 
techniques. Could 
hinder progress in 
analytical techniques 
for other matrices. 

+ 
Ensures that a robust monitoring 
baseline is available, hence 
contributing to good knowledge of 
the risks to or via the aquatic 
environment of ubiquitous PBTs. 
≈ 
Does not guarantee a robust 
monitoring baseline in all MS, 
therefore not ensuring a good 
knowledge of the risks to or via 
the aquatic environment of 
ubiquitous PBTs. 
+ 
Value for money decreased by the 
likelihood of data gaps. 

≈ 

≈ 

++ 

+ 

NA 

++ 

++ 
Provides targeted high-quality EU 
datasets, fit for purpose for PS 
prioritisation. 

NA 

++++ 

Magnitude  of  impact  as  compared  with  the  baseline  scenario  (the  baseline  is  indicated  as  0):  ++  strongly 
positive; + positive; – – strongly negative; – negative; ≈ marginal/neutral; NA not applicable 

6.3. 

Summary of preferred options and impacts 

The preferred options are: 
A3c - all substances; 
B2a - flexible presentation for ubiquitous PBTs; 
B3a - choice of matrix linked to analytical sensitivity; 

EN 

9 

   EN 

 
 
 
 
B4a - conditional reduced monitoring for ubiquitous PBTs; 
C3 - watch list with legal obligation. 

These would be implemented by amending the EQSD 2008/105/EC and WFD Annex X. The 
benefits,  costs  and  distributional  effects  relative  to  the  baseline  are  summarised  in  the 
following table, taking account of the interactions between the options. 

Benefits 

• 

• 

• 

• 

• 

• 

• 

• 

Costs 

• 

• 

• 

• 

All the latest scientific information reviewed would be taken into account; 

MS would be encouraged to monitor in biota when most appropriate; 

A more accurate picture would be obtained of pollution by ubiquitous PBTs; 

There would be a significant improvement in knowledge of the risks posed by all 15 of the prioritised substances 
and  the  ubiquitous  PBTs  among  the  existing  PS,  and  of  the  effectiveness  of  measures  for  these  substances, 
allowing  introduction/improvement  of  measures  at  EU  and  MS  level,  better  targeting  of  sediment  remediation, 
and optimisation of protection from identified risks - thus leading to benefits to biodiversity and human health; 

Measures applied to reduce the risks from some substances (e.g. Nickel) would be seen to reduce the risks from 
others (e.g. E2) as well; 

The  harmonisation  of  EQS  for  more  substances  would  provide  a  more  level  playing  field  for  businesses  in 
different MS; 

The  administrative  burden  associated  with  explaining  the  failure  of  the  chemical  status  objective  as  a  result  of 
ubiquitous PBTs would be reduced, and the public would receive clearer information; and 

Savings  on  monitoring  ubiquitous  PBTs  would  be  expected,  which  could  be  invested  in  improving  the 
information base for future prioritisation exercises, i.e. the watch list; 

Additional monitoring costs to public authorities; 

Costs to public authorities and private companies, likely passed to consumers, of additional UWWT to remove 
Nickel  and  E2,  costs  to  industry  to  reduce  point  source  industrial  emissions  of  Nickel,  and  costs  to  livestock 
farmers  to  install  fencing  to  keep  animals  away  from  water  courses  to  reduce  E2  emissions  to  water,  although 
some of those costs could fall under other legislation;  

The  possible  costs,  unknown  but  not  likely  to  be  significant,  of  substituting  Quinoxyfen,  if  authorisation  not 
anyway withdrawn under the plant protection products legislation; these could fall on the producers, formulators, 
farmers and/or consumers depending upon the substitute; 

Costs to operate the watch-list. 

Main distributional effects 

The most significant distributional effects are summarised here, except generic environmental and health benefits. Most relate 
to the preferred substance option (A3c) rather than the options addressing the other general objectives. There is uncertainty 
about how many would be in the baseline. 
Sectoral effects 

• 

• 

EN 

could  occur  in  agriculture  and  plant  protection  products,  due  to  the  inclusion  of  four  currently  used  plant 
protection  products  in  the  preferred  package;    however,  most  of  the  measures  that  might  be  needed  would  be 
expected in the baseline; 

could also occur in the water industry, resulting from the need to meet a more stringent EQS for Nickel, and an 

10 

   EN 

 
 
 
EQS for E2; 

• 

• 

would occur in the public sector as a result of having to monitor additional substances, and possibly also to cover 
investiments in UWWTPs (a cost that would likely be passed on to consumers); 

could occur in other sectors such as aquaculture, construction the metals industry, transport and waste handling, 
but would not be expected to be significant. 

Producer and user-specific effects 

• 

• 

could arise for the producers and formulators of the pestidices and biocides, again depending upon the baseline; 

could  affect  the  export  of  certain  substances  still  produced  in  the  EU  for  export,  including  HBCDD  and 
Trifluralin, although this export could stop anyway under the baseline. 

MS and region-specific effects 

• 

• 

• 

could include minor effects on trade in relation to exported and imported substances, but these would be largely 
in the baseline; 

could  occur  in  relation  to  plant  protection  products,  since  some  MS  use  more  and  have  a  larger  number  of 
products on the market; 

could include effects relating to relative pharmaceutical consumption, extent of coastline, prevalence and density 
of urban conurbations, intensity of livestock farming, and natural conditions affecting bioavailability 

Overall, the preferred options would achieve the most objectives with the greatest efficiency 
while  ensuring  coherence  with  the  existing  legislation  and  avoiding  significant  unfair 
distributional effects. 

7. 

MONITORING AND EVALUATION 

The WFD contains built-in monitoring and evaluation processes.  Regular monitoring of the 
environmental concentrations of the PS and PHS is foreseen in the Directive.  

EN 

11 

   EN