Water legislation.
Date: 2015-05-21
Institutions: Directorate-General for Parliamentary Research Services
Subjects: directive (EU), environmental law, environmental policy, environmental protection, legislation, quality of the environment, report, water management, water pollution, water protection

Water  
Legislation 
Cost of Non-Europe 
Report 

STUDY 

EPRS | European Parliamentary Research Service 
Author: Thomas Zandstra 
European Added Value Unit 
PE 536.369 - May 2015 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Cost of Non-Europe  
in Water Legislation 

On  21  March  2014,  the  Coordinators  of  the  Committee  on  Environment,  Public  Health  and 
Food  Safety  (ENVI)  asked  for  an  evaluation  to  be  made  of  the  application  and 
implementation  of  current  EU  legislation  on  water  and  for  an  assessment  of  possible  gains 
from future action in this area.  

This  paper  has  been  drawn  up  by  the  European  Added  Value  Unit  of  the  Directorate  for 
Impact  Assessment  and  European  Added  Value,  within  the  European  Parliament’s 
Directorate-General  for  Parliamentary  Research  Services.  Its  aim  is  to  help  improve 
understanding of the subject matter by providing evidence of the specific benefits that could 
be achieved through European action.  

This  assessment  builds  on  expert  research  commissioned  specifically  for  the  purpose  and 
provided by Triple E consulting- Energy, Environment & Economics B.V.  

Abstract 

This ‘Cost of Non-Europe’ study examines the state of implementation of current EU Water 
Legislation and identifies the cost of the lack of further European action in this field.  

legislation  confirms 

The  assessment  made  of  existing  water 
there  are  still 
implementation  gaps  and  areas  of  poor  performance.  The  subsequent  examination  of  five 
case  studies,  where  it  was  believed  that  a  significant  potential  exists  for  further  EU  action, 
served  to  demonstrate  that  there  are  several  barriers  which  hinder  the  achievement  of  the 
goals set in the legislation. More European action would accordingly be necessary to limit the 
impact on Europe's water quality of flooding or of pharmaceutical residues. To limit the use 
of fresh water more generally, there is a need for European coordination to increase the use 
of water-efficient equipment and water-metering.   

that 

This  research  makes  a  cautious  estimate  that  the  benefits  of  full  implementation  of  existing 
legislation  could  reach  2.8  billion  euro  per  year.  The  study  also  demonstrates  that  further 
European action in this field could provide further added value, representing a ‘cost of non-
Europe’ of some 25 billion euro per year. 

PE 536.369 

  1 

 
 
  
 
 
 
 
 
 
 
Cost of Non-Europe Report 

AUTHOR 
Thomas Zandstra, European Added Value Unit 

ABOUT THE PUBLISHER 
This  paper  has  been  drawn  up  by  the  European  Added  Value  Unit  of  the  Directorate  for 
Impact  Assessment  and  European  Added  Value,  within  the  Directorate–General  for 
Parliamentary Research Services of the Secretariat of the European Parliament.  
To contact the Unit, please e-mail EPRS_europeanAddedValueUniot@ep.europa.eu  

LANGUAGE VERSIONS 
Original: EN 
Translations: DE, FR 

This document is available on the internet at: www.europarl.europa.eu/thinktank 

DISCLAIMER 
The  content  of  this  document  is  the  sole  responsibility  of  the  author  and  any 
opinions  expressed  therein  do  not  necessarily  represent  the  official  position  of  the 
European  Parliament.  It  is  addressed  to  the  Members  and  staff  of  the  EP  for  their 
parliamentary work. Reproduction and translation for non-commercial purposes are 
authorised,  provided  the  source  is  acknowledged  and  the  European  Parliament  is 
given prior notice and sent a copy. 

Manuscript completed in March 2015. Brussels © European Union, 2015.  
Printed in May 2015.  

PE 536.369 
ISBN: 978-92-823-7110-7 
DOI: 10.2861/303057 
CAT: QA-04-15-333-EN-N 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
Water Legislation 

Contents 

Abbreviations  ........................................................................................................................................ 4 

Executive summary ............................................................................................................................... 6 

Introduction ............................................................................................................................................ 8 

1.  The state of implementation of the Water Framework Directive ..................................... 10 

1.1. The implementation of measures to improve water quality  ......................................... 10 

1.2. The implementation of measures to improve the quantitative aspects  ....................... 11 

1.3. The implementation of measures to improve the spatial aspects  ................................ 12 

2.  The cost of non-Europe in water legislation ......................................................................... 13 

2.1.  The Programmes of Measures ........................................................................................... 13 

2.2.  Eco-design and water metering ........................................................................................ 15 

2.3.  Economic instruments ........................................................................................................ 17 

2.4.  The re-use of wastewater ................................................................................................... 17 

2.5.  Pharmaceutical residues ..................................................................................................... 19 

3.  Synthesis of the findings .......................................................................................................... 20 

4.  Recommendations ...................................................................................................................... 21 

ANNEX I 

Research paper 

Existing and Future  EU Water Legislation .................................................................................... 23 

  3  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost of Non-Europe Report 

Abbreviations 

BWD 

CAP 

CIS 

CoNE 

DWD 

EQS 

GWD 

MS 

– Bathing Water Directive 

– Common Agricultural Policy 

– Common Implementation Strategy of the WFD 

– Cost of Non-Europe 

– Drinking Water Directive 

– Environmental Quality Standards 

– Groundwater Directive 

– Member State 

NWRMs 

– Natural Water Retention Measures 

PoM 

PS  

RBD  

RBM  

– Programmes of Measures 

– Priority Substances 

– River Basin District 

– River Basin Management 

RBMP    

– River Basin Management Plans 

TEU  

– Treaty on European Union 

UWWTD 

– Urban Waste Water Treatment Directive 

WEI 

WFD  

– Water Exploitation Index 

– Water Framework Directive 

WS&D   

– Water Scarcity and Drought 

4 

 
 
  
 
 
  
 
  
  
 
 
 
 
 
 
 
Water Legislation 

Note on methodology 

Costs  of  Non-Europe  (CoNE)  reports  are  designed  to  study  the  possibilities  for  economic 
benefits  and  the  achievement  of  a  ‘public  good’  through  common  action  at  EU  level.  They 
attempt  to  identify  policy  areas  which  can  benefit  from  deeper  EU  integration,  where  the 
added value of action at EU level is potentially significant. 

This  Cost  of  Non-Europe  report  examines  the  state  of  implementation  of  current  EU  Water 
Legislation  and  identifies  the  cost  of  no  European  action  in  this  field.  The  study  is  a 
combination  of  a  backward-looking  (ex-post)  and  forward-looking  (ex-ante)  evaluation  of 
European  water  legislation.  The  ex-post  part  looks  at  the  implementation  of  existing 
legislation,  while  the  ex-ante  part  assesses  the  potential  costs  and  benefits  of  further 
intervention  at  European  level,  on  the  basis  of  five  case  studies,  where  it  was  believed  that 
potential exists for additional EU action.  

The  findings  are  compared  to  the  conclusions  of  the  European  Commission’s  Blueprint1, 
which  was  carried  out  to  review  progress  and  to  realign  efforts  to  achieve  water-related 
targets.  

1 With the Blueprint to Safeguard Europe’s Water Resources published in 2012, the EC looked into the 
WFD’s effectiveness and gaps in implementation and at potential solutions in four general areas – land 
use and ecological status, chemical status and pollution, water efficiency and vulnerability of EU waters 

  5  

 
 
 
 
 
                                                 
Cost of Non-Europe Report 

Executive summary 

The European Parliament has repeatedly expressed concern over the implementation of the 
Water  Framework  Directive  (WFD)2    which  provides  a  solid  legislative  basis  for  long-term 
integrated  water  management  in  the  EU.  In  2012,  The  European  Parliament  adopted  a 
resolution  on  the  implementation  of  European  water  legislation3  which  called  on  the 
European Commission to enforce it and to adapt the legislation to new policy priorities. Later 
the same year, the European Commission presented its ‘Blueprint to safeguard Europe’s water 
resources’4  which  responded  in  certain  measure  to  the  concerns  expressed  in  the  EP 
resolution,  but  concentrated  on  better  implementation  of  water  legislation  and  on 
mainstreaming water policy objectives into other policies.  

This research details the implementation gaps and sets out four related policy challenges: 

-  There  is  still  a  poor  understanding  of  the  chemical  risks  in  relation  to  water 
quality, due to insufficient monitoring at national level and the lack of an EU risk 
assessment for whole groups of chemical substances in water (cumulative effect).  

-  There is an imbalance between the combined approach in the current legislation 
of applying European quality standards (EQS) for water and European emission 
controls.  Emission controls foreseen in the water framework directive have not 
yet  been  developed  -  so,  while  the  EU  has  a  range  of  emission  control 
instruments for industrial chemicals, pesticides and biocides, they were not used 
over the last decade to respond specifically to water pollution concerns. 

-  The  goals  of  water  protection  policies  and  related  policies,  particularly,  but  not 
exclusively,  energy  and  agriculture,  are  occasionally  incoherent  or  even  in 
conflict. 

-  The  absence  of  a  structural  vertical  and  cross-border  dialogue  between  the 
different tiers of government involved in the different River Basin Management 
Plans (RBMs) hinders their effective implementation. 

Research  demonstrates  that  properly  implemented  regulation  has  the  potential  of  bringing 
about  substantial  savings  on  water  treatment.  This  study  estimates  that  if  existing  EU 
legislation  were  to  be  fully  implemented,  and  all  water  bodies  to  achieve  a  ‘good’  status 
ranking, the combined annual benefits could be at least  2.8 billion euro.  

In addition to the examination of implementation issues, five cases were looked at to assess 
the need for more European action and to quantify the cost of ‘non-Europe’.  The assessment 
identified four policy challenges, where the absence of European action leads to a cost of non-
Europe of 25 billion euro annually, viz.:  

-  The  implementation  of  the  Programmes  of  Measures,  especially  with  regard  to 
flood  plain  restoration,  is  hindered  by  the  lack  of  effective  tools  to  design  the 
most  cost-effective  measures  to  achieve  the  goals  set  in  the  legislation.  The 

2 Directive 2000/60 EC 
3 2001/2297 INI 
4 SWD(2012) 381 final, page 2 

6 

 
 
 
 
 
 
                                                 
Water Legislation 

ensuing  delayed  restoration  of  8.8 million  hectare  of  floodplains  across  Europe 
leads to a cost of non-Europe of 15.2 billion euro per year.  

-  Existing  legislation  lacks  effective  measures  to  prevent  pollution  by  at  source, 
including  regulations  for  product  authorisation,  to  reduce  the 
level  of 
pharmaceutical  residues  in  urban  waste  water  streams.  The  absence  of  these 
measures and the related water treatment costs leads to a cost of non-Europe of 9 
billion euro per year. 

-  The  absence  of  European  criteria  for  maximum  water  consumption  by 
showerheads  and  water  taps,  and  the  current  exclusion  of  showerheads  and 
water taps in the Eco-design Directive, leads to a cost of non-Europe of 1.2 billion 
euro per year.  

-  Current  policies  on  water  pricing  lacks  complementary  rules  on  the  mandatory 
use of water meters by end-users. Water pricing on a volumetric basis is a proven 
incentive for reducing the use of fresh water and also leads to lower water bills. 
The absence of water meters in households leads to a cost of non-Europe of 200 
million euro per year.  

  7  

 
 
 
Cost of Non-Europe Report 

Introduction  

Water  usage  is  pervasive  and  extends  far  beyond  its  use  for  drinking.  Activities  such  as 
agriculture,  commercial  fishing,  energy  production,  manufacturing,  transport  and  tourism, 
which are crucial for generating and sustaining economic growth and prosperity, use water. 
This usage, however, combined with population growth and urbanisation, is leading to ever 
greater pressure on Europe’s water resources.  

To face these challenges, the European Union has, over the last 40 years, introduced a range 
of  laws  to  protect  Europe’s  waters.  With  the  Water  Framework  Directive  (WFD)  which 
entered into force in 2000, much of the older legislation was replaced by this comprehensive 
water  legislation,  which  introduced  river-basin  planning,  river-basin  management  and 
ambitious long-term targets for water protection.  

The  entry  into  force  of  the  Water  Framework  Directive  provided  a  comprehensive  legal 
framework,  replacing  a  number  of  existing  directives  on  water.  The  directive  is 
complemented by more specific EU laws regulating specific aspects of water use: 

-  The Groundwater Directive (2006) 

-  The Environmental Quality Standards Directive (2008) 

-  The Urban Wastewater Directive (1991) 

-  The Nitrates Directive (1991) 

-  The new Bathing Water Directive (2006) 

-  The Drinking Water Directive (1998) 

-  The Floods Directive (2007) 

-  The Marine Strategy Framework Directive (2008) 

-  Two Commission Decisions (2005 and 2008) on ecological status.  

Whereas previous legislation often adopted a sector-specific approach, the Water Framework 
Directive aims at protecting water based on natural geographical formations: river basins. A 
river basin or catchment covers the entire river system, from the sources of small tributaries 
to  the  estuary,  including  its  groundwater.  Under  the  Water  Framework  Directive,  Europe’s 
river basins and associated coastal areas have been divided into 110 river basin districts, 40 of 
which  are  international  and  cross  borders,  covering  about  60%  of  EU  territory.  Further  to 
this,  Member  States  are  now  obliged  to  draw  up  River  Basin  Management  Plans  (RBMPs) 
and Programmes of Measures (PoMs) to safeguard the ecological and chemical status of each 
of the 110 river basin districts. The ecological and chemical statuses are the two main criteria 
for  defining  water  quality.  To  grade  the  status  of  waters,  the  Water  Framework  Directive 
establishes  a  concept  of  ‘Water  Status’  comprising  five  different  levels:  ‘high’,  ‘good’, 
‘moderate’, ‘poor’ and ‘bad’. 

The  ecological  status  of  waters  refers  to  the  magnitude  of  aquatic  flora  and  fish  fauna,  the 
availability of nutrients, and aspects such as salinity, temperature and pollution by chemical 
pollutants. Morphological features, such as quantity, water flow, water depth and river-bed 
structure, are also taken into account.  

8 

 
 
 
 
 
 
Water Legislation 

The chemical status is defined by environmental quality standards that have been established 
for  chemical  pollutants  of  major  concern  across  the  EU.  The  Water  Framework  Directive  is 
therefore linked to other EU legislation such as the REACH5 regulation on chemicals and the 
Directive on Integrated Pollution and Prevention Control (IPPC) for industrial installations.  

The rules for groundwater are slightly different and the chemical and quantitative statuses 
are the main criteria. Member States must use geological data to identify distinct volumes of 
water  in  underground  aquifers,  and  European  law  limits  abstraction  to  a  percentage  of  the 
annual recharge. 

This system to establish the status of the different waters could be summarised in the form of 
three main drivers for determining the water status:  

-  Quality  (chemical  and  physico-chemical),  determined  by 

the 
including  heat,  nutrients,  pesticides, 

level  of 
industrial 

anthropogenic  emissions, 
chemicals and micro-pollutants, such as pharmaceutical residues; 

-  Quantity (Hydrology), the flow system and quantity of water available, which is 
altered by water abstraction and consumption, water-level regulation (dams and 
weirs)  or  changes  to  natural  water  retention  capacities  (land-sealing  and 
drainage);  

-  Space  (Morphology),  the  structure  of  the  river,  its  bed  and  riparian  zone  (i.e. 
river  banks),  which  are  changed  by  reducing  available  space  (using  floodplains 
for  settlement  or  agriculture),  altering  the  connectivity  of  ground  and  surface 
waters  (canals  and  culverts),  the  connectivity  between  the  river  and  adjacent 
land (dykes and levees) and upstream and downstream connectivity (dams). 

5 Regulation (EC) No 1907/2006 

  9  

 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

1.  The  state  of  implementation  of  the  Water  Framework 

Directive  

The  Water  Framework  Directive  sets  October  2015  as  the  deadline  for  all  waters  having  at 
least  a  ‘good’  status.  Despite  all  efforts,  the  European  Commission6  and  the  European 
Environment Agency (EAA)7 has reported that roughly 50% of Europe’s surface waters are 
likely to have a poor ecological status by the deadline of 23 October 2015. These expectations 
corroborate  the  reporting  for  related  directives.  For  example,  reporting  for  the  Habitats 
directive shows that over two-thirds of river and lake habitats and inland water species have 
an  unfavourable  conservation  status.  Reports  on  the  chemical  status  of  groundwater  show 
that 25% of all groundwater bodies have a poor chemical status. One frequent cause for poor 
status  is  nitrates  in  groundwater  emanating  from  agricultural  fertilizers.  Pressures  on 
hydrology  and  morphology  (hydro-morphology)  are,  however,  the  main  reasons  for  this 
failure to achieve a ‘good’ status.  

In  2012,  the  European  Parliament  expressed  it  concerns  at  the  rate  of  the  the  Water 
Framework  Directive's  implementation  in  the  Member  States.  This  led  to  the  adoption  of  a 
resolution  by  the  European  Parliament  in  2012  on  the  implementation  of  EU  water 
legislation8. The resolution called on the European Commission to enforce implementation of 
existing  water  legislation,  to  adapt  existing  legislation  to  reflect  water  priorities  and  to 
introduce  new  legislation  to  address  the  impact  of  specific  sectors  and  activities.  Later  that 
year,  the  European  Commission  published  its  ‘Blueprint  to  safeguard  Europe’s  water 
recourses’9.  The  European  Commission  took  note  of  Parliament’s  resolution  and  outlined 
actions  for  Member  States  to  achieve  the  goals  of  the  the  Water  Framework  Directive. 
However,  the  actions  put  forward  in  the  ‘Blueprint’  concentrated  mainly  on  better 
implementation  of  current  water  legislation  and  the  integration  of  water  policy  objectives 
into other policies and did introduce new solutions to overcome the gaps. 

This  research  examined  the  state  of implementation  of  the  Water Framework  Directive  and 
its related legislation. The level of implementation and the effectiveness of the legislation was 
assessed  on  the  basis  of  three  drivers  for  defining  the  'Water  Status'  (quality,  quantity  and 
space) a number of still existing implementation gaps were made visible: 

1.1.  The implementation of measures to improve water quality  

The  implementation  of  the  Water  Framework  Directive  is  still  insufficient  with  regard  to 
monitoring  pollutants.  Article  16  of  the  WFD  provides  for  a  combined  approach  to  setting 
Environmental Quality Standards (EQS) and emission controls. So far, this has led only to the 
setting of quality standards but not to additional European emission controls. While the EU 
has a range of emission control instruments for industrial chemicals, pesticides and biocides, 
so far these have not been used to respond specifically to water pollution concerns. Second, 
Member States are not quantifying all diffuse emissions originating from a variety of sources 

6 COM 2015 120 
7 EEA (2012) European waters — current status and future challenges, Synthesis 
8 2001/2297 INI 
9 SWD(2012) 381 final, page 2 

10 

 
 
 
 
 
                                                 
Water Legislation 

as required by the Environmental Quality Standards. The number of pollutants identified by 
Member States also varies significantly. As a consequence, most of the measures to prevent 
or reduce chemical pollution are too general, with no or unclear effects.   

1.2.  The implementation of measures to improve the quantitative 

aspects   

According  to  the  EU  treaty  European  measures  on  the  quantitative  management  of  water 
generally  require  unanimous  Council  decisions.  The  Water  Framework  Directive  addresses 
quantitative  water  aspects  only  indirectly  and  therefore  there  is  no  need  for  unanimous 
Council  decisions.  The  directive  introduced  policies  for  effective  water  management  which 
aim on authorisation schemes for water abstraction, the promotion of efficient water use and 
the  use  of  water-pricing  policies.  However,  to  date,  there  has  been  no  strong  evidence  that 
the instruments for achieving the quantitative goals have been successfully applied.  Overall 
the process is typified by the presence of inadequate targets and tools which hinder effective 
implementation.  

For example, Member States are able to apply a very narrow definition of water services, in 
order  to  facilitate  compliance10.  This  led  to  a  situation  where  most  water  users,  except  the 
users of public drinking water and waste water services, are not covered by the water pricing 
requirements  of  the  Water  Framework  Directive.  Recently,  the  European  Court  of  Justice, 
ruled that this as such is not a breach of WFD requirements, as Member States are allowed to 
“opt  not  to  proceed  with  the  cost  recovery  for  a  given  water  use  activity,  where  this  does  not 
compromise  the  purposes  and  the  achievement  of  the  objectives  of  that  directive  [Water  Framework 
Directive]”.11  

More successful are the measures to address the fresh water use by water-using products. 
Currently the   Eco-design directive12 and its daughter regulations are the main pieces of 
EU legislation for reducing the freshwater use by water-using products but it's limited to 
dishwashers and washing machines and for that reason the water saving effect is currently 
limited.  

However,  the  difficulties  to  achieve  the  goals  as  set  in  the  water  legislation  cannot  be  seen 
separately from the distinctive features of water related EU sector-specific policies such as for 
agriculture  and  energy,  which  focus  mainly  on  supply  and  production  and  tend  to  require 
greater land and water use. Nevertheless, a revised Common Agricultural Policy (CAP) was 
adopted  in  2013,  which  included  some  measures  aimed  at  dealing  with  water  use  in 
agriculture. However, the decision to add the Water Framework Directive to the list of issues 
subject to cross-compliance has been postponed.  

10 As noted in the European Commission infringement proceeding against Austria (EC - IP/12/653); 
Germany (EC - IP/12/536 and IP/11/1101);Belgium, Denmark, Finland and Sweden (EC - IP/11/1264); 
Ireland (EC - IP/11/1433) 
11 Judgment of the European Court of Justice (Second Chamber), 11 September 2014, in Case C‑525/12 
12 DIRECTIVE (2009/125/EC) establishing a framework for the setting of Eco design requirements for 
energy-related products 

  11  

 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

1.3.  The implementation of measures to improve the spatial aspects  

European land use measures require unanimous Council decisions too, according to the EU 
Treaty. It is therefore largely up to national policies to manage the spatial aspects relevant to 
achieve the spatial goals set in the water legislation.  

The  restoring  of  floodplains  and  the  improving  of  the  hydromorphological  conditions  (the 
physical  characteristics  of  the  shape,  boundaries  and  content  of  a  water  body)  affected  by 
existing infrastructure, such as dams and dykes are the main spatial challenges with regard 
to the goals of the Water Framework Directive.  

The  current  legislation  lays  down  only  very  general  binding  rules  to  ensure  that  hydro-
morphological goals are achieved (WFD Art 11.3i). The economic instruments, including cost 
recovery  for  water  services,  do  not  cover  land  use  in  general  and  only  cover  water 
infrastructure such as dams and dykes as services for inland navigation, flood protection or 
energy production in very broad terms. Furthermore, the economic analysis and assessment 
of better environmental options, as required by the legislation (WFD Art 4.3b and Annex III), 
is regarded as inadequate for gaining an understanding of whether potentially cost-effective 
measures such as reducing land use, have been considered before mitigating the impacts of 
land use.  

The potential benefits of full implementation of the Water Framework Directive 

The  implementation  of  the  Water  Framework  Directive  relies  in  the  end  on  Member  States 
taking  a  range  of  cost-effective  measures  in  a  transparent  and  participatory  way. 
Subsequently,  Member  States  must 
in  their  River  Basin 
Management Plans.  

integrate  these  measures 

The  examination  of  EU  water  legislation  shows  that  further  to  the  implementation  and 
compliance gaps, the lack of coherence between sector-specific and water policies, as well as 
between  different  water-related  policies  is  hindering  the  effective  achievement  of  water 
policy goals. The introduction of the River Basin Management Plans and the Programmes of 
Measures which were intended to streamline policies, have not yet managed to reduce those 
conflicts or lead to better policy integration in a systematic manner.  

Full implementation of the WFD would lead to substantial savings on water measures. When 
cautiously estimated, by using average unitary benefit per inhabitant multiplied by MS and 
then the EU population, the overall benefit of full implementing the FWD might be at least 
2.8 billion euro per year13.  

13 ACTeon, Comparative study of pressures and measures in the major river basin management plans 
in the EU, 2012 

12 

 
 
 
 
 
 
 
 
                                                 
Water Legislation 

2.  The cost of non-Europe in water legislation 

The  assessment  of  the  implementation  of  the  existing  water  legislation  has  confirmed  that 
there  are  still  implementation  gaps  and  areas  of  poor  performance.  This  part  of  the  study 
assesses  whether  there  is  a  need  for  additional  European  water  legislation.  Five  cases  were 
examined where it was believed that potential exists for additional EU action, namely: 

-  The Programmes of Measures 

-  Eco-design and water metering 

-  Economic instruments 

-  The re-use of wastewater 

-  Pharmaceutical residues in urban waste water 

The  previous  identified  implementation  gaps  and  areas  of  poor  performance are  addressed 
by the five cases and where applicable the potential costs and benefits are quantified. 

2.1.  The Programmes of Measures  

The Programmes of Measures (PoMs) are at the heart of river basin management planning, as 
it sets out the actions to secure the objectives of the water legislation. It builds on national gap 
analysis and includes the following considerations: 

-  Proposals  for  any  modification  of  the  procedures  for  licensing  abstractions  and 

consenting discharges.  

-  Basic measures to implement Community legislation for the protection of water 

in the river basin district.  

-  Pricing  measures  or  other  economic  instruments  to  provide  incentives  to 

encourage more sustainable and efficient water use.  

Member  States  have  to  set  up  these  Programmes  of  Measures  to  set  out  all  actions  for 
establishing  cost-effective  and  integrated  solutions  for  the  targets  as  set  in  the  River  Basin 
Management Plans.  

The creation and implementation of these the River Basin Management Plans appears to be 
still at a relatively early stage. In 2012, 105 (75%) of the 124 foreseen River Basin Management 
Plans  were  reported  to  the  Commission14.  In  addition  to  implementation  problems,  the 
assessment noted that the River Basin Management Plans struggled to provide adequate and 
detailed information that allowed for assessments and proper monitoring, and that Member 
States  made  excessive  use  of  exemptions  to  the  guidelines  set  out  under  the  Water 
Framework  Directive  in  order  to  justify  current  levels  of  abstraction  or  management 
practices. The fact that the River Basin Management Plans have been integrated into local and 
regional decision-making in many Member States suggests that where it is lagging, it is due 
to national or bilateral cross-border discussions on implementation rather than to problems 
interpreting the relevant EU regulations.  

14 COM (2012) 670 

  13  

 
 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

The  research  details  that  one  of  the  remaining  challenges  is  to  improve  the  hydro-
morphological  status  of  water  bodies.  The  Commission  identified  that  the  River  Basin 
Management  Plans  were  insufficiently  aligned  or  integrated  with  other  important  adjacent 
policy domains and documents such as the Flood Risk Management Plans or taking climate 
change and adaptation into account 

An  assessment  of  the  basic  (mandatory)  and  supplementary  measures  which  should  be 
included in the Programmes of Measures (WFD Article 11) shows that in practice there are no 
strong  specific  requirements  for  actually  restoring  hydro-morphology  or  for  creating  more 
space  for  rivers.  The  Programmes  of  Measures  have  to  be  seen  as  part  of  the  central 
governance  tool,  the  River  Basin  Management  Plans,  which  should  foster  Integrated  Water 
Resource Management (IWRM) and cross-border cooperation by taking the entire river basin 
as an administrative unit instead of national, regional or local borders. 

Opportunities  for  closer  European  coordination 
improve  the  hydro-
morphological  status  of  water  bodies  are  limited,  as  the  EU  has  limited  regulated  powers 
over  land  use  and  spatial  planning.  However,  there  are  two  areas  where  closer  European 
coordination could provide added value: 

in  order  to 

•  Dyke  set-back  and  floodplain  restoration,  often  referred  to  as  Natural  Water 

Retention Measures (NRWM) 

•  Dam removal 

The added value that could come from boosting financial incentives and policy coherence, in 
particular  with  regard  to  policies  on  flood-risk  management,  agriculture  and  investment 
policies,  could  be  improved  by  introducing  effective  management  tools,  clear  governance 
principles  and  effective  financing  tools.  A  wider  application  of  the  cost-recovery  principle 
(WFD  art  9)  and  full  implementation  of  the  water  legislation  could  also  be  helpful  to 
incentivise and finance measures. 

Existing data15 show that the potential for flood-plain restoration is huge and offers a broad 
range  of  positive  impacts,  such  as  flood  protection,  clean  drinking  water  provision  and 
recreation, with economic benefits estimated to be higher than the economic costs. However, 
the upfront costs are high and payback periods can be as long as 20 years. The costs range 
from  5 000  euro/hectare  to  over  100 000  euro/hectare,  depending  on  the  price  of  land  and 
whether major infrastructure works are required, i.e. dyke set-back. 

 The annual benefits also vary, from 500 euro/hectare to more than 10 000 euro/hectare. The 
most pronounced benefits lie in reduced flood damage and drinking water treatment. Other 
ecosystem  service  provisions,  including  food  and  biomass  production  and  recreational 
activities, are more difficult to quantify. 

To realise the restoration of 8.8 million hectares of floodplains, European coordination would 
be needed, in order to harness investments of 24.1 billion euro per year for the period 2015-
2030.  This  would  result  in  a  total  cost  for  this  period  of 361.8  billion  euro,  mainly  for  land 
purchase and infrastructure works. Nevertheless, these actions could lead to annual benefits 

15 IEEP (2010) Green infrastructure in-depth case analysis 

14 

 
 
 
 
 
 
 
 
                                                 
Water Legislation 

of  39.3  billion  euro  in  2030  or  total  benefits  of  295  billion  euro  for  the  period  2015-2030, 
mainly due to reduced flood damage, lower public water supply costs and increased tourism 
and  recreation  activities.  This  would  altogether  result  in  an  annual  net  gain  of  15.2  billion 
euro.  

2.2.  Eco-design and water metering 

Each  European  uses,  on  average, 100-200  litres  of  tap  water  a day.  Households  account  for 
about  10  %  of  total  water  consumption  in  the  whole  of  the  EU.  About  30%  of  this  is  for 
personal  hygiene,  about  30%  for  washing  clothes  and  dishwashing,  25  to  30  %  for  flushing 
toilets and only about 5 % for drinking and cooking16.  

The Eco-design directive17 and its daughter regulations are the main pieces of EU legislation 
for reducing the freshwater use by water-using products. Although this legislation focusses 
primarily  on  energy-related  products,  there  are  already  two  examples  of  minimum 
requirements  being  extended  to  water  use:  the  Washing  Machines  Regulation 18  and  the 
Dishwasher  Regulation19.  The  directive  and  its  daughter  regulations  are  relatively  new  but 
their expected effects are substantial. The measures to reduce the freshwater consumption of 
washing machines and dishwashers should result in annual water savings of 336 million m3 
in the EU by 2020 (1.2% of the EU residential total)20 . However, poor market surveillance is 
hindering implementation,21 which could limit the quantitative effect on Europe’s freshwater 
sources. 

The  possibilities  provided  by  the  Eco-design  directive  are  limited,  as  it  focuses  on  energy-
related products. This means that not all water-using products, such as toilets and irrigation 
systems,  fall  within  the  directive’s  scope.  This  focus  on  energy  use  diminishes  the  water-
saving potential of the Eco-design directive. Research shows that if all domestic water-using 
products were covered by the directive, a 19.6% reduction in EU total public supply could be 
achieved (around 10% if only energy-related products were included, excluding dishwashers 
and washing machines). This would correspond to a 3.2% reduction in the EU’s total annual 
abstraction volume22.  

The  Eco-design  directive  is  currently  in  its  second  working  plan,  which  has  identified 
showers  and  water  taps  as  products  to  be  considered  for  the  adoption  of  implementation 
measures.  The  average  person  uses  30-80  litres  when  showering  and  although  progress  on 

16 European Environment Agency (EAA) data on household consumption 
17 DIRECTIVE (2009/125/EC) establishing a framework for the setting of Eco design requirements for 
energy-related products 
18 REGULATION ((EU) No 1015/2010) implementing Directive 2009/125/EC with regard to Eco design 
requirements for household washing machines 
19 REGULATION ((EU) No 1016/2010) implementing Directive 2009/125/EC with regard to Eco design 
requirements for household dishwashers 
20 EU residential total water consumption, from the public grid, is 27 billion m³ in 2008 (source: VHK, 
MEErP, 2011). 
21 European Council for Energy Efficient Economy (ECEEE) webpage: 
http://www.eceee.org/ecodesign/Horizontal-matters/eceee-pages-on-ecodesign-and-labelling-
market-surveillance/MSreport 
22 BioIS & Cranfield University(July 2009) Study on water efficiency standards 

  15  

 
 
 
 
 
                                                 
Cost of Non-Europe Report 

introducing criteria on showerheads and water taps has been limited to date, the estimated 
water savings are substantial and are estimated to reach 3.7 billion m3 per year by 2030.  

Water consumers would have to invest in new showerheads and water taps before they can 
benefit from savings and might face higher purchase costs but also lower usage-related costs. 
In the case of showerheads and water taps, the payback time for products, in order to achieve 
10-20% savings, is estimated to be less than 1 year23. The impacts of eco-design measures on 
industry  are  positive  but  limited.  96%  of  the  surveyed  companies  (most  of  which  in  the 
manufacturing sector) reported that Eco-design had either positive or neutral effects on their 
profitability24. 

Assuming  a  constant  average  water  price  in  the  EU  of  3.7  euro/m3  and  an  average  energy 
price  of  0.2  euro/kWh,  the  savings  on  water  bills  and  respectively  on  energy  bills  would 
reach  13.6  billion  euro  and  19.6  billion  euro  per  year  in  2030.  As  referred  to  above,  these 
savings  can  only  be  made  when  existing  showerheads  and  water  taps  are  replaced. 
Assuming a normal replacement rate of shower heads and water taps an average additional 
cost  of 9.3  euro/unit  for  the  higher-performing  products,  there  would  be  an  annual 
investment  needed  by  households  of  1  billion  euro  per  year,  which  would  lead  to  a  total 
investment cost of 16.9 billion euro for the period 2015-203025. Based on annual investments 
of 1 billion euro to replace showerheads and water taps, there would be  a potential annual 
accumulating gain in GDP of at least 1.2 billion euro per year in the period 2015-2030.  

Water  metering  is  a  complementary  measure  to  eco-design.  Effective  metering  makes  end-
users  aware  of  the  amount  of  water  they  use  and  the  savings  made  by  installing  more 
efficient water-using products. Especially when effective water metering is linked to effective 
water pricing,  water  metering  can  lead  to  lower  consumption.  Research  shows for  example 
that introducing volumetric charging in agriculture can reduce the volume of water used by 
10 -20 %.26 

Greater use of water meters would also bring benefits but, as with showerheads and water 
taps,  consumers  will  only  make  gains  once  they  have  invested  in  water  meters.  When 
assessing  the  potential  costs  of  Non-Europe  with  respect  to  water  metering,  the  following 
rough  estimates  can  be  made:  assuming  a  constant  average  water  price  in  the  EU  of   3.7 
euro/m3  and  water  savings  of  22m3  per  household  per  year,  the  estimated  annual  cost 
savings  per  household  are  81.4.  euro The  total  number  of  households  in  the  EU28  reported 
for 2013 by Eurostat27 is 213 839.2. The exact number of households that already have a water 

23 VHK (2011) Final Report Task 1-4 Study on Amended Working Plan under the Ecodesign Directive 
(remaining energy-using products and new energy-related products) 
24 Pôle Éco-conception et Management du Cycle de Vie & Institut de développement de produits (2014) 
Profitability of Ecodesign: an Economic Analysis, Highlights from 
http://cloud.snappages.com/b0d6d10923becba07c0287d0b0af8fd47ed8a57d/Profitability%20of%20eco
design_highlights_1.pdf 
25 Calculations based on World Energy Outlook 2010, water energy nexus.  
26 European Environment Agency, Assessment of cost recovery through pricing of water, 2013 
27 Eurostat (2014) Number of private households by household composition, number of children and 
age of youngest child (1 000), last updated on 29.04.2014 and available at 
http://appsso.eurostat.ec.europa.eu/nui/submitViewTableAction.do 

16 

 
 
 
 
 
                                                 
Water Legislation 

meter  installed  is  not  available  but,  assuming  that  only  one-third28  have  water  meters,  the 
potential  gain  in  the  EU28  would  be  over 0.4 billion  euro  per  year  from  investing 0.2  euro 
billion per year to install water meters in the period 2015-2030.  

2.3.  Economic instruments 

The  Water  Framework  Directive  (Article  9)  obliges  Member  States  to  take  account  of  the 
principle of cost recovery from water services and therefore to ensure sufficient water-pricing 
schemes  and  to  apply  the  ‘polluter-pays-principle’  (Article  5).  However,  research29  shows 
that  the  use  of  economic  instruments  in  Europe  is  still  insufficient  to  achieve  sustainable 
water  use.  On  the  contrary,  Member  States  even  subsidise  water-using  activities  in  other 
policy areas such as bioenergy, agriculture and the construction of dams. This alters relative 
prices  and  thus  leads  to  excessive  water  consumption  instead  of  reducing  its  use.  Further 
barriers  to  the  sufficient  use  of  economic  instruments  are  caused  by  inadequate  knowledge 
regarding the use of such instruments, a lack of transparency in the calculation of costs and a 
lack of public acceptance or historical allocation of water rights that prevents the introduction 
of such measures30. The WFD shows weaknesses too when it comes to ensuring a sufficient 
use of economic instruments. The directive fails to set clear targets for the recovery of costs 
and it is unclear to what extent the ‘polluter pays principle’ should be applied.  

Moreover,  the  use  of  flat  rates  for  water  use  is  still  widespread  in  the  EU  and  provides  no 
incentive  for  sustainable  water  use31.  However,  industry  often  directly  abstracts  water  and 
the  low  or  non-existent  prices  they  pay  for  abstraction  do  not  provide  an  incentive  for 
investments in water efficiency and savings32.  

It is clear that economic instruments, if combined with the use of volumetric elements (such 
as water metering) can act as an effective incentive to reduce the use of water. However, it is 
important  to  note  that  the  use  of  economic  instruments  is  not  a  policy  area  but  rather  an 
approach for meeting the EU’s water targets. Based on the data available, it is yet not possible 
to assess the benefits of achieving those goals. A first step at the EU level could be to estimate 
the  potential  effects  of  these  policies  if  applied  in  all  Member  States  and  to  discourage 
Member State policies from subsidising the use of water.  

2.4.  The re-use of wastewater 

Pressure  on  Europe`s  freshwater  resources  is  increasing.  Several  Member  States  already 
experience occasional periods of drought and these periods of water shortage are becoming 
more frequent and longer. It is not only the Mediterranean countries that are affected by this: 
France, Bulgaria, Malta, Belgium and the UK have also suffered successive droughts over the 

28 This is a rather conservative estimate. Based on most expert judgment it is likely that over 50% of 
households are equipped with a water meter across the EU-28. 
29 EC [COM(2012) 670 final] Report (...) on the Implementation of the Water Framework Directive 
(2000/60/EC) River Basin Management Plans – pp.10-11 
30 EC [SWD(2012) 382 final]]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to 
Safeguard Europe’s Water Resources 
31 EEA (2013) Assessment of cost recovery through water pricing 
32 CEPS (2012) Which Economic Model for a Water-Efficient Europe? 

  17  

 
 
 
 
 
                                                 
Cost of Non-Europe Report 

last twenty years33. The EU Water Scarcity and Drought Working Group estimated that the 
overall economic impact of drought events in the last 30 years at the EU level was around 100 
billion euro. The re-use of water is covered (directly or indirectly) by the Water Framework 
Directive and the Urban Waste Water Treatment Directive (UWWTD) and also forms part of 
the  Water  Scarcity  and  Drought  (WS&D)  policy  recommendations  put  forward  by  the 
European  Commission34.  Reclaimed  water  is  also  covered  by  other  EU  water-related 
legislation  but  coverage  depends  on  the  final  use.  For  example,  irrigation  and  ‘green 
agriculture’ generally fall under the scope of the Common Agricultural Policy (CAP), while 
quality standards for drinking water are set by the Drinking Water Directive (DWD).  

Further to the obligations laid down by water legislation, several initiatives have been carried 
out, under which re-used grey and wastewater replaces the use of freshwater, for example, in 
irrigation  in  agriculture,  industrial  processes,  non-potable  urban  applications,  groundwater 
recharge and in recreational activities. The data on the two largest consumers of conventional 
water resources, agriculture and electricity generation, show that two-thirds of agriculture’s 
water needs are already sourced from re-used water, while electricity generation hardly uses 
re-used water at all.  

Despite  the  European  legislation  on  re-use  and  Member  States’  specific  actions,  several 
obstacles to ensuring effective water re-use can be identified:  

- 

- 

- 

- 

- 

- 

a lack of clear international standards; 

scattered  references  to  different  water  re-use  issues  in  various  EU  and  national 
level regulations across multiple sectors; 

some national standards are criticised for being too stringent and hence creating 
barriers to increasing water re-use 35; 

the need for synchronisation on standards related to health risks36; 

new quality standards for water re-use in the DWD and food safety legislation in 
cases where recycled water is to be used directly or indirectly for consumption 37;  

insufficient  awareness  and  training  on  this  issue  among  the  key  stakeholders 
(including farmers and the general public)38 .  

It  is  clear  that  re-use  can  play  a  role  in  achieving  the  objectives  by  reducing  the  negative 
impacts of droughts and water scarcity. However, in the broader picture, this approach only 
addresses a very specific and small part of the quantitative issues and potential future health 
impacts  identified  by  this  study.  Therefore,  on  its  own,  increased  re-use  of  greywater  and 
wastewater may not have sufficient impact to close much of the current gap between existing 
water  policies  and  successful  implementation  levels.  Furthermore,  water  re-use  does  not 
automatically  lead  to  a  reduction  in  water  consumption.  This  is  true,  for  example,  of 

33 TYPSA (2013) Updated Report on Wastewater Reuse In The European Union. 
34 TYPSA (2012). Service contract for the support to the follow-up of the Communication on Water 
scarcity and Droughts: WASTEWATER REUSE IN THE EUROPEAN UNION 
35 EurEau (2009) EurEau position on water reuse for irrigation as a water scarcity solution 
36 EurEau (2011) EurEau Position Paper Water re-use and other alternative resources at home: rainwater 
harvesting and greywater recycling for domestic purposes 
37 EurEau (2011) EurEau Position Paper Water re-use and other alternative resources at home: rainwater 
harvesting and greywater recycling for domestic purposes 
38 See EEA (2012) European waters — current status and future challenges Synthesis 

18 

 
 
 
 
                                                 
Water Legislation 

wastewater re-use for irrigation in agriculture. Wastewater, which would have been returned 
to the environment, is instead ‘consumed’ by agriculture and is thus missing downstream. 

Nevertheless, there is no clear case for regulation to promote wastewater re-use at EU level. 
Although  European  standards  on  the  safe  re-use  of  greywater  and  wastewater  would  be 
complementary, this study shows that national policy and regulatory revisions should play 
a more important role because, in many cases, water re-use primarily helps solve problems 
in  specific  regions  of  the  EU,  rather  than  significantly  contributing  to  sustainable  water 
management in broader terms. 

2.5.  Pharmaceutical residues  

Residue compounds from pharmaceuticals in water and soil are increasingly identified as an 
emerging  environmental  concern  by  a  number  of  organisations,  including  the  European 
Environmental  Agency  (EEA)  and  the  World  Health  Organisation  (WHO).  Article  8c  of  the 
Water  Framework  Directive,  like  the  Priority  Substances  Directive,39  spells  out  specific 
provisions for pharmaceuticals. It calls on the European Commission to develop a strategy to 
deal with pollution in water by pharmaceutical substances within 2 years.  

In 2013, for the first time, three commonly used pharmaceuticals were added to the Priority 
Substances Directive watch list, namely two hormones (17alphaethinylestradiol and 17beta-
estradiol)  and  a  painkiller  (the  non-steroidal  anti-inflammatory  drug  (Diclofenac).  The 
addition of these pharmaceuticals to the priority substances watch-list means that their levels 
and  effects  will  be  monitored  to  determine  whether  or  not  to  include  them  on  the  list  of 
priority substances. Their addition to the watch-list has opened up a number of possibilities 
for the selection and monitoring of substances.  

However, an accurate understanding of the scale of the problem and the associated costs is 
hampered by a lack of data, in particular at the EU-28 level. The (eco)toxicological effects of 
pharmaceuticals  are  not  well-understood  and  the  monitoring  of  their  release  and 
concentrations  in  European  waters  and  sediments  is  patchy  at  best,  as  most  are  not  part  of 
national  routine  monitoring  programmes.  Even  less  is  known  about  the  effects  of  smaller 
doses  of  pharmaceutical  discharge  over  longer  periods  of  time  on  humans  or  the 
environment. The interaction between compounds in nature is also scarcely understood. 

Closer EU policy coordination on pharmaceuticals could follow a number of scenarios with 
different cost and benefit implications. The main bone of contention, which divides industries 
with  a  stake  in  this  issue,  is  whether  the  problem  should  be  addressed  through  water 
legislation, pharmaceutical legislation or a combination of both. The pharmaceutical industry 
argues that water pollution should be covered by pharmaceutical rather than environmental 
legislation  in  order  to  avoid  dual  legislation40  and  proposes  a  combination  of  upstream 
measures - such as monitoring use in hospitals - when deemed relevant in combination with 
downstream  measures  such  as  water  treatment.  In  contrast,  the  water  industry  and 

39 European Parliament legislative resolution of 2 July 2013 on the 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)0876 – C7-0026/2012 – 
2011/0429(COD))  
40 Interview with EFPIA (25/9/14) 

  19  

 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

environmental  NGOs  argue  for  measures  to  prevent  pollution  at  source,  including  product 
authorisations41.  

In terms of water legislation, it would make sense to introduce upstream measures to avoid 
that pharmaceutical residues reach the waste water in the first place, together with product 
authorisation. This would limit the polluting effect of pharmaceuticals on water and would 
reduce the costs of end-of-pipe water treatments.  

The  water  treatment  costs  of  removing  pharmaceutical  residues  from  urban  waste  water 
streams are significant. In order to avoid those costs, it appears worthwhile to investigate the 
costs  and  benefits  of  upstream  measures  such  as  adding  environmental  aspects  to  the  EU 
pharmaceuticals authorisation system and EU-wide campaigns to encourage the replacement 
and  safe  disposal  of  unused  drugs.  European  measures  to  coordinate  upstream  action  to 
reduce the level of pharmaceutical residues from urban waste water streams would lead to 
lower  water  wastewater  treatment  costs,  which  could  result  in  annual  savings  of 9  billion 
euro per year.  

3.  Synthesis of the findings  

The  Water  Framework  Directive  (WFD)  introduced  innovative  policy  instruments  and 
stringent  goals  to  improve  the  quality  and  management  of  European  waters.  The  cost  of 
none-Europe assessment of the five cases demonstrates that there are several shortcomings in 
the  existing  framework  that  form  barriers  to  achieve  the  goals  set  in  the  Water  Framework 
Directive.  The  Cost  of  None-Europe  assessment  identified  four  building  blocks  where  new 
European action would remove barriers and where its current absence leads to a cost of non-
Europe totalling some 25 billion euro per year. 

Building Blocks - Potential efficiency gains  
from Water legislation 

Cost of non-Europe  
(billion euro) 

Realising flood plans 

Reducing pharmaceutical residues in urban waste water 

Increased use of water efficient equipment  

Increased application of water metering  

Total 

15.2  

9.2  

1.2 

0.2 

25.8 

41 Interviews with EEB (5/9/14) and EurEau (9/9/14) 

20 

 
 
 
 
 
 
 
                                                 
Water Legislation 

4.  Recommendations 

The  assessment  of  the  implementation  of  the  existing  water  legislation  has  confirmed  that 
there  are  still  implementation  gaps  and  areas  of  poor  performance  with  regard  to  the 
European  water  legislation  and  identified  actions  to  overcome  the  main  implementation 
gaps. If the Water Framework is fully implemented and if all of Europe’s waters achieved a 
‘good’ status, the benefits could be at least 2.8 billion euro per year.  

Four recommended actions to overcome the main implementation gaps 

-  

-  

-  

-  

Emission controls foreseen by the Water Framework Directive would need to be introduced 
to improve the control for industrial chemicals, pesticides and biocides in water. 
The  monitoring  of  waters  at  national  level  needs  to  be  improved  following  the  criteria  of 
the water legislation and complemented with a European risk assessment for whole groups 
of chemical substances in water to assess their cumulative effect.  
The  goals  of  the  water  protection  policies  and  related  policies  in  particular,  but  not 
exclusively,  energy  and  agriculture  need  to  be  made  coherent.  A  first  step    could  be  the 
addition of the Water Framework Directive to the list of issues subject to cross-compliance 
with the Common Agricultural Policy. 
A structural vertical and cross-border dialogue between the different  tiers of government 
involved in the River Basin Management Plans should be established to ensure an effective 
and coherent implementation of the water legislation. 

The  cost  of  non-Europe  assessment  identified  building  blocks  where  new  European  action 
would have added value and where its current absence leads to a cost of non-Europe  of 25 
billion euro per year.  

Four recommended actions to obtain potential efficiency gains in Water legislation 

-  

-  

-  

- 

To  realise  a  restoration  potential  of  8.8  million  hectare  of  floodplains  as  part  of  Natural 
Water  Retention  Measures  (NRWM),  the  Water  Framework  Directive  and  the  Floods 
Directive  should  be  complemented  with  management  tools  to  support  member  States  to 
identify obsolete infrastructure, to establish effective prioritising and to develop financing 
tools.  
The  current  water  legislation  should  be  complemented  with  upstream  measures  and 
product authorisation measures for pharmaceuticals (e.g. safe disposal of unused drugs) to 
reduce  the  level  of  pharmaceutical  residues  from  urban  waste  water  streams.  This  would 
improve the chemical quality of wastewater and lead to lower water treatment costs. 
The  Eco-design  directive  should  be  expanded  to  include  criteria  for  maximum  water 
consumption  by  showerheads  and  water  taps  to  further  reduce  the  use  of  freshwater  in 
Europe. Second, the scope of the Eco-design directive could be widened to all water-using 
products.   
Current policies on water pricing should be complemented with rules on the mandatory use 
of water meters by end-users.  

  21  

 
 
 
 
 
 
 
 
 
 
Cost of Non-Europe Report 

22 

 
   
Water Legislation 

The Cost of Non-Europe  
in Water Legislation 

ANNEX I 

Existing and Future  
EU Water Legislation 

Research paper  
by Triple E Consulting 

 
 
 
 
 
 
 
Cost of Non-Europe Report 

AUTHORS 
Rob Williams, Triple E Consulting – Energy, Environment & Economics B.V., Westersingel 
32A, 3014 GS, Rotterdam, The Netherlands, Rob.williams@tripleeconsulting.com 
Stefan Scheuer, Stefan Scheuer Consulting  
Oscar Widerberg 
Lisa Eichler 
Mariya Gancheva 

RESPONSIBLE ADMINISTRATOR 
Thomas Zandstra, European Added Value Unit 

ABOUT THE PUBLISHER 
This  paper  has  been  drawn  up  by  the  European  Added  Value  Unit  of  the  Directorate  for 
Impact  Assessment  and  European  Added  Value,  within  the  Directorate–General  for 
Parliamentary Research Services of the Secretariat of the European Parliament.  
To contact the Unit, please e-mail EPRS_EuropeanAddedValueUnit@ep.europa.eu  

LANGUAGE VERSIONS 
Original: EN 

This document is available on the internet at: www.europarl.europa.eu/thinktank 

DISCLAIMER 
The  content  of  this  document  is  the  sole  responsibility  of  the  author  and  any 
opinions  expressed  therein  do  not  necessarily  represent  the  official  position  of  the 
European  Parliament.  It  is  addressed  to  the  Members  and  staff  of  the  EP  for  their 
parliamentary work. Reproduction and translation for non-commercial purposes are 
authorised,  provided  the  source  is  acknowledged  and  the  European  Parliament  is 
given prior notice and sent a copy. 

Manuscript completed in December 2014. Brussels © European Union, 2015.   
Printed in May 2015.  

ISBN:  978-92-823-7113-8 
DOI: 10.2861/07615 
CAT: QA-04-15-334-EN-N 

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Water Legislation 

Contents 

Abbreviations ....................................................................................................................................... 27 

Executive summary ............................................................................................................................. 28 
Conclusions on progress to date ................................................................................................ 28 
Remaining challenges .................................................................................................................. 29 
Policy recommendations for potential future EU policy actions .......................................... 29 

1. 

Introduction and method .......................................................................................................... 31 

2.  Phase I - Ex-post impact assessment ....................................................................................... 34 
2.1.  The structure of water-related EU law ............................................................................. 34 
2.2.  Assessment of progress in the different areas and use of tools ................................... 41 
2.3.  Assessment of the effectiveness in addressing water status drivers ........................... 44 
2.4.  Conclusions from the Ex-post Impact Assessment ........................................................ 47 

3.  Phase II - The cost of non-Europe ............................................................................................ 53 
3.1.  Potential new EU legislation vs. gaps in coverage and areas of poor performance .... 53 
3.2.  Case study for Programmes of Measures ........................................................................ 55 
3.3.  Case study for the re-use of wastewater .......................................................................... 60 
3.4.  Case study for Eco-design and water metering .............................................................. 67 
3.5.  Case study for economic instruments .............................................................................. 75 
3.6.  Case study for pharmaceutical residues .......................................................................... 79 
3.7.  Summary of case study results .......................................................................................... 85 

4.  Conclusions .................................................................................................................................. 88 
4.1.  Comparison with the Blueprint findings and actions .................................................... 88 
4.2.  Conclusions on progress to date and remaining challenges ........................................ 89 
4.3.  Policy recommendations .................................................................................................... 90 

Annexes 

Annex A – Water policies factsheets ................................................................................................. 94 

Annex B – Stakeholders interviewed .............................................................................................. 111 

Annex C – Bibliography .................................................................................................................... 112 

25 

 
 
 
 
 
 
 
 
 
 
 
Cost of Non-Europe Report 

List of figures 

Figure 1: Illustration of the water cycle ............................................................................................. 36 

Figure 2: Illustration of assessment of EU water policy structure  against  
water status elements ........................................................................................................................... 39 

Figure 3: Water status assessment, North-Rhine-Westphalia, 2010 ............................................. 40 

Figure 4: Functioning of a flood control area with controlled reduced tides .............................. 58 

Figure 5: Overview of surveyed Danube reaches and tributaries ................................................ 59 

Figure 6: Water use and re-use of European countries by application ........................................ 61 

Figure 7: Effect of water price on household use in Denmark 1985-2004   
and Estonia 1992-2004 .......................................................................................................................... 69 

Figure 8: Composition of typical effects on bills for household measured  
charging  based on installation of a simple meter ........................................................................... 72 

Figure 9: Potential benefits from EU policy measures for  2015-2030 and annually .................. 91 

Figure 10: Potential investment needs of EU policy measures for 2015-2030  
and annually .......................................................................................................................................... 91 

List of tables 

Table 1: Overview of EU water-related legislation ......................................................................... 35 

Table 2: Overview of the progress of EU water legislation ........................................................... 50 

Table 3: Water re-use by sector and MS (EU27),  including relevant national 
regulations/guidelines ........................................................................................................................ 62 

Table 4: EU water-related directives requiring specific standards for specific  
water uses, along with the different re-use applications................................................................ 64 

Table 5: Range of life cycle costs for treated wastewater re-use, .................................................. 66 

Table 6: Summary of findings from IA for the three potential priority substances ................... 81 

Table 7: Policy options and costs to address pharmaceutical residues ........................................ 84 

Table 8: Recommended focus for EU water protection actions .................................................... 87 

Table 9: Overview of ex-post assessment and Blueprint to Safeguard  
Europe’s Water Resources .................................................................................................................. 92 

Table 10: Water Framework Directive (WFD) factsheet ................................................................. 94 

Table 11: Urban Waste Water Treatment Directive (UWWTD) factsheet ................................... 97 

Table 12: Ecodesign directive factsheet ............................................................................................. 99 

Table 13: Environmental quality standards (EQS) directive factsheet ....................................... 101 

Table 14: List of priority substances (PS) factsheet ....................................................................... 102 

Table 15: Floods Directive factsheet ................................................................................................ 103 

Table 16: Water scarcity and droughts (WS&D) policy factsheet ............................................... 104 

Table 17: Drinking Water Directive (DWD) factsheet .................................................................. 106 

26 

 
 
Water Legislation 

Table 18: Bathing Water Directive (BWD) factsheet ..................................................................... 107 

Table 19: Groundwater Directive (GWD) factsheet ...................................................................... 108 

Table 20: Nitrates Directive factsheet .............................................................................................. 109 

List of boxes 

Box 1 - Research on costs and benefits of water metering in the UK ........................................... 71 

Box 2 - The CAP and its reform .......................................................................................................... 76 

Box 3 - Examples of economic instruments from selected Member States .................................. 78 

Abbreviations 

BWD – Bathing Water Directive 

CAP – Common Agricultural Policy 

CIS – Common Implementation Strategy of the WFD 

CoNE– Cost of Non-Europe 

DWD – Drinking Water Directive 

EQS – Environmental Quality Standards 

GWD – Groundwater Directive 

MS – Member State 

NWRMs– Natural Water Retention Measures 

PoM– Programmes of Measures 

PS – Priority Substances 

RBD – River Basin District 

RBM – River Basin Management 

RBMP – River Basin Management Plans 

TEU – Treaty of European Union 

UWWTD– Urban Waste Water Treatment Directive 

Water  Status  –  Overall  status  of  surface  and  groundwater  as  defined  by  the  Water 

Framework Directive 

WEI– Water Exploitation Index 

WFD – Water Framework Directive 

WS&D – Water Scarcity and Drought 

27 

 
 
 
 
 
 
Cost of Non-Europe Report 

Executive summary 

This study concerns Existing and Future EU Water Legislation. The overall objective of this 
study was to carry out a combination of a backward looking (ex-post) and forward looking 
(ex-ante)  evaluation  of  European  water  legislation.  The  emphasis  is  on  the  ex-post  aspect, 
mainly because of the need to check the level of implementation of existing legislation. The 
ex-ante aspect aims at assessing the potential costs and benefits of further intervention at EU 
level  using  five  case  studies,  along  the  lines  of  the  approach  adopted  for  other  sectors  and 
reported in the ‘Mapping the Cost of Non-Europe, 2014 -19’ report.42  

In  line  with  the  objectives  described  above,  this  report  is  divided  into  two  main  parts.  The 
first part focuses on the ex-post type impact assessment – identifying policy areas and tools 
as  well  as  the  main  water  status  elements  and  assessing  the  implementation  progress, 
effectiveness  and  coverage  of  the  existing  body  of  legislation.  The  findings  are  compared 
against  the  conclusions  of  the  European  Commission’s  Blueprint43  that  was  carried  out  to 
review  progress  and  realign  efforts  for  reaching  water-related  targets.  The  second  phase 
builds  on  the  first  and  considers  the  costs  and  benefits  of  additional  potential  EU-level 
legislation (or other action) within the scope of the five pre-selected case studies to address 
any identified gaps.  

Conclusions on progress to date 

The  Water  Framework  Directive  (WFD)  introduced  a  number  of  innovative  policy 
instruments and stringent goals to improve the quality and management of European water 
bodies. By providing a framework for a range of water-related legislation, the EU has created 
an  impressive  and  comprehensive  body  of  regulation  and  guidance.  The  results  of  the 
assessment  of  the  progress  towards  reaching  the  WFD  goals  and  implementing  its 
instruments  which  was  made  in  the  run  up  to  the  Blueprint,  however,  showed  significant 
gaps. While the progress was visible and rapid in the beginning with a reduction of pollution 
levels  as  a  result,  further  progress  has  been  limited.  Three  key  water-related  targets  are 
highlighted: 

1.  Water quality – successful policy design available, but implementation is 

lagging 

The assessment carried out in this study concludes that a successful policy design exists for 
reaching  water  quality  targets.  However,  implementation  is  lagging  behind  as  emission 
controls for point and diffuse sources still have to catch up with work on quality standards. 
The  Blueprint  comes  to  different  findings,  focussing  on  the  lack  of  information  about 
chemical status in river basins rather than on policy and implementation gaps. Consequently 
it proposes strengthening the enforcement of measures.  

42 EP (2014) Mapping the Cost of Non-Europe 2014-2019, July 2014 edition 
www.europarl.europa.eu/the-secretary-general/resource/static/files/files/2014-july---mapping-the-
cost-of-non-europe--en-.pdf 
43 With the Blueprint to Safeguard Europe's Water Resources published in 2012 the EC looked into the 
effectiveness, gaps in implementation of the WFD and potential solutions in four general areas – land 
use and ecological status, chemical status and pollution, water efficiency and vulnerability of EU waters 

28 

 
 
 
 
 
                                                 
Water Legislation 

2.  Water quantity – limited progress and incomplete implementation 

Our  findings  indicate  limited  progress  towards  established  water  quantity  targets  mainly 
due to incomplete implementation, typified by weak targets and tools. These issues could be 
tackled  by  promoting  better  policy  integration,  reinforcing  the  EU  resource  efficiency 
strategy,  and  strengthening  targets  and  tools.  The  Blueprint  reaches  similar  findings  and 
proposes a long list of actions to overcome the problems. The majority of actions would lead 
to  a  series  of  further  implementation  guidelines  for  the  WFD,  though  the  effectiveness  of 
guidelines is questionable.  

3.  Space – limited progress and incomplete implementation 

The  research  carried  out  for  this  study  has  confirmed  that  only  limited  progress  has  been 
made with regards to space related water targets. As with quantity targets, implementation 
remains incomplete and is hindered by weak targets and a lack of corresponding tools. These 
issues  could  be  tackled  by  promoting  better  policy  integration  into  other  sectoral  policies, 
reinforcing the EU resource efficiency strategy, and strengthening implementation tools. The 
Blueprint  offers  some  similar  findings  but  differs  in  that  it  does  not  consider  the  use  of 
economic  instruments  as  important  and  does  not  identify  the  lack  of  clarity  of  the  WFD 
targets  and  missing  WFD  measures  as  an  issue.  The  only  concrete  actions  proposed  are  a 
guidance  document  on  green  infrastructure,  enforcement  of  the  Floods  Directive  and 
Greening  the  CAP.  A  link  with  the  EU  Strategy  for  a  Resource  Efficient  Europe  is  not 
established in the Blueprint. 

Remaining challenges 

The reasons for the implementation gap in the WFD can be attributed to five main challenges: 

−  There  has  been  a  slow  and  incomplete  implementation  of  the  entire  framework  at 

Member State level.  

−  The  cost-effectiveness  of  Programmes  of  Measures  (PoMs)  is  not  always  clear  and  it 
can be assumed that it is difficult to attract funding for large scale restoration projects.  
−  There  are  insufficient  linkages  between  the  River  Basin  Management  Plans  (RBMPs) 
and other policy domains and legislation such as agriculture and flood management.  

−  A gap in the deployment of EU-level instruments to control emissions of pollutants. 
−  There  is  weak  overall  integration  between  water  protection  and  energy  and 
agricultural  policy  resulting  in  some  counter-productive  policy  measures  and 
instruments. 

Policy recommendations for potential future EU policy actions 

Our analysis identifies the following promising areas for further water policy action:  

1.  Strengthen EU-wide emission controls for pollutants vis-à-vis water quality standards; 

2.  Reduce  water  and  energy  use  via  water-related  eco-design  standards  (for  shower  heads 
and water taps), while promoting water metering to improve progress on water quantity 
targets; and 

3.  Improve  PoMs  and  EU  coordination  to  support  floodplain  restoration  to  further  space-

related water targets. 

29 

 
 
 
 
 
 
Cost of Non-Europe Report 

These  proposed  actions  would  need  to  happen  in  combination  with  improving  policy 
integration  at  EU  and  national  levels  in  order  to  achieve  better  implementation.  This  study 
does not cover improving policy integration in detail.  

We have produced approximate estimates of costs and benefits to indicate the potential scale 
of  these  actions.  It  should  be  stressed,  however,  that  these  are  extrapolations  based  on 
various assumptions and should be treated with caution. It should also be noted that related 
estimates (for pharmaceuticals) have not been quantified. 

Potential  total  benefits  of  additional  EU  policy  measures  for  the  period  2015-2030  could 
amount to: 

− 

− 

− 

€248.9  billion  savings  from  replacing  old  shower  heads  and  water  taps  with  more 
efficient  ones,  due  to  reduced  water  and  energy  bills  under  today’s  EU  average 
prices. Equivalent to €2.2 billion per year; 

€43.5  billion  savings  if  one-third  of  EU  households  install  water  meters  due  to 
reduced water and energy bills under today’s EU average prices. Equivalent to €0.4 
billion per year ; and 

€295  billion  benefits  from  restoring  8.8  ha  of  floodplains  across  Europe  –  highly 
variable  across  Europe  and  mainly  resulting  from  reduced  flood  risk  management 
and  water  treatment  costs  and  from  increased  income  from  leisure  and  tourism 
activities. Equivalent to €39.3 billion per year in 2030. 

These benefits can only be achieved if the necessary investments to implement the measures 
are also made. Estimates for these investments are presented below: 

− 

− 

− 

€16.9 billion total costs (2015-30) for the higher price of more efficient shower heads 
and water tap. Equivalent to €1.0 billion per year ; and 

€18.9 billion total costs (2015 -30) for installing water meters in one-third of European 
households. Equivalent to €0.2 billion per year; 

€362  billion  investment  needs  for  realising  the  restoration  of  8.8  ha  of  floodplains 
which includes land purchase and infrastructure works and is highly variable across 
the EU. Equivalent to €24.1 billion per year. 

30 

 
 
 
 
 
 
 
 
Water Legislation 

1.  Introduction and method 

This chapter presents the objectives of this study, the structure of this report  
and a description of the methodology. 

This  is  the  Final  Report  of  the  “Study  on  Existing  and  Future  EU  Water  Legislation”.  The 
overall objective of this study was to carry out a combination of a backward looking (ex-post) 
and forward looking (ex-ante) evaluation of European water legislation. The emphasis is on 
the  ex-post  aspect,  mainly  because  of  the  need  to  check  the  level  of  implementation  of 
existing  legislation.  The  ex-ante  aspect  aims  at  assessing  the  potential  costs  and  benefits  of 
further intervention at EU level, along the lines of the approach adopted for other sectors and 
reported in the ‘Mapping the Cost of Non-Europe, 2014 -19’ report.44  

In  line  with  the  objectives  described  above,  this  report  is  divided  into  two  main  parts.  The 
first part focuses on delivering the ex-post type impact assessment – identifying policy areas 
and  tools  as  well  as  the  main  water  status  elements  and  assessing  the  implementation 
progress,  effectiveness  and  coverage  of  the  existing  body  of  legislation.  The  second  phase 
builds  on  the  first  phase  to  consider  the  costs  and  benefits  of  additional  potential  EU-level 
legislation (or other action) to address any identified gaps.  

This report is structured as follows: 

−  Chapter 1 presents the approach and methods used; 
−  Chapter  2  contains  the  Ex-post  Impact  Assessment  of  existing  water-related 

legislation; 

−  Chapter  3  covers  an  assessment  of  the  potential  costs  and  benefits  of  additional 

European level interventions (cost of non-Europe); and 

−  Chapter 4 presents an overall conclusion summarising progress to date and potential 

future options. 

1.1.  Approach and method 

This section briefly explains the approach taken in this study and the 
methodologies applied to carry out the assessment. 

The  primary  source  of  information  for  this  study  has  been  an  extensive  literature  review, 
covering  EU  documentation  as  well  as  external  studies  and  assessments  from  research 
bodies,  NGOs,  etc.  Annex  C  provides  an  overview  of  the  reviewed  literature.  In  order  to 
supplement  and  help  us  to  critically  assess  this  literature  we  also  carried  out  a  relatively 
small  number  of  targeted  interviews  with  an  expert  group  consisting  of  selected  experts 
representing  a  variety  of  perspectives.  10  interviews  were  conducted  between  18  July  2014 

44EP (2014) Mapping the Cost of Non-Europe 2014-2019, July 2014 edition 
http://www.europarl.europa.eu/the-secretary-general/resource/static/files/files/2014-july---
mapping-the-cost-of-non-europe--en-.pdf 

31 

 
 
 
 
 
 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

and  25  September  2014  with  senior  representatives  from  environmental  NGOs,  the  water 
industry, the pharmaceutical industry, water authorities and water experts (see Annex B).The 
experts  were  selected  in  order  to  gain  the  maximum  relevant  (for  our  study)  breadth  and 
depth  of  knowledge  from  a  small  group.  Their  opinions  and  input  has  been  incorporated 
throughout this report and is referenced via footnotes. 

1.1.1.  Phase I 

Phase  I  sets  out  to  analyse  the  overall  body  of  EU  policy  and  legislation  relating  to  water. 
This  analysis  is  intended  to  assess  the  extent  to  which  this  policy  and  legislation  have 
properly identified the main challenges and considered all relevant options. The analysis also 
considers the level of progress achieved by the key Directives and policies.  

In order to address these broad objectives the chapter is structured as follows: 

1.  The  structure  of  the  water-related  EU  law  and  the  main  pieces  of  legislation  is 
described  along  with  an  identification  of  the  main  policy  areas  and  the  criteria  by 
which the status of the water environment is judged. 

2.  A discussion of the availability of impact data, in particular data relating to costs and 

benefits. 

3.  An  assessment  of  the  progress,  effectiveness  and  coverage  of  the  existing  water 
legislation–  via  a  literature  review  of  material  such  as  impact  assessments, 
evaluations, and other analytical reports. The progress assessment is presented under 
the following two categories: 

o  Policy  areas  and  tools:  analysing  regulations  and  policy  related  to  human 

safety and environmental protection. 

o  Water  status  elements:  reviewing  regulations  and  policy  regarding  water 

quality, quantity and morphology. 

4.  An assessment of the coverage of existing water legislation, with gaps identified. 

5.  Conclusions  on  the  progress  and  coverage  of  the  most  important  EU  water-related 

regulations and policies. 

1.1.2.  Phase II 

The model for our approach in Phase II is the ‘Cost of non-Europe’ report.45 The basis of our 
approach is to assess the potential for additional European level action to address a number 
of perceived shortcomings in water related policy. Wherever possible, we have assessed the 
economic  costs  and  benefits  of  this  additional  EU-level  action  and  provided  a  qualitative 
assessment of the key issues. 

The approach for Phase II is divided into the following steps: 

−  Step  1  –  Identify  promising  areas  for  further  assessment  -  based  on  the  analysis  carried 
out under Phase I, five cases from five topics mentioned in the ToR are selected for 
further research. For each of these case studies, we then apply the following steps: 

45 EP (2014) Mapping the Cost of Non-Europe 2014-2019, July 2014 edition 
www.europarl.europa.eu/the-secretary-general/resource/static/files/files/2014-july---mapping-the-
cost-of-non-europe--en-.pdf 

32 

 
 
 
 
 
                                                 
Water Legislation 

−  Step  2  –  Describe  the  problem  and  policy  context  -  describe  the  policy  context  and 
background,  intervention  logic,  and  state  of  European  harmonisation,  building  on 
the empirical findings from Phase I to defend the selection of the case. 

−  Step 3 – Develop a baseline scenario- Wherever possible and deemed relevant, the costs 
are  expressed  in  monetary  terms.  However,  we  also  acknowledge  that  “costs”  is  a 
multi-facetted  expression  and  has  relevance  to  a  number  of  aspects  of  a  problem. 
Furthermore,  straightforward  cost  data  are  not  available  for  all  issues  and  Member 
States, while transaction costs are of greater importance for other issues such as the 
organisation of river basin management. Hence, this task will result in a simple base-
line  scenario  where  the  current  situation  is  clearly  described  and  costs  estimated  to 
the furthest and most appropriate extent possible in order to identify costs incurred 
by  citizens,  society  and  stakeholders  due  to  gaps  and  fragmentation  in  the  policies 
and legislation. 

−  Step 4 – Determine potential and effects of EU coordination - the potential for improved 
coordination  at  EU  level  and  the  type  and  size  of  synergies  this  would  yield  are 
estimated. Based on the data from the previous task and the base-line scenario, a new 
scenario is developed to understand the potential benefits of additional action at EU 
level.  The  comparison  between  the  baseline  scenario  and  the  new  “added  value” 
scenario  is  used  to  answer  the  following  question:  What  are  the  efficiency  gains,  in 
economic  terms  or  otherwise,  from  further  European  action  to  overcome  the  gaps, 
reduce fragmentation and further harmonise of the EU water policy and legislation? 
An MS-led approach is also considered. 

−  Step 5 – Synthesise findings - The aim is to answer the following questions (as per the 

ToR):  

a.  What are the existing gaps that can be addressed through better application 

and implementation of the existing legislative framework?  

b.  What are the costs in monetary terms of the infrastructure necessary to 

overcome these gaps?  

c.  What are the costs of actions required to reduce fragmentation in, and further 

harmonising, EU water legislation? 

33 

 
 
 
Cost of Non-Europe Report 

2.  Phase I - Ex-post Impact Assessment 

This chapter provides a review of the extent to which the existing body of EU 
water legislation addresses water related concerns and issues in Europe. 
Progress and impact of the existing water legislation is also assessed. 

The  EU  has  a  40-year  record  of  developing  its  water  policy.  The  first 25  years  resulted  in a 
patchwork  of  legislation,  covering  different  human  uses  and  parts  of  the  aquatic 
environment  and  putting  in  place  quality  standards  and  emission  controls  as  well  as 
monitoring  and  management  requirements.  Over  the  past  14  years  the  policy  has  been 
fundamentally  reorganised  as  a  result  of  the  Water  Framework  Directive  (WFD),  which 
entered into force in 2000. It requires river basin planning and management and sets a very 
broad  and  ambitious  long-term  target  for  water  protection  –  achieving  ‘good  status’. 
Fourteen years later, and less than one year away from the deadline for achieving the general 
objective of the WFD, i.e. achieving “good” status for all water bodies, the challenge faced by 
the  EU  remains  immense.  To  address  this  challenge,  the  European  Commission  has  put 
forward  its  proposals  for  the  future  in  the  “Blueprint  to  Safeguard  Europe’s  Water 
Resources”, with a clear emphasis on better implementation of water policy. 

In this phase we look into the work feeding into the Blueprint and other (non-EC) sources in 
order  to  assess  the  general  structure  and  progress  of  the  water  legislation  in  the  EU,  while 
seeking to verify the findings from the Blueprint. 

2.1.  The structure of water-related EU law 

This section sets the scene and defines the scope and areas of existing 
legislation. With regard to the scope of legislation it is useful to consider two 
water ‘cycles’ - the human cycle (small) and the hydrological cycle (large). 
For the areas of legislation we use a policy diagram, which places the Water 
Status, as defined by the WFD, in the centre with policies related to the 
different elements of water status - quality, quantity and morphology – 
around the centre. 

2.1.1.  Overview of water-related EU legislation 

The  2000  Water  Framework  Directive  (WFD)  is  arguably  the  most  overarching  piece  of  EU 
water legislation. It sets long-term and ambitious objectives for managing and improving the 
entire aquatic environment, and establishes requirements for integrated and transparent river 
basin  management.  More  specific  pieces  of  legislation  dealing  with  particular  aspects  of 
water  management  or  use  have  been  passed  both  before  and  after  the  WFD.  The  following 
table  shows  key  EU  legislation  in  chronological  order,  together  with  key  objectives.  More 
detail on each piece of legislation is available in the Factsheets provided in Annex A. 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
Water Legislation 

Table 1: Overview of EU water-related legislation 

Year 

Policy 

Scope / Tools 

Main objectives 

Water-specific legislation 

1976 

1976 

1980 

Dangerous  Substances  Directive  76/464/EEC 
repealed by WFD and PS/EQS Directives 
Bathing  waters,  last  amended  by  DIRECTIVE 
2006/7/EC  concerning  the  management  of 
bathing water quality and repealing Directive 
76/160/EEC (BWD) 
Drinking  water  quality, 
last  amended  by 
DIRECTIVE  98/83/EC  on  the  quality  of  water 
intended for human consumption (DWD) 

1980  Groundwater  protection  last  amended  by 
DIRECTIVE  2006/118/EC  on  the  protection  of 
and 
groundwater 
deterioration (GWD) 
DIRECTIVE  91/271/EEC  concerning  urban 
waste water treatment (UWWTD) 

pollution 

against 

1991 

1991 

2000 

2007 

concerning 

91/676/EEC 

establishing 

2000/60/EC 

DIRECTIVE 
the 
protection of waters against pollution caused 
by nitrates from agricultural sources (Nitrates 
Directive) 
DIRECTIVE 
a 
framework for Community action in the field 
of  water  policy  (WFD)  and  amended  and 
complemented  by  the  following:  DECISION 
list  of 
No2455/2001/EC  establishing  the 
priority substances in the field of water policy 
(PS) 
and  DIRECTIVE  2008/105/EC  on 
environmental  quality  standards  in  the  field 
of  water  policy  (EQS),  further  amended  by 
DIRECTIVE  2013/39/EU  as  regards  PS  in  the 
field of water policy 
DIRECTIVE  2007/60/EC  on  the  assessment 
and  management  of  flood  risks  (Floods 
Directive) 

Surface water/ 
Emission controls  
Human use/ Quality 
standards and RBM 

Human 
consumption/ 
Quality standards 

Groundwater/ EQS  
and Emission 
controls  

Waste water 
collection and 
treatment/ Emission 
controls and 
identification of 
vulnerable areas 
Agricultural/ 
Emission controls 
and identification of 
vulnerable zones 
All aspects of the 
water cycle/ RBM, 
economic 
instruments, EQS, 
emission controls 

All water uses/ 
planning  

2007 

COM  [(2007)  414]  Addressing  the  challenge 
of  water  scarcity  and  droughts 
in  the 
European Union (WS&D) 

All water uses 

Important non water-specific but related legislation 

-  Eliminate pollution by dangerous substances 

-  To preserve, protect and improve the quality 

of the environment and  

-  To protect human health by complementing 

WFD with regard to bathing water 

-  To protect human health from the adverse 
effects of any contamination of water 
intended for human consumption by ensuring 
that it is wholesome and clean 

-  To establish specific measures to prevent and 

control pollution of groundwater 

-  To complement the WFD on the provisions 
preventing or limiting inputs of pollutants 
-  To protect the environment from the adverse 
effects of urban waste water discharge and 
treatment and of biodegradable industrial 
waste water from the agro-food sector 

-  To reduce water pollution caused or induced 

by nitrates from agricultural sources 

-  To prevent further such pollution 

-  To prevent further deterioration and protect 

and enhances the status of the aquatic 
ecosystems  

-  To promote sustainable water use 
-  To reduce / cease emissions of priority / 

priority hazardous substances 

-  To mitigate the effects of floods and droughts 

-  To establish a framework for the assessment 
and management of flood risks, aiming at the 
reduction of the adverse consequences for 
human health, the environment, cultural 
heritage and economic activity 

-  To present policy options at EU, national and 
regional levels to address and mitigate the 
effects of water scarcity and droughts 

1979 

1985 

1992 

2009 

and 

85/337/EEC 

Directive  79/409/EEC  and 
latest  version 
Directive 2009/147/EC on the conservation of 
wild birds (Birds Directive) 
subsequent 
Directive 
amendments  on  the  assessment  of  the 
effects  of  certain  public  and  private  projects 
on the environment (EIA Directive) 
Directive  92/43/EEC  on  the  conservation  of 
natural  habitats  and  of  wild  fauna  and  flora 
(Habitats Directive) 
DIRECTIVE 
a 
framework  for  the  setting  of  ecodesign 
requirements  for  energy-related  products 
(Ecodesign  Directive)  and  its  implementing 
regulations e.g. 

2009/125/EC 

establishing 

Nature conservation 

-  To protect species of wild birds in the EU 

Environmental 
protection 

-  To set requirements for mandatory 

Environmental Impact Assessment (EIA) for 
certain projects 

Nature conservation 

-  To ensure biodiversity through 

All water uses 

-  To set ecodesign requirements for energy-

conservation of natural habitats and wild 
fauna and flora in the EU 

using products (EuPs)  

-  To provide for criteria and conditions for 
the setting of ecodesign requirements 
which the regulated EuPs must fulfil in 

35 

 
 
 
Cost of Non-Europe Report 

Year 

Policy 

Scope / Tools 

Main objectives 

(EU)  No  1015/2010 

REGULATION 
(...) 
implementing  Directive  2009/125/EC  with 
regard 
for 
household washing machines 

to  eco-design 

requirements 

Domestic water use 

order to be placed on the market 
-  To increase energy efficiency and the 

security of energy supply 

-  To establish ecodesign requirements for the 
placing on the market of electric mains-
operated household washing machines 
including requirements for the water 
consumption 

Source: Authors’ own analysis 

2.1.2.  The water cycle– defining policy areas and tools 

In  order  to  assess  the  policy  areas  and  instruments  it  is  useful  to  consider  the  natural  and 
human water cycles. The former covers the hydrological cycle (precipitation, infiltration, flow 
and runoff and evaporation) and the related natural processes within a water system (water 
quality,  erosion  and  sediment  and  chemical  transport).  The  human  cycle  describes  the 
anthropogenic  use  of  water  (abstraction,  use  and  discharge)  and  is  often  called  the  small 
cycle.  The  following  diagram  summarises  these  two  water  cycles  and  indicates  the  main 
pieces  of  legislation  and  policies  that  relate  to  these  cycles.  The  illustration  shows  that  the 
majority  of  ‘old’  EU  water  legislation  is  concerned  with  the  human  water  cycle  addressing 
human  health  directly  and  indirectly  through  resource  protection  by  combining  quality 
standards  and  emission  controls.  The  WFD  broadens  the  scope  of  EU  water  policy  to  the 
hydrological cycle, strengthens environmental objectives and introduces new tools including 
river  basin  planning  and  economic  instruments  aiming  at  achieving  a  more  efficient  use  of 
water and thus reducing water use. 

Figure 1: Illustration of the water cycle 

Source: Authors’ own analysis 

36 

 
 
 
 
 
 
Water Legislation 

The main policy areas and related policy instruments can be classified as follows: 

1.  Human  safety:  setting  standards  for  human  use,  i.e.  BWD,  DWD;  supporting 
protection  of  water  resources  through  emission  controls  and  quality  standards,  i.e. 
WFD, UWWTD, Nitrates, GWD, PS&EQS; reducing risks from floods and droughts, 
i.e. WFD, Floods Directive, WS&D. 

2.  Environmental protection: setting emission controls and quality standards, i.e. WFD, 
UWWTD, Nitrates, GWD, PS&EQS; reduce resource use (i.e. amount of land, water, 
energy and material use46,47), i.e. WFD requirements and instruments to protect and 
restore hydromorphology and increase efficiency of water use and Ecodesign. 

2.1.3.  The “Water Status” approach 

In  order  to  assess  the  overall  coverage  of  water-related  EU  law,  we  have  decided  to  use 
‘Water Status’ as defined by the WFD. This provides a new and comprehensive approach for 
addressing all water issues. The “water status” is defined for surface water by its ecological 
and chemical status and for groundwater by the quantitative and chemical status (WFD, Art 
2.17 and 2.19). The ecological status is defined as an expression of the quality, structure and 
ability to function of aquatic ecosystems (WFD Art 2.21) and is determined by its biological 
quality  as  supported  by  hydromorphological  and  chemical  /  physico-chemical  quality 
elements (WFD, Annex V). 

This  system  of  status  definitions  can  be  simplified  to  the  following  three  elements,  which 
determine overall water status:  

-    Quality(chemical and physico-chemical), determined by the level of anthropogenic 
emissions,  including  heat,  nutrients,  pesticides,  industrial  chemicals  and  micro 
pollutants, like pharmaceuticals which are present; 

-   

 Quantity  (Hydrology),  the  flow  regime  and  quantity  of  water  available,  which  is 
altered by  water abstraction and consumption, water level regulation (dams, weirs) 
or changes to natural water retention capacities (land sealing and drainage); and 

-    Space  (Morphology),  the  structure  of  the  river,  its  bed  and  riparian  zone  (i.e.  river 
banks),  which  is  changed  by  reducing  available  space  (using  flood  plains  for 
settlement or agriculture), altering connectivity of ground and surface waters (canals, 
culverts),  the  connectivity  between  the  river  and  adjacent  land  (dykes  and  levees) 
and the up and down stream connectivity (dams). 

These three elements are the main drivers for water status, determining whether the WFD’s 
objective  of  good  ecological,  good  chemical  and  good  quantitative  status  for  the  different 
types of waters, rivers, lakes, coastal, transitional and groundwater can be achieved. 

As  illustrated  by  figure  2  below,  the  majority  of  EU  water  policies  address  the  chemical 
quality  (DWD,  UWWTD,  GWD,  PS&EQS,  BWD,  Nitrates  Dir.,  WFD  Art  11  and  16),  either 

46 Sustainable Europe Research Institute (2009); How to measure Europe’s resource use - An analysis for 
Friends of the Earth Europe. 
47 EC [COM (2011) 571 final] Roadmap to a Resource Efficient Europe 

37 

 
 
 
 
 
                                                 
Cost of Non-Europe Report 

through EQS or emission controls. There are only a few, relatively new, policies addressing 
quantitative  aspects  (WFD  Art  9  and  11,  WS&D,  Floods  Directive).  Space  and  structure  are 
only  addressed  by  the  Floods  Directive  and  the  Programmes  of  Measures  (PoMs),  which 
require controls over activities that adversely impact hydromorphological conditions (WFD, 
Art 11.3i). It also requires the recovery of costs for water services, which includes changes to 
the morphology, for example dams and dykes, to store water and change flow levels (WFD 
Art 9).  

The  PoMs,  as  required  by  the  WFD,  address  all  water  status  elements.  Nevertheless,  the 
mandatory  (basic)  measures  set  out  by  the  WFD  are  less  prescriptive  with  regard  to 
hydrology  and  morphology  (‘general  binding  rules’),  compared  to  measures  to  control 
abstractions  and  impoundment  (registers  and  prior  authorisations)  and  measures  against 
pollution (prior authorisation and prohibition) (see also chapter 3.2.1).48 

The outer circle represents the sectors which are the main sources of pressure on water status 
and whose policies can conflict with water protection objectives. A detailed analysis of such 
conflicts is beyond the scope of this study. However this is an important issue and we have 
provided a brief description of arguably the most significant examples in order to illustrate 
this point and to highlight the importance of better policy integration49: 

-    Agriculture: Agricultural activities, which receive nearly 40% of the EU budget, are 
mentioned in 90% of RBMPs as the main cause of significant impact on water quality 
and  quantity.50  In  their  recent  assessment  the  European  Court  of  Auditors  (ECA) 
concluded  that  while  cross-compliance  and  the  rural  development  fund  have  a 
positive  impact  on  water  protection,  they  are  limited  compared  to  the  ambitious 
goals,  and  recommended  modifying  EU  policies  and  better  integrating  these  with 
RBMPs.51 

-    Energy:  Energy  production  impacts  water  status  in  many  ways.  Dams  for  hydro-
power  generation  and  storage  prevents  fish  migration  and  sediment  transport, 
cooling  towers  for  thermal  power  production  consume  water  and  cause  heat 
pollution.  Coal  fired  power  stations  emit  mercury  which  deposits  in  water,  and 
increased  production  of  biofuels,  like  producing  diesel  from  rapeseed  or  gasoline 
from  maize,  increase  nutrient  and  pesticide  pollution.  The  EU’s  climate  and  energy 
policy has a major impact on those developments. There is a risk that specific policies 
can  lead  to  a  further  increase  in  conflicts,  by  focussing  funding  and  activity  on 
supply  infrastructure  or  specific  energy  sources,  i.e.  renewable  energy  in  transport. 
However  the  reverse  can  also  be  true,  with  certain  policy  choices  fostering  better 
integration, usually by increasing energy efficiency. 52  

48 See WFD Article 11.3, list of mandatory measures – based on own assessment of this list 
49 Interviews with Peter Gammeltoft (23/7/14), Thomas Dworak (18/7/14), EEB (5/9/14) and Pierre 
Strosser (25/9/14) and own Blueprint assessment 
50 European Commission (2012), Impact assessment accompanying the Blueprint SWD 2012/382, page 6. 
51 European Court of Auditors (2014), Special Report (No 4/2014): "Integration of EU water policy 
objectives with the CAP: a partial success" 
52 IEA 2013, Energy Efficiency Market Report 

38 

 
 
 
 
                                                 
Water Legislation 

Figure 2: Illustration of assessment of EU water policy structure  
against water status elements 

Source: Stefan Scheuer Consulting 2014 

Despite  the  complexity  in  describing  the  status  of  bodies  of  waters  in  accordance  with  the 
technical  requirements  of  the  WFD53,  progress  has  been  made  and  water  status  maps  have 
been  published  and  are  almost  complete  for  all river  basin  districts.54 Our  literature  review 
and  expert  interviews  did  not  identify  major  issues  with  the  status  maps,  although  status 
classification  of  bodies  of  water  had  been  challenged,  for  example  the  Cholorphyll-a 
concentrations set in the Elbe river basin district55, and general weaknesses regarding the EU 
wide calibration of status classification methods have been identified. 56 Recent data indicate 
that over 50% of water bodies are failing to achieve Good Status57 and that pressures on the 

53 CIS WFD guidance documents: N° 4 - Identification and Designation of Heavily Modified and 
Artificial Water Bodies; N° 5 - Transitional and Coastal Waters - Typology, Reference Conditions and 
Classification Systems; N° 6 - Towards a Guidance on Establishment of the Intercalibration Network 
and the Process on the Intercalibration Exercise; N° 10 - Rivers and Lakes - Typology, Reference 
Conditions and Classification Systems; N° 13 - Overall Approach to the Classification of Ecological 
Status and Ecological Potential; N° 14 - Guidance on the Intercalibration Process (2004-2006) 
54 EC [SWD (2012) 382 final]]SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources–part 2, page 14 
55 EEB 2010, 10 years of the Water Framework Directive: A Toothless Tiger? - A snapshot assessment of 
EU environmental ambitions 
56 EEB, RSPB and Pond Conservation (2006) NGO Technical Review of the Water Framework Directive 
Intercalibration Process 
57 EC [SWD (2012) 382 final]SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources–part 1, page 12 

39 

 
 
 
                                                 
Cost of Non-Europe Report 

hydrology  and  morphology  (hydro-morphology)  are  the  most  significant  reasons58  behind 
this situation. As a result of this new assessment waters which had been classified as good a 
decade  ago  are  now  classified  as  below  good.  This  is  illustrated  in  the  figure  below,  which 
compares  the  former  assessment  results  in  North-Rhine-Westphalia  based  on  the  common 
indicators regarding waste water discharges with a new indicator which shows the impact of 
morphological  changes.  As  can  be  seen  the  second  diagram  shows  a  much  larger  share  of 
river in red, orange and yellow – indicating quality levels below good. 

This is not surprising as the attention of water policies in the EU and Member States has been 
focused  on  improving  the  chemical  quality  (with  some  success),  while  hydrology  and 
morphology are closely linked to quantitative resource use and allocation policies, like land, 
energy, material and water, which are driven by general economic developments and sector 
policies much more than water policies. In addition EU competencies are limited in those areas. 

The Blueprint accordingly highlights the importance of better integration of water concerns 
into other policies as being a key factor required in order to make progress. 

Figure 3: Water status assessment, North-Rhine-Westphalia, 2010  

Saprobiean indicator in use for 50 years,  
sensitive to urban waste water discharges. 

58 EC [SWD (2012) 382 final]SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources–part 2, page 6 

40 

 
 
 
 
 
 
 
                                                 
Water Legislation 

Macrozoobenthos indicator sensitive to structural changes 

Source: Landesamt für Natur, Umwelt und Verbraucherschutz Nordrhein Westfalen,  
“Der Zustand der Gewässer in Nordrhein Westfalen” available at 
www.umwelt.nrw.de/umwelt/pdf/monitoring.pdf 

2.2.  Assessment of progress in the different areas and use of tools 

This assessment relies primarily on the factsheets that have been developed 
during the review of existing legislation and water-related policies (see 
Annex A for more details and all data sources and references). It presents 
general progress both in terms of monitoring and reporting and attainment 
of objectives. 

2.2.1.  Policy areas where significant progress has been achieved – human health 

protection 

  shows that the EU has made good progress concerning human health protection by 

setting EU quality standards 

Our  initial  assessment  of  the  achievements  to  date  and  implementation  progress  indicates 
that the highest compliance rates are achieved for the DWD and the BWD – with at least over 
90%  compliance  with  the  quality  standards  set  in  the  respective  directives.  An  increasing 

41 

 
 
 
 
 
Cost of Non-Europe Report 

number  of  water  bodies  even  achieve  “excellent  quality”  status,  defined  as  99-100% 
compliance with the quality standards.  

2.2.2.  Policy areas where mixed progress has been achieved – emissions controls 

and quality standards 

  Shows that there is mixed progress in using emission controls and quality standards 

affecting environmental protection but also human safety. 

Compliance  with  the  UWWTD  is  high  for  the  pre-2004  Member  States  (around  90%)  but 
lower  for  the  newer  ones,  especially  regarding  secondary  and  more  stringent  waste  water 
treatment (compliance rates are around 40% and 14% respectively).The newer Member States 
are also subject to other implementation deadlines and are so far reported to be on track.With 
regard to pollution, a 2011JRC report59 concluded that the total nitrogen pollution  from the 
land  to  the  sea  had  decreased  by  9%,  while  the  total  phosphorus  load  had  decreased  by 
around 15% in 2005 compared to 1991, mainly due to a decrease in point source emissions. 
The  high  decrease  observed  in  the  North  and  Baltic  Seas  was  mainly  related  to  the 
implementation of advanced waste water treatment. To a large extent the improvement in the 
quality  of  EU  bathing  waters  in  recent  decades  is  due  to  the  implementation  of  UWWTD 
provisions. 

The  large  majority  of  Member  States  have  also  achieved  good  progress  with  regard  to  the 
GWD. Almost all EU countries have reported on the establishment of threshold values in the 
required  format  either  using  drinking  water  standards  or  relevant  international  or  national 
standards  as  the  basis.  More  than  half  of  the  Member  States  (56  %)  have  also  considered 
environmental  quality  objectives  –  international  (e.g.  EQS  Directive)  or  national  standards. 
By  area,  about  25  %  of  groundwater  across  Europe  is  classified  as  being  in  poor  chemical 
status. Of the total number of groundwater bodies reported in the RBMPs, 6.4 % are classified 
as being in poor quantitative status. Nonetheless, by 2015, almost 90% of groundwater bodies 
are forecast to be in good chemical status and 96 % in good quantitative status.60 

The transposition and implementation of the Floods Directive is also reported to be on track 
with the first flood risk management plans expected in 2015. Nonetheless, this is a relatively 
new  directive  and  so  far  only  its  transposition  can  be  assessed.  Progress  towards  the 
directive’s objectives cannot currently be evaluated.  

2.2.3.  Policy  areas  where  progress  is  lagging–  diffuse  and  unknown  pollution 

and resource use 

  Shows progress lagging in using emission controls to reduce diffuse pollution and in 

reducing resource use and lack of information on chemical quality affecting 
environmental protection and human safety. 

Implementation  of  other  water  policy  legislation  appears  to  have  progressed  at  a  much 
slower  pace.  There  are  major  delays  in  implementation  or  clear  divergence  from  intended 
goals and lack of achievement. 

59 JRC (2011) Long term nutrient loads entering European seas 
60 EEA (2012) European waters — current status and future challenges Synthesis, page 21 

42 

 
 
 
 
 
 
 
                                                 
Water Legislation 

Regarding the overall objective for EU water policies as set by the WFD – ‘good status’, over 
50%  of  water  bodies  are  expected  to  fail  to  achieve  the  good  status  objective  by  2015.  The 
EAA  (2012)61  reports  that  almost  50%  of  Europe's  surface  waters  are  likely  to  be  in  a  poor 
ecological  status  by  2015.  The  picture  is  more  difficult  to  assess  for  chemical  status  as  this 
status  is  not  known  for  more  than  40%  of  Europe's  surface  waters.  Nevertheless,  by  2015 
more  than  90%  of  Europe's  groundwater  is  expected  to  be  in  good  status  in  terms  of  both 
quantity and quality. Analysis of the pressures causing poor status shows that 30% - 50% of 
the  surface  water  bodies  are  affected  by  diffuse  pollution  (principally  due  to  agriculture). 
More  than  40%  of  the  river  and  coastal  water  bodies  are  affected  by  diffuse  sources,  whilst 
20–25%  of  them  are  also  subject  to  'point  source'  pollution.  Lack  of  ambition  of  relevant 
policies as well as hydro-morphological pressures (e.g. abstraction, land use, flow regulation 
and  dykes)  are  reported  as  the  main  reasons  behind  this  failure  to  achieve  good  ecological 
status.62 

The  WFD  allows  exemptions,  delays,  setting  lower  objectives  or  status  deterioration,  under 
certain  conditions.  The  justification  of  criteria  applied  for  the  exemptions  provided  in  the 
RBMPs  has  been  criticised  as  generally  lacking  transparency,  ‘indicating  a  degree  of 
arbitrariness  in  their  application’.63  To  date  compliance  with  regard  to  the  adoption  and 
submission  of  RBMPs  is  relatively  low,  with  only  70%  of  the  expected  reports  submitted. 
Furthermore,  not  many  of  the  submitted  RBMPs  contain  provisions  for  flood  risk 
management  or  water  scarcity  and  drought  (WS&D).  However,  the  reporting  deadline  for 
flood risk management plans is not until 2015, and there are only guidelines, as opposed to 
binding provisions on WS&D. A further impediment is posed by the lack of synchronisation 
between the RBMPs reporting cycle under the WFD and the reporting cycles under the older 
directives – the UWWTD and the Nitrates Directive.  

Improved  environmental  quality  monitoring  and  an  upward  compliance  rates  are  reported 
for the Nitrates Directive. Between 2008 and 2011 the concentration of nitrates only exceeded 
the  threshold  value  in  14%  of  the  reported  groundwater  bodies.  This  indicates  a  slight 
improvement  compared  to  the  previous  reporting  period.  However,  the  designation  and 
protection of nitrate vulnerable waters remains incomplete and eutrophication (the excessive 
growth of plants/algae in water caused by nitrates pollution), in particular of marine waters, 
is a significant problem. Another challenge is posed by the lack of synchronisation  between 
the reporting periods under the Nitrates directive and the RBMPs of the WFD. 

implementation  of  all  seven  areas  defined 

in  the  guidelines  of  the  WS&D 
The 
Communication is reported as being limited. The EEA64 reports that there is an imbalance in 
much of Europe's surface waters with water use often exceeding water availability, leading to 
water  stress  across  much  of  Europe.  Water  scarcity  is  reported  for  nearly  all  river  basin 
districts in the Mediterranean area. 

61 EEA (2012) European waters — current status and future challenges, Synthesis 
62 EC [SWD (2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources– part 1, chapter 2.5.1 and 
part 2, page 6. 
63 Ibid (part 1) chapter 2.5.1, page 21 
64 EEA (2012) European waters — current status and future challenges Synthesis, page 9 

43 

 
 
 
 
 
                                                 
Cost of Non-Europe Report 

The implementation of some more recent directives is hard to assess either due to their recent 
adoption  or  lack  of  reporting.  For  example,  the  EQS  Directive  is  still  being  implemented  – 
Member States have until September 2015 to transpose the directive. However, the chemical 
status  of  40%  of  surface  waters  remains  unknown,  implying  insufficient  monitoring  on  MS 
level. Furthermore, the effects of emerging pollutants are not yet known. 

2.3.  Assessment of the effectiveness in addressing water status drivers 

This section assesses the effectiveness of existing EU legislation in 
addressing the drivers of water status and highlights the conflicts with 
sector policies according to the approach set out in Figure 2 using 
information gathered for chapter 2.2 and via interviews. 

2.3.1.  Effectiveness of improving water quality 

The EU has put in place numerous quality standards as well as emission controls, which have 
been effective in principle in reaching their specific targets, as can be seen from the progress 
in bathing and drinking water protection and to some extent in reducing pollution caused by 
urban waste water (see chapters 2.2.1 and 2.2.2). The main reasons for these successes are: 

•  Limited number of pollutants and emission sources; and 
•  Focus on human health effects. 

However,  as  soon  as  the  number  of  pollutants  to  be  considered  increases,  or  multiple 
emission  sources  are  involved,  progress  appears  limited  (see  chapter  2.2.3).This  suggests 
ineffective policy design and/or policy conflicts. 

In terms of policy conflicts, pollution from agricultural use of pesticides and fertilisers, run –
off  from  transport  infrastructure  and  air  pollution  is  a  well-studied  and  understood 
problem.65 

With regard to ineffective policy design, there are noticeable difficulties in tackling pollution 
at the national level.  

WFD implementation is incomplete (see chapter 2.2.3) either due to insufficient monitoring of 
pollutants or missing national quality standards, in cases where no EU-level standards have 
been  set.  Problems  with  the  implementation  of  WFD  Article  16  (combined  approach  for 
setting EQS and emission controls) have been identified.66 So far it has only led to the setting 
of EQS but no additional EU emission controls were directly delivered as a consequence of 
water  protection  needs.  The  lack  of  EU  emission  controls,  as  would  be  available  through 
product authorisations, has been recognised by the EU legislator in 2013 by inserting a new 
Article  7a  on  Coordination,  in  the  EQS  Directive  requiring  the  Commission  to  use  relevant 
procedures  under  REACH,  Pesticides  and  Biocides  regulations  (See  Article  2.4  of  Directive 
2013/39/EU). 

65 EC [SEC (2011) 1547 final] SWD IMPACT ASSESSMENT (...) as regards priority substances in the 
field of water policy. EEA (2012) European waters — current status and future challenges Synthesis. 
66 Interview Axel Singhofen (5/9/14) 

44 

 
 
 
 
 
 
 
 
                                                 
Water Legislation 

This suggests ineffective interactions between emission controls (upstream pollution control) 
and quality standards instruments. As a consequence, water policy at national level is often 
confronted  with  end-of-pipe  emission  reduction  options,  for  example  new  waste  water 
treatment standards, which are often the least cost-effective options. 67 

The  issue  of  pharmaceutical  residues  has  highlighted  significant  knowledge  and  regulatory 
gaps.68  Such  gaps  are  also  apparent  for  other  issues,  like  nano-materials,  endocrine 
disrupting chemicals and chemical cocktail effects.69 

2.3.2.  Effectiveness of improving quantitative aspects 

According to the EU Treaty EU measures on the quantitative management of water resources 
require unanimous Council decisions. The WFD is the EU’s first attempt to develop policies 
to  address  quantitative  water  aspects  indirectly,  and  this  has  been  subject  to  constitutional 
challenges.70 Regulation of this issue requires the establishment of flow regimes sufficient to 
support  aquatic  life  close  to  undisturbed  conditions  (good  ecological  status)  and  the 
avoidance of excessive groundwater abstraction. 

The instruments which are designed to reach these goals are limited to authorisation regimes 
for  water  abstraction,  the  promotion  of  efficient  water  use  and  the  use  of  water  pricing 
policies. 

There is no strong evidence that these instruments have been successfully applied in the first 
round of RBMP in some Member States. For example no information has been found yet on 
how illegal abstractions in Spain71 or Italy72 have been reduced. Many Member States apply a 
narrow  definition  of  water  services73,  which  leads  to  a  situation  where  most  water  users, 
except  the  users  of  public  drinking  water  and  waste  water  services,  are  not  covered  by  the 
WFD water pricing requirements. The European Court of Justice, nevertheless, ruled that this 
as  such  is  not  a  breach  of  WFD  requirements,  as  Member  States  are  allowed  to  “opt  not  to 
proceed  with  the  cost  recovery  for  a  given  water  use  activity,  where  this  does  not  compromise  the 
purposes and the achievement of the objectives of that directive [WFD]”. 74  

The  economic  analysis  and  assessment  of  better  environmental  options,  as  required  by  the 
WFD  (Article  4.3b  and  Annex  III),are  regarded  as  being  insufficient  to  understand  whether 

67 EurEau (2012) EurEau  initial position paper on amending Directives 2000/60/EC and 2008/105/EC 
as regards priority substances in the field of water policy 
68 See EC [SEC (2011) 1547 final] SWD IMPACT ASSESSMENT (...) as regards priority substances in the 
field of water policy 
69 Interview with EEB (5/9/14)  
70 Environment: Commission takes Spain to Court over urban waste water and river basin plans 
[European Commission - IP/11/729] http://europa.eu/rapid/press-release_IP-11-
729_en.htm?locale=en 
71 WWF/Adena (2006) Illegal water us in Spain, effects and solutions 
72 Global Water Intelligence (2009) The truth behind Italy’s illegal 
abstractionhttp://www.globalwaterintel.com/archive/10/5/general/truth-behind-italys-illegal-
abstraction.html 
73 As noted in the European Commission infringement proceeding against Austria (EC - IP/12/653); 
Germany (EC - IP/12/536 and IP/11/1101);Belgium, Denmark, Finland and Sweden (EC - IP/11/1264); 
Ireland (EC - IP/11/1433) 
74 Judgment of the European Court of Justice (Second Chamber), 11 September 2014, in Case C‑525/12 

45 

 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

cost-effective  measures,  such  as  improving  water  efficiency,  have  been  considered  before 
mitigating the impacts of water supply infrastructure and abstraction.75 

The  stringent  WFD  obligation  to  prevent  the  deterioration  of  the  ecological  status  appears 
more effective and puts pressure on Member States to assess alternative water supply options 
including  desalination  and  irrigation  efficiency  (see  for  example  the  Spanish  assessment  of 
Ebro water transfer).76 

The  EU’s  Ecodesign  Framework  is  a  policy  instrument  that  addresses  the  environmental 
performance  of  products.  This  has  already  been  addressed  for  dishwashers  and  washing 
machines under the EuP Directive, although the water saving effect appears to be limited (see 
Phase II, section 3.4.1 of this report). 

The  main  water  using  sectors  in  the  EU  in  terms  of  quantity  are  agriculture  and  energy 77, 
which  are  also  subject  to  EU  policies  that  are  focussed  historically  on  supporting 
production78, in particular via direct payments, quotas and export support mechanisms, and 
energy  generation  and  transport,  in  particular  by  setting  renewable  energy  shares,  and 
supporting  carbon  capture  and  interconnection  projects  though  some  of  this  would  be 
counterbalanced  by  EU  policies  to  increase  energy  efficiency  and  thus  reduce  energy 
demand.79  Increased  agriculture  production  and  energy  generation  and  transport  increase 
the pressure on the quantitative status of the EU’s water bodies. 

2.3.3.  Effectiveness of improving spatial aspects 

It  is  largely  up  to  national  policies  to  manage  the  spatial  aspects  relevant  to  supporting 
conditions consistent with a good ecological status.  

As  with  quantitative  management  of  water  resources,  according  to  the  EU  Treaty,  EU  land 
use  measures  require  unanimous  Council  decisions.  Water  and  spatial  management  are 
closely  interrelated,  as  water  use  requires  space  and  use  of  space  changes  the  hydrological 
cycle and thus water availability.  

Lack of finance has been identified by experts80 as a challenge for restoring floodplains and 
for  improving  hydromorphological  conditions  affected  by  existing  infrastructure,  such  as 
dams and dykes. The importance of implementing the EU Floods Directive81 and interaction 
with RBMPs has been stressed. 

For example regarding flood risk,  management can include reducing the  use of floodplains 
and thus increasing the space for rivers, which improves the water retention capacity of the 

75 EC [SWD(2012) 382 final]]SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources – part 1 
76 Economic assessment of the Ebro Water Transfer – ES  from 
http://ec.europa.eu/ourcoast/index.cfm?menuID=7&articleID=18 
77 CEPS (2012) Which Economic Model For A Water-Efficient Europe? 
78 See TEU objectives for the CAP: increase productivity and assure availability of supplies (Article 39.1 
a and d) 
79 EU 2020 climate and energy framework and implementing policies  
80 Pieter Pollard (15/9/14) and Pierre Strosser  (25/9/14) 
81 Interview with Eduard Interwies (18/7/14) 

46 

 
 
 
 
 
 
 
 
                                                 
Water Legislation 

river basin, which in turn improves the hydrological regime and reduces the need for dams 
and  water  reservoirs,  which  improves  the  sediment  structure  of  the  river.  Similarly, 
increasing  the  efficiency  of  water  use  leads  to  reduced  water  demand,  which  reduces  the 
need for dams and reservoirs with the same positive effect on the river structure. Therefore 
the Floods Directive can be regarded as one of the EU’s main policy instruments to improve 
the availability of space for water. 

Besides those parallels, the management of space for water bodies including their structure, 
is less developed by the WFD, which only requires general binding rules (WFD Art 11.3i).The 
WFD economic instruments, including cost recovery for water services, do not cover land use 
in  general  and  only  cover  water  infrastructure  like  dams  and  dykes  as  services  for  inland 
navigation,  flood  protection  or  energy  production  in  a  broad  interpretation.  As  stated  in 
chapter  2.3.2,  during  the  first  round  of  RBMPs  a  wide  definition  of  water  services  was  not 
commonly  used.  Further  to  that,  the  economic  analysis  and  assessment  of  better 
environmental  options,  as  required  by  the  WFD  (Art  4.3b  and  Annex  III),  are  regarded  by 
some  as  insufficient82  to  understand  whether  potentially  cost-effective  measures,  like 
reducing land use, have been considered before mitigating the impacts of land use. 

Other  environmental  EU  policies,  including  the  Birds,  Habitats  and  Environmental  Impact 
Assessment Directives establish land use planning procedures for protected areas, which are 
linked with the WFD (Article 6). 

EU sector policies for agriculture and energy are mainly focussed on supply and production 
and  tend  to  increase  the  use  of  land  and  water.  The  lack  of  any  -  or  insufficient  - 
compensation  policies  and  measures  implemented  by  Member  States  cause  a  conflict  with 
reaching a good ecological status (see chapter 2.1.3 for examples). 83 

2.4.  Conclusions from the Ex-post Impact Assessment 

Our assessment of progress in policy areas and instruments (chapter 2.2) 
and of effectiveness of policies to improve the Water Status (chapter 2.3) 
provides a mixed picture. In addition to the overview given in the 
paragraphs hereafter, Table 2 below provides a detailed view of the 
assessment. 

Progress achieved towards human health objectives 

The progress that has been made in reaching human health protection objectives has mainly 
been  achieved  by  using  a  combination  of  EU-level  quality  standards  and  a  mix  of  EU  and 
national  emission  controls.  Progress  is  also  reported  in  dealing  with  specific  types  of 
pollution,  for  example  pathogens,  biodegradable  components  and  nutrients  in  urban  waste 
water, causing eutrophication and posing human health risk. The instruments are similar: a 
combination of EU emission controls backed by quality standards. 

82 EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources– part 1 
83 Interviews with Peter Gammeltoft (23/7/14) , Thomas Dworak (18/7/14) and Pierre Strosser 
(25/9/14) 

47 

 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

This approach appears to be a successful way of improving the quality elements in order to 
achieve the Water Status objectives. 

Problems exposed regarding effective ways of addressing pollution 

The implementation of the WFD exposes problems in dealing with pollution, notably: 

•  Diffuse pollution from agriculture, energy and transport activities; 

•  Weak understanding of chemical risks, due to lack of monitoring at national 
level and the lack of an EU risk assessment for whole groups of substances; 
and 

•  Emerging imbalance of the combined approach of setting mutually reinforcing 
EQS and emission controls. Emission controls, as foreseen by the WFD, have 
not yet come forward. While the EU has a range of emission control 
instruments for industrial chemicals, pesticides and biocides, they were not 
used over the last decade to respond specifically to water pollution concerns. 
Finally a range of chemical properties or products are not covered by EU risk 
assessments requirements or emission controls, including nano-particles, 
cocktail- and endocrine disrupting effects and pharmaceuticals.  

Limited progress towards reducing quantitative pressures 

Progress  towards  reducing  quantitative  pressures,  as  required  to  support  good  status  for 
surface and groundwater, has been limited so far. This can be attributed to a lack of clarity 
and  stringency  of  the  target  provided  by  the  WFD  as  well  as  a  lack  of  EU  and  national 
instruments.  Some  instruments  are  promoted  by  the  WFD,  notably  economic  assessments 
and  instruments  to  increase  water  efficiency,  but  implementation  is  often  narrow  or 
incomplete.  The  development  of  EU  policies  in  the  area  of  quantitative  water  resource 
management  is  restricted  due  to  limitations  set  by  the  EU  Treaty. 84  Nevertheless,  product 
policies have been passed which introduce minimum water efficiency requirements. 

On the other hand, EU energy, agriculture and transport policies have a significant impact on 
water  use,  which  is  rarely  considered  in  policy  development.  Overall,  there  remains 
significant untapped potential to improve water efficiency, on both the demand and supply 
side.  

Recent  European  Commission  initiatives  to  develop  an  EU  Strategy  for  a  resource-efficient 
Europe,  reinforce  these  findings  and  explore  the  economic  benefits  of  increasing  water 
efficiency  and  saving  water.  For  example,  the  Roadmap  for  a  resource-efficient  Europe 85 
proposes a water abstraction target of less than 20% of available renewable water resources 
as well as water efficiency targets and improved measures such as water metering, water re-
use,  reduction  of  leakage  from  water  infrastructure,  etc.  While  the  Flagship  for  resource 
efficiency86  emphasises  the  importance  of  a  water  policy  that  prioritises  water  saving 

84 See TEU Article 192.2b which requires unanimity in Council for measures affecting quantitative 
management of water resources.  
85 EC [COM(2011) 571 final] Communication (…) Roadmap to a resource efficient Europe, pp. 13-14 
86 EC[COM(2011) 21] Communication (…)A resource-efficient Europe – Flagship initiative under the 
Europe 2020 Strategy, p.6 

48 

 
 
 
 
 
                                                 
Water Legislation 

measures  and  improved  water  efficiency.  The  Communication  on  a  circular  economy87 
recommends that the Resource Efficiency Scoreboard, which is used to monitor the progress 
towards a resource efficient Europe, should be further developed and include indicators for 
water and land use.  

Limited progress regarding improved space and structure objectives 

Progress with regard to improving space and structure as required to achieve a good status is 
limited  for  similar  reasons  as  outlined  above  for  water  quantity:  lack  of  robust  targets  and 
instruments,  incomplete  national  implementation  and  conflicting  EU  policies  leading  to 
ineffective  policy  designs.  This  is  illustrated  by  the  unclear  cost-effectiveness  assessment  in 
PoMs,  which  mostly  address  new  projects  requiring  mitigation  measures  but  rarely 
investigate  better  environmental  alternatives  to  the  project  or  revisit  existing  projects  even 
though these options could be more cost-effective. 

In addition, the WFD requirements relating to the EU Floods Directive provide a potentially 
powerful  planning  instrument  if  well  integrated  with  the  RBMP  and  the  use  of  economic 
instruments. 

As mentioned above, the EU Strategy for a resource-efficient Europe, does not capture land 
water interactions. 

Policy coherence  

Coherence between sector and water policies as well as between different water policies has 
been identified as a main issue hindering effective delivery of water policy objectives. RBMPs 
and PoMs in general have not yet managed to reduce those conflicts or lead to better policy 
integration  in  a  systematic  manner,  although  individual  examples  are  provided  including 
increased economic transparency in several countries or for example the integration of waste 
management into RBMPs in France.88 Flood risk management is identified of a priority area 
for  better  integration  within  RBMPs.  We  have  not  studied  in  detail  conflicts  with  sector 
policies  in  view  of  identifying  potential  actions  at  EU  level,  but  the  impact  on  water 
protection from the CAP and EU energy policies is widely recognised.89  

Table  2  presents  an  overview  of  progress  of  EU  water  legislation  based  on  the  analysis  in 
chapter  2  and  the  factsheets  in  Annex  A.  The  factsheets  provide  information  about  the 
implementation  process  of  the  directives  (regarding  transposition  as  well  as  reporting  on 
progress  towards  objectives).  Additionally,  the  factsheets  offer  some  quantitative  data  on 
related  costs  and  benefits.  Hence,  Table  2  combines  the  Directive-specific  information  from 
the factsheets with the conclusions from the analysis in chapter 2 to provide an evaluation of 
implementation progress of EU water legislation.  

87 EC [COM(2014) 398 final/2] Communication (…)Towards a circular economy: A zero waste 
programme for Europe, p. 14 
88 Interview with Pierre Strosser (25/9/14) 
89 Common view of experts interviewed 

49 

 
 
 
 
                                                 
Cost of Non-Europe Report 

Table 2: Overview of the progress of EU water legislation 

Area 

Policy 

Directive 
2000/60/EC – 
WFD 

Progress - 
administrative 

Lagging: 
30% of the RBMPs 
have not been 
submitted  

l
l

A

y
t
i
l

a
u
Q

Emission controls and EQ 
Directive 
98/83/EC - 
DWD 

Positive: 
Implemented, 
reporting on track 

Progress – toward objectives 

Costs 

Benefits 

Lagging: 
•  Surface waters in 2015 – 50% in 
poor ecological status, 40% with 
unknown chemical status 90;  
•  Main pressures are on hydro-

morphology91 and from diffuse 
and still some point-source 
pollution 92; however  

•  Groundwater in 2015 – 90% in 

good status for both quantity and 
quality. 93 

Total costs of all WFD-
related measures: €209 - 
€326 billion (or €8-€15 
billion/year); total costs 
of WFD-specific 
measures:  
€40 - €230 billion (or €2 
- €11 billion/year)94,95 

Positive:  
Very high compliance rates in all 
Member States; some issues 
remain with compliance of remote 
or small suppliers 

Estimated unit costs for 
removal of pesticides 
from drinking water 
were €0.028 /m3 in 
2006 98 

If 70% of EU WBs would be 
in good ecological status 
(GES) by 2015, the expected 
total yearly benefits might 
be 
€1.5 - €20 billion/ year; if 
100% of the EU WBs would 
reach GES by 2015, the 
expected total yearly 
benefits might be €2.82 - 
€37.3 billion/year96, 97 

Lower health costs 

Relation to 
other policies 

Agriculture, 
Energy, 
Transport, 
Industry 

Problematic areas 

•  Insufficient use of economic 
assessment and instruments; 
Cost-effectiveness unclear  
•  Significant and arbitrary use of 

exemptions  to postpone 
reaching or setting lower 
objectives 

•  Insufficient integration with 

other policy areas 

•  Conflict of reporting cycles 

with other water legislation. 

Limited number of substances 
addressed 

90 EEA (2012) European waters — current status and future challenges: Synthesis, p.9 
91 EC [SWD(2012) 382 final] IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to Safeguard Europe's Water Resources, part 2, p.17 
92 EEA (2012) European waters — current status and future challenges: Synthesis, p.14 
93 EEA (2012) European waters — current status and future challenges: Synthesis, p.9 
94 Acteon (2012) Comparative study of pressures and measures in the major river basin management plans in the EU: Task 4 b - Costs & Benefits of WFD 
implementation: Final report, p.46 
95 These estimations are based on RBD cost data reported by 11 Member States through WISE for the first WFD planning cycle. These costs are disaggregated to costs 
per inhabitant, water body and km2. Together with statistical models for the transfer of costs to RBD where data is missing these values are used to estimate the costs 
of WFD relevant and WFD specific measures for all RBDs. The range represents the average values derived from the simple extrapolation and after the statistical 
modelling. This study is conducted for EU27. 
96Acteon (2012) Comparative study of pressures and measures in the major river basin management plans in the EU: Task 4 b - Costs & Benefits of WFD 
implementation: Final report, p.46 
97 For the estimation of the benefits the authors use a similar approach as for the costs. However, the low number of RBD with benefit data did not allow for statistical 
modelling. Hence, the range represents the figures resulting from the rough multiplication of the unitary values derived from the reported RBD data and the number 
of inhabitants in the EU and assuming a certain proportion of the water bodies will be in good ecological status in 2015. This study is conducted for EU27. 
98 EC [SEC(2011) 1547 final]]SWD IMPACT ASSESSMENT (...) as regards priority substances in the field of water policy, p.32 

50 

 
 
 
 
 
                                                 
Area 

Policy 

Directive 
2006/7/EC  - 
BWD 

Progress - 
administrative 

Mixed: 
Implemented, 
reporting on track, 
but probably not all 
bathing sites 
identified, especially 
inland waters 

Progress – toward objectives 

Costs 

Benefits 

Positive:  
Very high compliance rates in all 
Member States 

Average conventional 
waste water treatment - 
operational cost is 
€1.9/m3; capital 
investment is €474 – 
593/m3/day 99 

Lower health costs, 
recreational and tourism 
benefits  

Water Legislation 

Relation to 
other policies 

Agriculture 

Problematic areas 

Emission controls and EQS 
Positive:  
Directive 
Implemented, 
91/271/EEC - 
UWWTD 
reporting on track, 
new compliance 
deadlines for post-
2004 Member 
States 
Positive: 
Implemented, 
reporting on track 

Directive 
91/676/EEC - 
Nitrates 
Directive 

Directive 
2006/118/EC - 
GWD 

Positive: 
Implemented, 
reporting mostly on 
track 

Mixed: 
High compliance in “old Member 
States”, lower compliance in “new 
Member States”; decrease in 
nitrogen and phosphorus loads in 
EU seas attributed to it 100 

Average conventional 
waste water treatment - 
operational cost is 
€1.9/m3; capital 
investment is €474 – 
593/m3/day 101 

Lower health costs, reduced 
treatment for drinking water  

•  Missing cost-effective 

approaches to decentralised  
treatment 

•  Ageing infrastructure 
•  Combined sewage overflows 

Lagging: 
Compliance is increasing but diffuse 
pollution is still a major pressure 
for around half of the water bodies 
in the EU 102 
Mixed: 
Currently 25% of groundwater is in 
poor chemical status; 6.4% - in poor 
quantitative status; but expectation 
is that for both criteria around 90% 
of groundwater will be in good 
status in 2015 103 

The average overall cost 
of monitoring of existing 
PS in the EU27 is €69 
million annually or €1.7 
million per PS per 
year104, 105 

Agriculture  

•  Diffuse pollution from 

Agriculture, 
Industry 

agriculture is still a major 
pressure for much of EU 
waters 

•  Illegal abstraction in some 

Med countries 

•  New pollutants, like EDC and 
pharmaceutical not covered 

99 EC [SWD(2012) 382 final] IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to Safeguard Europe's Water Resources, part 2, p.25 
100 JRC (2011) Long term nutrient loads entering European seas, p.47 
101 EC [SWD(2012) 382 final]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to Safeguard Europe's Water Resources, part 2, p.25 
102 EEA (2012) European waters — current status and future challenges: Synthesis, p.14 
103 EEA (2012) European waters — current status and future challenges: Synthesis, p.21 
104 EC [SEC(2011) 1547 final]]SWD IMPACT ASSESSMENT (...) as regards priority substances in the field of water policy, pp.80-81 
105 This is the average value derived from a bottom-up and a top-down estimation made for the IA. The bottom-up approach was based on unit costs and found that 
monitoring costs for PS in the EU27 lie in the range €51-97 million, while the top-down approach was based on overall monitoring expenditure per MS and found 
that the range of monitoring costs is €41-94 million. €69 million is the average of the overall range i.e. €41-97 million.  

51 

 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

Area 

Policy 

Directives 
2008/105/EC 
and 
2013/39/EU on 
EQS & PS 

Progress - 
administrative 

Unknown: 
The new directive is 
under 
implementation 

Progress – toward objectives 

Costs 

Benefits 

Relation to 
other policies 

Problematic areas 

Lagging: 
40% of surface waters are with 
unknown chemical status 106; effects 
of emerging pollutants are not 
known 

The average overall cost 
of monitoring of existing 
PS in the EU27 is €69 
million annually or €1.7 
million per PS per  
year107 

Lower health costs 

Industry 

•  Effects of emerging pollutants 

are unknown 

e
c
a
p
s
d
n
a
y
t
i
t
n
a
u
Q

Floods and droughts 

Directive 
2007/60/EC - 
Floods 
Directive 

Positive(so far): 
Implemented, first 
reports to be 
submitted in late 
2015 

Unknown: 
Flood risk management plans to be 
submitted in late 2015 

NWRMs bring flood 
protection benefits of 
around €740 million  for the 
period 2010-2100108; Avoid 
flood costs - economic 
damage from floods in EU for 
the period 2006-2010, are 
estimated at €6.4 
billion/year 109 

COM [(2007) 
414] 
Addressing 
WS&D 

Lagging: 
Only some of the 
submitted RBMPs 
address WS&D 
issues 

Lagging: 
Water imbalances and stress are 
reported in many of Europe’s 
surface waters 110 

Total costs due to water 
shortages in Cyprus in 
the period 2010-2030 
may reach €200 million 
(2009 prices) 111,112 

•  No binding legislation in this 

policy area 

Legend:   

   Human safety 

   Human safety and Environmental protection 

   Environmental protection 

Source: Authors’ own analysis 

106 EEA (2012) European waters — current status and future challenges: Synthesis, p.9 
107 EC [SEC(2011) 1547 final]]SWD IMPACT ASSESSMENT (...) as regards priority substances in the field of water policy, pp80-81, for an explanation how the value is 
derived – see footnote 44 
108 EC [SWD(2012) 382 final] IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to Safeguard Europe's Water Resources, part 2, p.23 
109 EC [SWD(2012) 382 final]]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to Safeguard Europe's Water Resources, part 1, p.28 
110 EEA (2012) European waters — current status and future challenges: Synthesis, p.9 
111Zachariadis, T. (2010) The Costs of Residential Water Scarcity in Cyprus: Impact of Climate Change and Policy Options as cited in EC [SWD(2012) 382 
final]]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to Safeguard Europe's Water Resources, part 1, p.28 
112 These estimates were made using three scenarios for increasing water demand in Cyprus and taking projected climate change effects into account. The whole 
range of the estimated scarcity costs is €72-200 million. Furthermore, this value is the estimated scarcity cost for the domestic, industry and tourism sectors as these 
sectors are supplied from the same freshwater sources – dams and desalination plants. 

52 

 
 
 
 
 
 
 
 
 
 
 
                                                 
Water Legislation 

3.  Phase II - The cost of non-Europe 

This chapter considers the potential for a number of possible future extensions of 
EU water legislation. The majority of these potential extensions relate to gaps in 
coverage or areas of poor performance identified in the previous chapter. 

The  Terms  of  Reference  for  this  study  highlighted  five  policy  issues  where  it  was  believed 
that  potential  existed  for  additional  EU  action  and  coordination.  The  previous  chapter  has 
confirmed that there are currently gaps or areas of poor performance. Section 3.1 shows that 
all  of  those  gaps  and  areas  concerning  the  water  policy  itself  could  be  addressed  to  some 
extent by the five case studies suggested in the terms of reference. For each of the five cases 
we have described the issues as well as the European level policy options available to address 
them, and then made an attempt to estimate the potential costs and benefits of doing so. 

3.1.  Potential  new  EU  legislation  vs.  gaps  in  coverage  and  areas  of 

poor performance 

This section presents the areas in which there is a coverage gap, 
 the potential for new EU legislation and the areas which will be  
covered in the following case studies. 

The main gaps in policy coverage and areas of poor policy performance which emerge from 
our high level ex-post assessment (the previous chapter) are: 

•  Missing EU emission controls and gaps in chemical risk assessments and controls; 
•  A need for stronger targets, and new and better use of existing tools for improving 

quantitative water status as part of a resource efficiency strategy; and 

•  A need for new and better use of existing tools for improving space for, and structure 

of, water bodies as part of a resource efficiency strategy. 

The five areas of potential new measures (legislative and non-legislative) cover the gaps and 
areas of poor performance in the following way: 

1.  Programmes  of  Measures  (PoM):  Address  the  majority  of  national  implementation 
including  cost-effectiveness  of  measures  and  the  use  of  required 
questions 
instruments. Being part of the RBMPs implies that they would be the main vehicle to 
achieve  better  integration  of  different  policies  at  national/regional  level.  It  would 
therefore allow those quantity and space issues of water status to be addressed, which 
would be considered to respect the principles of subsidiarity and proportionality and 
where EU measures might not be appropriate.  

2.  Waste  Water  Re-use:  addresses  a  very  specific  part  of  the  quantitative  issues  and 
eventually new health aspects. This issue needs to be placed within the larger context 
of water efficiency and the savings hierarchy (reduce, re-use, desalinate, transfer). 

3.  Eco-design  and  metering:  addresses  a  significant  part  of  the  quantitative  issues  and 
provides an important link to energy policies and energy-intensive sectors, which are 
major land and water users. Effectiveness will be linked to economic instruments. 

53 

 
 
  
 
 
 
 
 
 
 
Cost of Non-Europe Report 

4.  Economic instruments: central to all Water Status Elements, as they have the potential 
to  improve  cost-effectiveness  of  PoMs  and  help  finance  restoration  measures.  One  of 
the  most  important  economic  instruments  is  the  use  of  water  tariffs  which  require 
water metering to be effective. There are other examples of new policy tools (and better 
use of existing tools) which can also be considered. 

5.  Pharmaceutical  residues:  specific  and  arguably  the  largest  outstanding  gap  with 
regard to better management of the pollution challenge. However, it does not address 
the  significant  problems  with  other  types  of  pollution  for  which  EU  emission  control 
instruments  are  further  developed  (including  REACH  and  Pesticide  and  Biocide 
authorisations) which have not been used so far in synchronisation with setting quality 
standards. 

From  this  screening  it appears  that  the  five  priority areas cover most  of  the issues  we have 
identified. The coverage is perhaps weakest on water quality, which is only addressed in an 
illustrative way by the pharmaceutical residues case, and regarding the better EU-level sector 
policy  coordination  and  integration  of  environmental  concerns  into  agriculture,  energy  and 
other policies. 

A cross cutting and important area where there is potential for added value from EU action is 
the  alignment  of  sector  policy  objectives  in  order  to  reduce  policy  conflicts  and  to  improve 
environmental  policy  integration.  Policy  coherence  and  integration 113  remains  one  of  the 
main  challenges  in  water  policy.  This  covers  integration  of  (i)  water  concerns  into  different 
sectors  and  policy  areas  especially  agriculture,  chemicals,  pharmaceuticals,  economic  and 
financial  policy,  and  (ii)  of  different  water  policies,  such  as  flood  risk  and  river  basin 
management.  RBMPs114  represent  an  important  vehicle  to  foster  such  integration  especially 
in  the  case  of  land  use,  quantitative  management  of  water  resources  and  the  energy  mix, 
where EU measures require unanimity in the Council.115 Nevertheless, there is potential for 
additional  EU  action  to  reduce  existing  conflicts  between  European  water  legislation  and 
major  EU  sector  policies,  including  the  Common  Agricultural  Policy  (CAP)  and  EU  energy 
policy. 

The detailed analysis of these policy interactions and possible solutions is beyond the scope 
of  this  study.  Nevertheless,  the  following  EU  policies  can  be  highlighted  as  important 
examples which are linked with the case studies: 

•  Agriculture: A revised CAP with some measures aimed at dealing with water use in 
agriculture  was  adopted  in  2013,  though  adding  the  WFD  to  the  list  of  cross-
compliance  has  been  postponed  in  view  of  the  ongoing  WFD  implementation.  Given 
that progress towards reaching the WFD’s good status objectives has been slow, partly 
because  of  the  significant  pressures  from  agricultural  activities  and  lack  of  financing 
for  restoration  projects,  there  is  room  for  additional  EU  action  to  improve  policy 
coherence and facilitate financing (see also chapter 3.2 on PoMs, building block for the 
costs of non-Europe on floodplain restoration). 

113 According to the majority of the expert group for this study 
114 According to the majority of the expert group for this study 
115 TEU Article 192 2.b 

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Water Legislation 

•  Energy:  A  new  EU  climate  and  energy  policy  framework  for  2030  has  recently  been 
agreed upon. It sets targets for renewable energy and energy efficiency for 2030116 and 
is, hence, expected to have significant repercussions for WFD implementation (see also 
chapter 3.4 on Eco-design and metering, building block on the cost of non-Europe on 
water taps and shower heads). 

3.2.  Case study for Programmes of Measures 

This section starts by identifying the current problems and policy context 
related to PoMs and RBMPs. It then describes the magnitude of the 
identified issues, the proposed options for improvement and the advantages 
of addressing the issue on a European level. 

3.2.1.  The problem and the policy context 

The  Programmes  of  Measures  (PoMs)  as  required  by  the  WFD  set  out  all  measures  put  in 
place  and  made  operational  to  reach  the  objectives  as  established  by  the  RBMPs.  As 
discussed  in  chapter  2,  one  of  the  main  structural  challenges  faced  by  the  WFD 
implementation  is  the  improvement  of  the  hydromorphological  status  of  bodies  of  water. 
Pressure  on  the  hydromorphology,  mainly  resulting  from  dams,  dykes  and  land  use,  is 
causing the majority of failures to reach good status as set by the WFD. An assessment of the 
basic  (mandatory)  and  supplementary  measures  as  required  by  the  WFD  article  11  on  the 
PoMs correlates with this finding: 

•  Regarding  water  quality  some  eight  categories  of  measures  are  prescribed,  ranging 
from  prohibitions,  prior  authorisations  and  controls  of  different  types  of  pollutant 
discharges  at  national  level  and  the  enforcement  and  implementation  of  emission 
controls set at EU level. 

•  Quantitative  aspects  are  addressed  by  general  controls,  prior  authorisations  and 

registers for abstractions and impoundments. 

•  For  managing  hydromorphological  and  spatial  aspects,  only  one,  rather  vague 
category  of  measures  is  described:  controls  which  may  take  the  form  of  prior 
authorisations or controls based on general binding rules. In practice this has led to a 
focus  on  mitigating  the  negative  impacts  of  new  infrastructure  projects  with  little 
priority  given  to  existing  infrastructure.  This  tendency  is  reinforced  by  the  WFD 
Article  4  objective  to  prevent  further  deteriorations,  which  is  not  subject  to  the  usual 
exemptions applied for the restoration objectives. 

•  Water  pricing  based  on  cost-recovery  and  user  /polluter  pays  principle  is  a 
crosscutting  measure,  which  could  also  support  reductions  of  pressures  on 
hydromorphology, but national implementation of water pricing tools has focused on 
public water supply and treatment services. 117  

116 EC (2014) 2030 Framework for Climate and Energy: Outcome of the October 2014 European Council, 
presentation. The agreed targets for 2030 are: reduction of greenhouse gas emissions by at least 40%; 
increase the share of renewable energy to at least 27% of the energy consumption and raising energy 
efficiency by at least 27%. 
117As noted in the European Commission infringement proceeding against Austria (EC - IP/12/653); 
Germany (EC - IP/12/536and536and IP/11/1101);Belgium , Denmark, Finland and Sweden (EC - 
IP/11/1264) Ireland (EC - IP/11/1433) 

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This  means  that  in  practice  there  are  no  strong  specific  requirements  for  actually  restoring 
hydromorphology  and  for  creating  more  space  for  rivers.  Restoration  programmes  are  a 
typical  case  of  financing  an  upfront  investment  which  is  a  major  challenge  given  the  tight 
budgetary policies in most Member States. 

PoMs  have  to  be  seen  as  part  of  the  central  governance  tool,  the  River  Basin  Management 
Plans  (RBMPs),  which  should  foster  Integrated  Water  Resource  Management  (IWRM)  and 
cross-border cooperation by taking the entire river basin as an administrative unit instead of 
national,  regional  or  local  borders,  with  reviews  at  six  year  intervals  (2009,  2015,  2021  and 
2027). The first comprehensive assessment of the RBMPs was carried out in the context of the 
reporting requirements of article 18 in the WFD, which noted that that “The strength of the 
planning  process,  and  the  adequacy  and  reliability  of  the  RBMP  depends  upon  good 
implementation  of  every  intermediate  step”  (p.3).118  Consequently,  the  level  and  quality  of 
the  design  and  implementation  of  the  RBMPs  and  their  PoMs  are  essential  for  the  entire 
success of the WFD. 

The creation and implementation of RBMPs appear to be still at an early stage. In 2012, only 
75  %  (n=124)  of  the  total  number  of  expected  RBMPs  were  reported  to  the  Commission. 
Spain,  Portugal,  Greece,  and  Belgium,  in  particular,  were  identified  as  laggards  by  not 
adopting or only partially adopting plans. Besides implementation problems, an assessment 
noted  that  the  RBMPs  struggled  to  provide  adequate  and  detailed  information  to  allow  for 
assessments and proper monitoring, and that they made excessive use of exemptions to the 
guidelines set out under the WFD to justify the current levels of abstraction or management 
practices.  For  example,  the  2012  assessment  notes  that  in  some  cases  data  were  missing  to 
assess the chemical and biological status for over 50 % of the water bodies. In several cases, 
the  RBMPs  were  considered  to  need  more  integration  into  local  and  regional  decision-
making procedures which are currently causing more organisational challenges than needed 
due to high transaction costs and administrative confusion in managing the river basins. The 
fact  that  RBMPs  have  been  integrated  into  local  and  regional  decision  making  in  many 
Member  States  suggests  that  where  it  is  lagging  it  is  due  to  national  implementation 
discussions  rather  than  due  to  problems  interpreting  relevant  EU  regulations.  Finally,  the 
2012  assessment  noted  that  the  RBMPs  were  insufficiently  aligned  or  integrated  with  other 
important adjacent policy domains and documents such as the Flood Risk Management Plans 
or taking climate change and adaptation into account. 

3.2.2.  Potential impacts and role of EU coordination 

Based on the assessment above, there are two areas where added value of EU actions could 
be significant119: 

•  Dyke  set  back  and  floodplain  restoration,  often  referred  to  as  Natural  Water 

Retention Measures (NRWM); and 

•  Dam removal. 

The  potential  for  direct  regulatory  intervention  from  the  EU  is  limited  due  to  limited 
regulatory  powers  over  land  use  and  spatial  planning,  but  financial  incentives  could  be 
strengthened  and  policy  coherence,  in  particular  flood  risk  management,  agriculture  and 

118 COM(2012) 670 final, p. 24 
119 Interview with Pierre Strosser 25/9/14 

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investment policies, could be improved. A wider application of the cost-recovery principle and 
full implementation of WFD article 9 could also be helpful to incentivise and finance measures. 

In practice this means that the EU could provide additional support and incentives for river 
basin authorities including: 

•  Management  tools  to  better  define  obsolete  infrastructure,  which  has  either 
outlived its original purpose or reached a condition where maintenance costs 
outweigh benefits; 

•  Governance principles for successful restoration projects; and  

•  Prioritisation  and  financing  tools,  including  use  of  EU  structural  and 

agriculture funds. 

This  would  need  to  be  accompanied  by  further  efforts  to  reduce  policy  conflicts  by  better 
integration the economic rational of restoration projects, in particular flood plain restoration, 
into main EU policies. 

The bottom line is that an economic rationale for dam removal, dyke set back and flood plain 
restoration  has  to  be  made.  For  dyke  removal  and  floodplain  restoration,  several  studies 
provide cost and benefit assessments, although these show very large regional variations, as 
the following three examples illustrate. 

The Flemish Sigma plan to manage floods at the Scheldt estuary has been in operation since 
1977  and  combines  increasing  the  height  of,  and  strengthening  the  dykes,  the  standard 
procedure at the time, with the establishment of Flood Control Areas (FCA), which are low 
lying  areas  partly  reconnected  with  the  river  during  flood  events  (see  illustration  below). 
These  are  first  steps  in  a  NWRM.  The  Sigma  plan  was  updated  and  expanded  in  2005  to 
further strengthen the NWRM aspects and ecological protection focus of the plan. This was 
shown  to  be  more  cost-effective  than  the  construction  of  a  major  storm  surge  barrier  and 
protection of agricultural output.120 The total investment costs for the restoration of 4.646 ha 
of  Scheldt  estuary  floodplains,  building  of  dykes  and  sluices,  are  estimated  at  €521  million  
(€112.205  /ha)  and  the  economic  benefits  resulting  from  reduced  flood  damages  and 
increased  recreation  and  provision  of  other  ecosystem  service  are  estimated  respectively  at 
€740  million,  and  €155  million.121  The  payback  period  for  the  flood  relevant  aspects,  which 
dominate  the  plan,  are  estimated  to  be  around  14  years  using  a  social  discount  rate 122 
suggesting that annual benefits are around €10,000 /ha.  

120 Broekx S, et al. (2011) Designing a Long-Term Flood Risk Management Plan for the Scheldt Estuary 
Using a Risk Based Approach. Natural Hazards, 57 (2), 245‒266, 
www.springerlink.com/content/e43138836415t02n/ 
121 IEEP at al (2010) Green Infrastructure In-Depth Case Analysis Theme 4: Freshwater And Wetlands 
Management And Restoration 
122 Broekx S, et al. (2011) Designing a Long-Term Flood Risk Management Plan for the Scheldt Estuary 
Using a Risk Based Approach. Natural Hazards, 57 (2), 245‒266, 
www.springerlink.com/content/e43138836415t02n/ 

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Figure 4: Functioning of a flood control area with controlled reduced tides 

Source: Illustration from ECSA Bulletin 62 - Winter 2014, Estuaries in Focus – Sigma Plan Proves Efficiency 

Around  1.8  million  ha  or  2/3  of  the  Danube  river’s  floodplains  are  no  longer  active,  in  the 
sense  of  being  connected  to  the  river,  and  it  is  estimated  that  0.8  million  ha  could  be 
restored.123 The total restoration potential, including for the Danube main tributaries, Drava, 
Sava and Tisza, reaches 1.4 million ha.124 The restoration costs are estimated at an average of 
€5,000  /ha  and  the  benefits  at  an  average  of  €500  /ha  and  year  for  provision  of  ecosystem 
services for fisheries, forestry, animal fodder, nutrient retention and recreation, leading to a 
payback period of 10-20 years.125 

France  has  a  wetland  restoration  potential  of  around  1.5  million  ha. 126  The  Grenelle  II  Law 
from  2010  establishes  a  multiannual  programme  for  the  restoration  of  the  ecological 
continuity of rivers (infrastructure works) and foresees the purchase and public management 
of some 20,000 ha of wetland by end of 2015. The impact assessment provided for the latter 
estimates  the  investment  costs  (land  purchase)  at  between  €3,000  and  €7,000  per  ha  and 
management costs of €251 to €521 per ha. The annual benefits are estimated at €1,950 /ha for 
avoided costs of drinking water treatment, €400 / ha for fishing and hunting revenues and 
between €150 and €490 per ha for flood protection. 

The  total  annual  benefits  add  up  to  €2,500  and  €2,850  per  ha  leading,  with  a  net  benefit 
between €1,979/ha and €2,589 /ha. This means that the investment costs would be recouped 
within 1-3 years.127  

123 WWF (2010) Assessment of the restoration potential along the Danube and main tributaries. Active 
floodplain means “Floodplain area between current flood defenses (dikes) often designed for the 100 
year flood return interval; it includes usually all water bodies, but for very large rivers such as the 
Danube the main channel surface will be calculated separately.” (WWF, 2010, p.4 
124 ibid 
125 IEEP et al (2010) Green Infrastructure In-Depth Case Analysis Theme 4: Freshwater And Wetlands 
Management And Restoration 
126 IEEP et al. (2010) Green Infrastructure In-Depth Case Analysis Theme 4: Freshwater And Wetlands 
Management And Restoration 
127 IEEP et al. (2010) Green Infrastructure In-Depth Case Analysis Theme 4: Freshwater And Wetlands 
Management And Restoration  and own calculations 

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Figure 5: Overview of surveyed Danube reaches and tributaries 

Source: WWF (2010) Assessment of the restoration potential along the Danube and main tributaries 

3.2.3.  Potential building blocks for illustrating the costs of non-Europe 

The definition of what non-EU means in this case has to be carefully developed considering 
the following elements: 

•  Better  enforcement  and  implementation  of  WFD  and  Floods  Directive  by 

providing: 

o  Management tools in order to better define obsolete infrastructure, 
which has outlived its original purpose and/or where maintenance 
costs outweigh benefits; 

o  Governance principles for successful restoration projects; and  
o  Prioritisation and financing tools, including for the use of EU 

structural and agriculture funds. 

•  Better  integration  of  ecosystem  service  considerations  in  EU  agriculture  and 

cohesion policies. 

The  examples  from  Belgium,  the  Danube  River  Basin  and  France  discussed  in  the  previous 
section  show  that  flood  plain  restoration  potentials  are  huge  and  deliver  a  broad  range  of 
positive  impacts,  such  as  flood  protection,  clean  drinking  water  provision  and  recreation, 
with economic benefits estimated to be higher than the economic costs. However the upfront 
costs  are  usually  high  and  payback  periods  can  reach  up  to  20  years.  The  costs  range  from 
€5,000/ha  to  over  €100,000  /ha  depending  on  the  price  of  land  and  whether  major 
infrastructure works are required, i.e. dyke set back. 

The  annual  benefits  also  vary,  from  €500/ha  to  above  €10,000  /ha.  The  most  pronounced 
benefits  are  from  reduced  flood  damage  and  drinking  water  treatment.  Other  ecosystem 

59 

 
 
 
 
 
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service  provisions,  including  food  and  biomass  production  and  recreational  activities,  are 
more difficult to quantify. 

The estimates of flood plain restoration potentials in France (1.5 million ha around 2% of the 
country’s  surface)  and  the  Danube  river  basin  (1.4  million  ha  also  around  2%  of  the  basin 
surface) could be used to extrapolate the costs and benefits. The following assumptions are 
made for such an extrapolation: 

•  The average potentials in the Danube River Basin and France of 2% of surface 

would be representative for the EU; and  

•  The average costs and benefits from the three examples in Belgium, France and 

the Danube river basin would be representative for the EU. 

The results for the EU are: 

  Realising a restoration potential of 8.8 million ha of floodplains;  
  Requires investments of €24.1 billion per year from 2015-2030 resulting in a total 
cost for this period of €361.8 billion mainly for land purchase and infrastructure 
works; and 

  Delivers annual benefits of €39.3 billion in 2030 or total benefits of €295.0 billion for 
the period 2015-2030 mainly due to reduced flood damages, public water supply 
costs and increased tourism and recreation activities. 

3.2.4.  Synthesis of findings 

NWRMs such as flood restoration have large potential for achieving the WFD objectives. The 
estimated  numbers  for  the  associated  costs  and  benefits  presented  above  are  based  on  a 
simple  extrapolation.  They  indicate  that  the  restoration  potential  is  huge  and  could  help  to 
significantly  close  the  gap  to  reach  the  WFD  objectives,  though  further  research  would  be 
required  to  quantify  that.  The  actions  are  marked  by  high  upfront  investment  costs  and 
payback times can be over 10 years. 

Costs and benefits are unevenly distributed, for example in the case of flood protection and 
tourism  where  often  public  investment  would  lead  to  benefits  for  a  selected  group  of 
individuals, which can pose a feasibility challenge.  

3.3.  Case study for the re-use of wastewater 

This section presents the re-use of wastewater case study. It identifies the 
current problems and policy context pertaining to the re-use of wastewater, 
establishes the magnitude of the identified problems, and consequently 
assesses proposed avenues for improvement and the advantages of 
addressing the issue at the European level. 

The area ‘re-use of wastewater’ as described in the ToR, refers to the impact of possible future 
harmonised  rules,  taking  into  account  technological  advances,  on  the  efficient  re-use  of 
treated  wastewater  and  greywater128  for 
in 

industrial  purposes  and/or 

irrigation, 

128‘Grey’ water is generally defined as water that has been used in households, excluding water from 
toilets, i.e. water from sinks, showers and baths. 

60 

 
 
 
 
 
 
 
                                                 
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households, for improving resource efficiency and water quality, as well as to mitigate water 
stress.  Therefore,  this  area  relates  primarily  to  water  quality  and  treatment  issues,  water 
stress  levels,  as  well  as  related  sectors  such  as  eco-efficient  industries  and  the  employment 
this could create via the need for water technology innovation and water infrastructure.  

3.3.1.  The problem and the policy context 

Pressure on freshwater sources is increasing around the world including in Europe. Climate 
change,  water  scarcity  and  population  growth  and  human  activities  all  exert  pressure  on 
European  water  resources.  Almost  all  Mediterranean  countries  regularly  experience  an 
imbalance  between  water  demand  and  water  supply  and  other  European  regions  also 
experience  irregular  periods  of  drought.  Periods  of  water  shortage  are  becoming  more 
frequent  and  longer  –  e.g.  France,  Bulgaria,  Malta,  Belgium,  and  the  UK  have  suffered 
successive droughts over the last twenty years.129 One way of reducing fresh water demand 
is  to  increase  the  re-use  of  grey  and  wastewater.  This  water  can  replace  freshwater 
consumption  in  a  number  of  applications  such  as  irrigation  in  agriculture,  industrial 
processes, non-potable urban applications (e.g. fire protection, toilet flushing), groundwater 
recharge and some recreational purposes. As can be seen in Figure 6, electricity generation, 
for  example,  currently  does  not  make  use  of  re-used  water.  Agriculture  currently  sources 
about  two-thirds  of  its  water  needs  from  reclaimed  water,  yet  this  sector  is  still  –  together 
with electricity generation – the largest consumer of conventional water resources. 

Figure 6: Water use and re-use of European countries by application 

Legend: AGR: agricultural irrigation, GWR: groundwater recharge, IND: industrial use, ELE: electricity 
generation, PWS: public water supply, ECO: ecological/environmental enhancement, URB: urban and 
domestic uses 
Source: TYPSIA (2012). Service contract for the support to the follow-up of the Communication on Water 
scarcity and Droughts: WASTEWATER RE-USE IN THE EUROPEAN UNION 

129 TYPSA (2013) Updated Report On Wastewater Reuse In The European Union. 

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Cost of Non-Europe Report 

The  following  table  (Table  3)  presents  a  summary  of  water  reclaim  and  use,  by  sector  and 
Member State (MS). This overview demonstrates that in those Member States where water re-
use  is  practiced  there  are  country-specific  standards  in  place.  In  the  majority  of  the  EU 
countries,  water  is  re-used  in  the  industrial  sector.  Water  re-use  in  agriculture  and  for 
municipal  purposes  also  occurs  in  some  of  them.  Most  Member  States  have,  or  are 
considering, plans for the future implementation of water re-use.  

Table 3: Water re-use by sector and MS (EU27),  
including relevant national regulations/guidelines 

MS 

Agri-
culture 

Munici
-pal 

Potable 
Unplanned 
Indirect 
Re-use 

Ground-
water 
recharge 

Industry 

Environ-
ment 

Future 
plan 

Desalina-
tion 

Regulations
/ Guidelines 

AU 
BE 
BG 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IT 
IE 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
UK 

X 

X 

X 
X 
X 

X 

X 

X 

X 
X 

X 

X 
X 

X 

X 

X 

X 
X 

X 

X 
X 

X 

X 

X 

X 

X 

X 
X 

X 

X 

X 
X 
X 

X 
X 
X 
X 

X 
X 
X 
X 
X 
X 

X 

X 
X 
X 

X 

X 
X 
X 

X 
X 
X 

X 
X 

X 
X 
X 
X 
X 
X 
X 
X 
X 
X 
X 
X 
X 

X 
X 
X 
X 

X 

X 
X 
X 

X 

X 
X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

No 
Under Prep. 
Under prep. 
Yes 
No 
No 
No 
No 
Yes 
Under prep. 
Yes 
Yes 
Yes 
No 
No 
No 
No 
Under prep. 
No 
Under prep. 
Yes 
No 
No 
No 
Yes  
No 
Under prep. 

Source: TYPSA (2013) Updated Report On Wastewater Re-use In The European Union, p.7 

The re-use of water is covered (directly or indirectly) by the WFD and the UWWTD and it is 
also part of the WS&D policy recommendations put forward by the EC:130 

a)  The UWDTD requires that “treated wastewater shall be re-used whenever appropriate” 
under the requirement of “minimising the adverse effect on the environment” in light of 

130 TYPSA (2012). Service contract for the support to the follow-up of the Communication on Water 
scarcity and Droughts: WASTEWATER REUSE IN THE EUROPEAN UNION 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Water Legislation 

the objective of its first article which is defined as the protection of the environment from 
the adverse effects of wastewater discharges. 

b)  The WFD refers, under Annex VI (v) to “emission controls” and under Annex VI (x) to 
“efficiency and re-use measures, inter alia, promotion of water efficient technologies in 
industry and water saving techniques for irrigation”, as two non-exclusive list, 
supplementary measures. 

Reclaimed water is also covered by other EU legislation with the coverage dependent upon 
the final use. For example, irrigation and “green agriculture” in general fall under the scope 
of  the  Common  Agricultural  Policy  (CAP)  (see  textbox  in  section  3.5),  while  the  quality 
standards for potable water are set by the DWD.  

In terms of identified obstacles to water re-use, these include: 

• 
• 

• 

a lack of international standards; 
scattered references to different issues of water re-use across various EU and 
national level regulations across multiple sectors; 
some national standards are criticised for being too stringent and hence creating 
barriers to an expansion in water re-use131; 

•  need for synchronisation on standards related to health risks132; 
•  new quality standards between water re-use and the DWD and food safety 

legislation in cases where recycled water is to be used directly or indirectly for 
consumption133; and 
insufficient awareness and training on this issue amongst the key stakeholders 
(incl. farmers and the general public).134  

• 

3.3.2.  Potential and effects of EU coordination 

The use of treated wastewater should be regarded as a way of increasing water availability 
(by  reusing  already  abstracted,  treated  and  delivered  water  rather  than  using  freshly 
abstracted,  treated  and  delivered  water)  and  can  therefore  contribute  to  improving  the 
quantitative  element  of  good  ecological  status  for  some  water  bodies.  Hence,  it  is  being 
considered  as  an  option  in  the  RBMPs  (as  part  of  the  PoMs)  to  be  established  as  part  of 
implementing the WFD. In addition, reusing waste water helps reduce water pollution.135 It 
can  lead  to  nutrient  recycling  e.g.  when  reusing  urban  waste  water  for  irrigation  in 
agriculture, it can reduce the need for fertilisers. The cost-effectiveness of waste water re-use 
depends on the amount of pollutants which need to be removed, which creates incentives to 
reduce  pollution  at  source.  Nevertheless,  in  the  case  of  waste  water  re-use  for  irrigation  in 
agriculture, this does not reduce water consumption. Waste water, which would have been 
returned  to  the  environment,  is  instead  ‘consumed’  by  agriculture  and  is  thus  missing 
downstream.  On  the  other  hand  other  abstractions  will  be  replaced,  leading  to  a  net  zero 
effect on the hydrological cycle at best if irrigation agriculture does not increase due to waste 
water  re-use.  Therefore  experts  recommend  the  establishment  of  a  water  saving  hierarchy 

131 EurEau (2009) EurEau position on water reuse for irrigation as a water scarcity solution 
132 EurEau (2011) EurEau Position Paper Water re-use and other alternative resources at home: 
rainwater harvesting and greywater recycling for domestic purposes 
133 EurEau (2011) EurEau Position Paper Water re-use and other alternative resources at home: 
rainwater harvesting and greywater recycling for domestic purposes 
134 See EEA (2012) European waters — current status and future challenges Synthesis 
135 Interview with Peter Pollard (15/9/14) 

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(for  example  similar  to  the  waste  hierarchy  -  reduce,  re-use,  desalinate,  transfer)  to  ensure 
that measures which actually reduce water consumption are given high priority.136 

In the relevant paragraphs of the WFD (Annex VI (v)) there is no explicit requirement to use 
a  specific  type  of  water,  for  a  specific  purpose;  the  only  requirement  concerns  the 
achievement of quality standards defined in the directives – so wastewater and/or greywater 
could  be  used.  In  addition  to  this  overarching  European  framework,  however,  there  are  a 
number of EU water-related directives already requiring specific standards for specific water 
uses, which are listed in the following table along with their respective re-use applications. 

Table 4: EU water-related directives requiring specific standards for specific water uses, 
along with the different re-use applications 

Wastewater 
re-use 

Agricultural 
irrigation 

Groundwater 
recharge 
Urban 
applications 
Indirect 
potable re-use 
Recreational 
water use 
Environmental 
enhancement 
Aquaculture 

Major concern 

Pollution of soil, groundwater and produce with 
chemical/bio-hazardous substances 
Health risk for workers and consumers 
Health concerns if potable re-use is intended 

Health concerns regarding exposed persons 

A 

X 

B 

X 

Related EU Directive 
C*  D 

E  F*  G*  H* 

X 

X 

X 

X 

X 

Health concerns 

X 

X 

Health concerns, infection risks for exposed 
persons 
Detrimental effects on the biocenosis 

Contamination of water and produce with 
chemical/bio-hazardous substances 

X 

X 

X 

X 

X 

X 

Legend: A = Sewage Sludge Directive; B = Nitrate Directive; C = Groundwater Directive; D = Drinking 
Water Directive; E = Bathing Water Directive; F = Surface Water Directive; G = Freshwater Directive; H 
= Shellfish Water Directive (C, F, G, H to be repealed under WFD latest by 2013) 

Proposals for improved guidance or regulation on the re-use of wastewater 

The  European  Commission  suggested  developing  EU  standards  for  water  re-use  –  the 
Blueprint  considered  different  policy  options  such  as  development  of  standards  by  the 
European  Committee  for  Standardisation  or  the  adoption  of  an  EU  regulation  establishing 
water  re-use  standards.137  EurEau  suggested  an  EU  guidance  framework  in  order  to  better 
manage  risks  by  describing  best  practice  for  irrigation  with  reclaimed  water  and  further 
research and development of site-specific recommendations for the re-use of greywater and 
harvested  rainwater  for  domestic  purposes.  In  the  latter  case  the  organisation  called  for  a 
detailed  assessment  (economic,  environmental,  health  etc.)  of  the  options  for  adapting  the 
existing water systems to a re-use cycle and for other measures, specifically relating to urban 
conditions where a water system is already in place. EurEau also see potential in the re-use of 
sludge from wastewater treatment in agriculture as an option for soil fertilization and as such 
have  called  for  an  update  of  the  Sewage  Sludge  Directive.  The  European  Water  Platform 

136 Interviews with EEB (5/6/14), Ecologistas en Accion(9/9/14) in writing and Pierre Strosser(25/9/14) 
137 EC [SWD(2012) 382 final] IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to 
Safeguard Europe's Water Resources, part 1, p.39 

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(WssTP) have also called for further examination of the potential to use reclaimed water for 
urban purposes such as park irrigation, street washing, fire-fighting etc.. 

There  are  standards  regarding  water  re-use  elsewhere  in  the  world,  for  example  the  World 
Health  Organisation  (WHO)  guidelines,  California  Recycled  Water  Regulations  and 
Guidance  and  the  Australian  Regulations  and  Guidelines.  The  majority  of  these  relate  to 
quality  standards  for  water  re-use  in  agriculture  and  for  non-potable  use.  The  current 
legislative  framework  does  not  set  binding  requirements  for  water  re-use  in  the  EU.  The 
Blueprint  and  a  number  of  stakeholders  have  called  for  the  establishment  of  common 
standards by the EC. 

Some  Member  States  have  legislation  in  place  which  deals  with  water  re-use  in  different 
sectors. The experience of different EU countries could be used for the establishment of EU 
standards.  For  example,  the  French  regulations  for  irrigation  with  reclaimed  water  use  the 
WHO  Guidelines  but  also  add  restrictions  for  some  techniques  and  distances  between 
irrigation  sites  and  residential  areas  and  roadways.  Some  other  Member  States  are  already 
considering  adopting  the  same  guidelines.  There  is  generally  less  experience  with  setting 
financial incentives for water re-use – some German regions provide subsidies for rainwater 
capture  and  re-use,  while  the  UK  and  France  offer  tax  reductions  to  incentivise  industry  to 
re-use water. 

3.3.3.  Potential building blocks for illustrating the costs of non-Europe 

Increased  re-use  of  wastewater  can  help  reduce  the  costs  caused  by  water  scarcity.  The  EU 
Water  Scarcity  and  Drought  working  group  estimated  that  the  overall  economic  impact  of 
drought events in the last 30 years at the EU level was around €100 billion. Results show that 
the  annual  average  impact  has  doubled  between  1976-1990  and  1991-2006.  It  reached  an 
average of €6.2 billion per year in the last few years, with an exceptional cost of €8.7 billion in 
2003. If the EU had achieved a 20% treated wastewater re-use target for irrigation to reduce 
water scarcity in Europe, this could have reduced the economic impact of drought in the EU 
by €20 billion in the last 30 years.138 

Increasing waste water re-use could deliver the following potential benefits:139 

•  Reduced demand for treated fresh water – with consequent energy savings 
(because the water does not need to be treated or pumped140) and reduced 
need for abstraction; 

•  Reduced cost of water supply - for consumers with a metered supply; 
•  Reduced drainage / public treatment costs and flows - where the water being 

re-used is kept out of the public drainage / sewerage system; and 

•  Reduced pollution / nutrient recycling. 

138 TYPSA (2012). Service contract for the support to the follow-up of the Communication on Water 
scarcity and Droughts: WASTEWATER REUSE IN THE EUROPEAN UNION. Please note that these 
estimations only cover economic costs and do not include social and environmental costs due to a lack 
of data. 
139 European Water Association (2007), Water Reuse in Europe, www.ewa-
online.eu/tl_files/_media/content/documents_pdf/Publications/E-
WAter/documents/21_2007_07.pdf 
140 For example 5.8% of total electricity consumption in Spain is for water use - Hardy, L., Garrido, A. & 
Juana, L. (2012) Evaluation of Spain’s Water-Energy, Nexus. International Journal of Water Resources 
Development. 28: 151-170 

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Potential additional costs involved in water re-use activities include: 

•  The energy and resources needed to treat the recovered water – which vary 

according to the required end use; and 

•  The need to dispose of any contaminants removed from the recovered water.  

Large variation in cost-effectiveness of re-used wastewater per application area 

Re-used wastewater exhibits large variations in cost-effectiveness depending on the sector, as 
well  as  the  necessary  collection  and  treatment  technologies.  Furthermore,  the  value  of 
wastewater re-use may depend on water availability at a given time and place.  

The  economic  value  of  treated  wastewater  in  a  sectoral  application  can  be  assessed  by  the 
corresponding conventional water price or the added value generated by the specific sector. 
The  economic  analysis  (according  to  WFD,  Article  5)  should  regard  water  as  a  production 
factor such  as  material,  work,  energy,  etc.  and  hence  be  able  to  put  a  figure  to  the  value  of 
(reclaimed)  water.  For  example,  a  report  by  Global  Water  Intelligence  (GWI) 141  states  that 
water used in certain industries generates 70 times more value than one cubic metre of water 
used in agriculture. 

Life  Cycle  Cost  analysis  is  a  useful  way  to  evaluate  the  conditions  under  which  treated 
wastewater  re-use  can  be  cost  effective  and  in  comparing  cost  performances  of  different 
collection  and  treatment  technologies  and  investment  strategies.  The  cost  estimates  include 
the  cost  of  a  product  over  its  entire  lifespan,  including  capital  costs,  annual  operation  and 
maintenance  costs.  Total  treated  wastewater  life  cycle  cost  is  converted  into  €/m3  for 
comparative  purposes.  Treated  wastewater  system  costs  are  a  function  of  facility  capacity, 
end-use  application  and  water  quality  requirements  for  each  re-use  alternative.  A  range  of 
costs estimated by Asano (1998) are presented in table 5 below. 

Table 5: Range of life cycle costs for treated wastewater re-use,  
per different collection and treatment technologies 

Source: costs estimated by Asano (1998) where (a): Costs are estimated for facility capacities ranging from 4,000 
to 40,000 m3/d. Lower cost figures within each treatment process category represent cost for a 40,000 m3/d 
reclamation plant while the upper cost limit is presented for a 4,000 m3/d facility, (b): Annual costs include 
amortized capital costs based on a facility life of20 years and a return rate of 7 %. 

141 Global Water Intelligence. Desalination Markets 2007. P15. www.globalwaterintel.com 

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While some rough estimates can thus be given for the cost-effectiveness levels of water re-use 
per  sectoral  application,  these  have  not  yet  been  actively  linked  back  to  potential  policy 
adjustments in terms of setting up more relevant EU or national level guidance or regulation. 

3.3.4.  Synthesis of findings 

This  case  study  has  demonstrated  potential  avenues  for  improving  standards  and  cost-
effectiveness of wastewater re-use in Europe. In particular, increased re-use can play a role in 
reaching the WFD and other related objectives by reducing the negative impacts of droughts 
and  water  scarcity,  increasing  minimum  flows  and  reducing  abstraction.  In  the  broader 
picture, this approach only addresses a very specific and small part of the quantitative issues 
and potential future health impacts identified during this study. Therefore, on its own, this 
approach may not have sufficient impact to close much of the current gap between existing 
water  policies  and  successful  implementation  levels.  We  would  recommended  placing  this 
approach within the larger context of the water efficiency and savings hierarchy (reduce, re-
use, desalinate, transfer) in order to increase impact and better connect to other EU priorities 
beyond the water field. 

Based on our analysis and expert interviews142, it can be concluded that there is no clear case 
for  regulation  to  promote  waste  water  re-use  at  EU  level  while  common  standards  for  safe 
use and a hierarchy of water saving approaches would deliver added value. National policy 
and regulatory revisions should play a more important role because in many cases water re-
use  primarily  helps  solve  problems  in  specific  regions  of  the  EU,  rather  than  significantly 
contributing to sustainable water management in broader terms. 

3.4.  Case study for Eco-design and water metering 

This section presents the case study for Eco-design and water metering. EU-
level eco-design and metering policy can help address a significant part of 
the quantitative issues identified in Phase I of this study. In addition it 
provides an important link to EU energy policy with significant 
environmental and economic impacts. Effectiveness of eco-design and water 
metering policies and regulations will be linked to economic instruments 
(discussed in Section 3.5). 

3.4.1.  The problem and the policy context 

Various human activities impose pressures on water resources in Europe while at the same 
time an increasing number of EU countries face longer lasting and more frequent droughts. 
Water  reclamation  and  more  efficient  water  use  are  both  options  to  safeguard  water 
resources.143 

In  July  2009  the  European  Commission  finalised  an  assessment144  demonstrating  that  the 
introduction  of  mandatory  requirements  on  water  using  devices  under  the  extended  Eco-

142 Interviews with EurEau (9/914);  EEB (5/9/14), Peter Pollard (15/9/14) and Pierre Strosser (25/9/14) 
143 EC [COM(2010)228 final] Second Follow-up Report to the Communication on water scarcity and 
droughts in the European Union COM (2007) 414 final. http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0228:FIN:EN:PDF 
144 BioIS & Cranfield University(July 2009) Study on water efficiency standards 

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design Directive could induce significant savings. If the policy scope was expanded to cover 
all  domestic  water  using  products,  a  19.6%  reduction  in  EU  total  public  supply  might  be 
achieved  (around  10%  if  only  energy-related  products  were  included  without  considering 
dishwashers and washing machines). This would correspond to a 3.2% reduction in the total 
annual EU abstraction. 

Eco-design for water-efficient products 

Following on from these 2009 findings, the European Ecodesign Directive145 and its daughter 
regulations  are  the  most  relevant  existing  legislation  regarding  efficient  water  use.  Even 
though  this  legislation  primarily  focuses  on  energy  use,  there  is  one  example  where  the 
minimum  requirements  were  extended  to  water  use:  the  Washing  Machines  Regulations146, 
where  maximum  water  consumption  is  defined.147  The  effect  of  this  regulation  is  therefore 
not only a reduction in CO2 emissions and energy savings but also expected savings in water 
consumption: compared to a business-as-usual scenario, the inclusion of the maximum water 
consumption definition in the Ecodesign Directive for washing machines is expected to result 
in annual savings of 83 million m3 (equal to saving one day of total urban water use in the 
EU).148  Similarly,  the  Dishwasher  Regulation,  while  not  placing  stringent  minimum 
requirements  with  regard  to  water  consumption,  has  defined  Best  Available  Technology 
(BAT). 

Reported  problems  with  the  implementation  of  the  Directive  and  its  implementing 
regulations  include  poor  market  surveillance  for  most  Member  States.149  Progress  with  the 
implementation of the Washing Machines regulation is unknown as this is a relatively new 
piece of legislation (having been introduced in 2010). 

The Eco-design Directive is currently in its 2nd Working Plan for the period 2012-2014, which 
identified  water-related  products  (e.g.  showers  and  taps)  as  products  to  be  considered 
between  2012  and  2014  for  adoption  of  implementing  measures.  Water  taps  and  shower 
heads were given the top ranking amongst twelve product groups in the work plan, with a 
potential annual energy saving of 885 PJ by 2030150 based on reduced heat demand linked to 
an annual water savings potential of 3,700 million m3  151 (equal to saving one month and four 
days of total urban water use in the EU). Nevertheless, progress has been limited, with only 
one product group, windows, being advanced by preparatory studies. The work on taps and 
showerheads  has  barely  begun.  Popular  opposition  to  the  EU  regulating  those  products  in 
some Member States has been named as one of the reasons for the delay.152 

145 DIRECTIVE (2009/125/EC) establishing a framework for the setting of ecodesign requirements for 
energy-related products 
146 REGULATION ((EU) No 1015/2010) implementing Directive 2009/125/EC with regard to ecodesign 
requirements for household washing machines 
147 EC (2010) SWD SUMMARY OF THE IMPACT ASSESSMENT Accompanying document to the Draft 
Commission Regulation (...) with regard to ecodesign requirements for household washing machines 
148 CSES & Oxford Research (2012) Evaluation of the Ecodesign Directive (2009/125/EC)  Final Report 
149 European Council for Energy Efficient Economy (ECEEE) webpage: 
www.eceee.org/ecodesign/Horizontal-matters/eceee-pages-on-ecodesign-and-labelling-market-
surveillance/MSreport 
150 VHK (2011 Final Report Task 1-4 Study on Amended Working Plan under the Ecodesign Directive 
(remaining energy-using products and new energy-related products) 
151 Own calculation based on VHK 2011 
152 Interview with EEB (5/9/14) 

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In addition to the producer-driven approach of regulating maximum water consumption of 
relevant  products,  more  efficient  water  use  can  be  encouraged  on  the  consumer-side  via 
water  metering.  Over  the  past  10  years  there  has  been  a  marked  increase  in  the  amount  of 
information  provided  to  consumers  (e.g.  water-efficiency  labels  for  households’  appliances, 
information  on  efficient  lawn  watering  and  gardening  practices,  etc.)  as  well  as  for 
agriculture. Many countries, NGOs, large municipalities, water companies and international 
organisations have dedicated home pages to water conservation and water use behaviour. 

Higher water prices encourage water savings 

There has been a general trend towards higher water prices in real terms throughout Europe 
over  the  past  20  years.  Wide  variations  in  water  charges  exist  both  within  individual 
countries  and  between  EU  Member  States.  This  is  due  to  the  wide  range  of  factors  that 
determine  local  water  prices  and  the  level  of  recovery  costs.  For  example,  in  several 
countries, increased water prices decreased household water use significantly (see figure (a) 
below).  In  many  central  and  eastern  European  countries,  water  prices  were  heavily 
subsidised  until  1990.  After  1990,  there  was  a  marked  increase  in  prices  in  these  countries 
during  their  transition  to  market-economies,  resulting  in  lower  water  use.  In  Estonia,  for 
example,  water  prices  increased  markedly  after  subsidies  were  removed,  which  in 
conjunction with water measuring and application of more advanced sanitation devices, has 
led to a reduction of more than 50 % in water use over the past 15 years (see figure  below). 153 

Figure 7: Effect of water price on household use in Denmark 1985-2004  
and Estonia 1992-2004 

Source: (a) DEPA (2004) updated by EEA and (b) Estonian Environment Information Centre (2006) 

153 EEA. Policies and measures to promote sustainable water use. 
http://www.eea.europa.eu/themes/water/water-resources/policies-and-measures-to-promote-
sustainable-water-use 

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Measuring water use is a prerequisite for usage-based water pricing 

Measuring  water  use  is  a  prerequisite  for  water  prices  reducing  consumption.  Households 
with  water  meters  installed  generally  use  less  water  than  households  without  meters.  In 
Europe,  household  and  industrial  water  metering  continues  to  increase.  Many  North-
Western  European  countries  already  meter  the  majority  of  water  uses.  However,  in  some 
other  countries,  and  in  particular  in  relation  to  agricultural  water  use,  metering  is  still 
limited. 

3.4.2.  Potential impacts and role of EU coordination 

This  section  provides  information  on  existing  estimates  regarding  the  costs  and  benefits  of 
eco-design and water metering and the role and impact of existing and/or further EU-level 
coordination. 

Eco-design for water-efficient products 

The dishwasher and washing machine regulations outlined above are estimated to generate 
combined savings due to decreased water consumption in the range of €444-544 million per 
year.154 This clearly demonstrates the large potential for increased EU coordination. 

Nevertheless the scope of EU Eco-design is limited to energy-related products, which allows 
only a few water using products to be covered, like water taps and showerheads, which are 
directly related to significant energy consumption. More important water using devices, like 
toilets or irrigation equipment, are rather weakly linked to energy consumption and it would 
currently  be  difficult  to  cover  those  via  implementing  measures  under  the  Eco-Design 
Directive. This means that there is ample room for EU action towards setting water efficiency 
standards  for  these  devices,  which  should  result  in  further  significant  water  savings.  As  a 
first  step  minimum  performance  requirements  for  water  taps  and  showerheads  could  be 
established,  without  having  to  adjust  the  Eco-design  Directive.  The  energy,  water  and 
consumer  bill  savings  potentials  are  significant.  The  associated  water  saving  potential  is 
estimated  at  3.7  billion  m3  per  year  by  2030,  which  is  about  20-30  times  higher  than  the 
savings  from  dishwashers  and  washing  machines  and  would  mean  a  reduction  of  urban 
water  consumption  by  around  10%  for  the  EU  as  a  whole.  This  would  have  a  significant 
positive impact in improving the quantitative status of water bodies and reducing the need 
for  water  infrastructure,  like  dams,  reservoirs  and  transfers,  leading  to  morphology 
improvements.  In  addition,  energy  savings  of  885  PJ  per  year  may  be  expected  due  to 
reduced consumption of hot water, which would amount to a reduction of the EU’s energy 
consumption  by  2%.  The  multiple  benefits  of  energy  savings  include  water  savings,  which 
are  estimated  at  1,155  million  m3  per  year  by  2030155,  increased  energy  security  (each  1% 
energy savings lead to 2.6% gas savings156) and reduced greenhouse gas emissions. 

In  general  the  main  economic  impact  of  eco-design  is  on  the  consumers,  who  might  face 
higher  purchase  costs  but  lower  usage-related  costs.  In  the  case  of  showerheads  and  water 

154 Calculated using the water saving reported in the two IAs report. For dishwashers - 56 to 64 million 
m3 and for washing machines 64 to 83 million m3 water per year saved in 2020. Both IAs use an 
average water price of €3.7/m3, yielding annual savings of €207-237 million for the dishwasher 
regulation and €237-307 million for the washing machines regulation. 
155 Own calculation, based in World Energy Outlook 20102, water energy nexus 
156 EC (2014) accompanying Impact assessment to Communication on Energy Efficiency COM(2014)520 
final 

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taps, the payback time for products, which enable 10-20% savings, is estimated to be less than 
one year.157 The impacts of eco-design measures on industry are limited and mostly positive. 
A  study158conducted  a  survey  in  order  to  find  out  whether  and  to  what  extent  ecodesign 
impacts  companies’  profitability.  Although  not  targeted  specifically  at  the  EU  Ecodesign 
Directive,  this  study  presents  interesting  results.  96%  of  the  surveyed  companies  (most  of 
which  in  the  manufacturing  sector)  reported  that  ecodesign  had  either  positive  or  neutral 
effects on their profitability. They also reported other benefits associated with ecodesign such 
as improved recognition and reputation (more than 80% of the responding companies from 
the EU reported this is a benefit), greater employee motivation, better customer relations and 
greater capacity to develop new products. 

Water metering 

The  text  box  below  provides  cost  and  benefit  figures  from  various  studies  that  have  been 
conducted in the UK. This research sheds light on the large water savings potential that can 
clearly outweigh the additional costs involved in the installation, maintenance and usage of 
water meters. 

Box 1 - Research on costs and benefits of water metering in the UK 

The  2009  ‘Walker  Report’159  and  other  studies160  from  the  UK  considered  the  costs  and 
benefits  of  water  metering  in  the  UK.  The  UK  has  an  interesting  combination  of  metered 
and non-metered supplies. Meter installation is compulsory for new housing but consumers 
are broadly free to choose between a billing system based on property size or metered use. 
Overall  their  results  support  the  conclusion  that  faster  rates  of  metering  penetration  (90% 
household  meter  penetration  by  2030)  could  be  ‘significantly  beneficial  for  customers  and 
the environment’, especially in areas where it is expensive to supply water. Metering clearly 
led to demand savings; these savings persisted over time. 

Water  metering  has  demonstrated  advantages  in  encouraging  water  savings,  it  helps 
identify leaks in the supply pipeline, it can help in the development of more sophisticated 
tariffs  and,  more  generally,  it  provides  more  information  to  customers  and  suppliers  on 
water usage. 

Quantified  benefits  can  be  summarised  as  follows:  average  total  water  saving  via  water 
metering amounts to around 25 litres per person per day (22 cubic meters per household a 
year). On a UK level this translates into substantial water savings of around 16% of average 

157 VHK (2011) Final Report Task 1-4 Study on Amended Working Plan under the Ecodesign Directive 
(remaining energy-using products and new energy-related products) 
158 Pôle Éco-conception et Management du Cycle de Vie & Institut de développement de produits (2014) 
Profitability of Ecodesign: an Economic Analysis, Highlights from 
http://cloud.snappages.com/b0d6d10923becba07c0287d0b0af8fd47ed8a57d/Profitability%20of%20eco
design_highlights_1.pdf 
159 The independent review of charging for household water and sewerage services: Final report’, UK 
Department for Environment, Food and Rural Affairs, December 2009 
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69459/walker-
review-final-report.pdf 
160Ofwat (2011) Exploring the costs and benefits of faster, more systematic water metering in England 
and Wales from http://www.ofwat.gov.uk/future/customers/metering/pap_tec201110metering.pdf.  
Herrington, P (2006). ‘Critical review of relevant research concerning the effects of charging and 
collection methods on water demand, different customer groups and debt’.05/CU/02/1. UKWIR 

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household  demand.  More  specifically,  the  studies  found  a  reduced  consumption  of  on 
average  15  litres  per  person  per  day  (13  cubic  meters  per  household  a  year).  In  addition, 
they noted a reduction in customer supply pipe leakages averaging ca. 10 litres per person 
per day (9 cubic meters per household a year).  

Water metering implies additional costs to the water industry. These costs mainly include: 
installing the meter (financing of the installation costs), costs of replacing the meter when it 
wears out, costs related to meter reading, and the costs of additional customer billing and 
services related to water metering. 

Though  much  variation  exists  in  the  attempts  to  quantify  costs,  on  average  the  additional 
costs of water metering amount to about £30 per household per year (see figure 8 below for 
an illustrative cost breakdown). 

Figure 8: Composition of typical effects on bills for household measured charging  
based on installation of a simple meter 

Source: ‘Walker Report’ (2009) 

Potential  impacts  of  future  binding  water  metering  across  all  sectors  and  users  in  the 
European  Union  should  be  assessed  in  terms  of  their  water  savings  potential  and 
corresponding cost-benefit ratio. 

Smart  metering,  where  the  meter  has  a  remote  data  connection  to  the  supplier  and  the 
customer  can  also  receive  live  information  on  consumption,  is  expanding  in  electricity  and 
gas  supply  across  Europe  and  elsewhere.  There  are  some  initial  trials  on  this  occurring  for 
water  metering,  for  example  in  the  UK.161  The  main  benefit  in  water  is  that  it  should  help 
water  companies  identify,  and  hence  tackle  and  recue  leakage.  For  consumers  it  could 
indicate  if  their  consumption  becomes  excessive,  for  example  due  to  a  leak  on  their  side  of 
the meter, and enable them to address this issue and avoid large water bills. An Australian 
review162  of  the  benefits  of  smart  metering  for  water  identified  some  benefits  (as  described 
above, but found that there was a lack of data to carry out a detailed cost benefit analysis. It is 
hoped that the current trials will help address this lack of data. 

161 www.thameswater.co.uk/media/press-releases/17391.htm  
162 www.swan-forum.com/uploads/5/7/4/3/5743901/smart_metering_cost_benefit.pdf  

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3.4.3.  Potential building blocks for illustrating the costs of non-Europe 

As  demonstrated  by  the  Eco-design  policy,  the  EU’s  internal  market  instruments  offer 
significant additional potential to increase the efficiency of water using products and reduce 
fresh  water  abstractions  for  public  water  supply,  which  can  help  improve  the  quantitative 
status of many bodies of water and to reach the WFD objectives. It also provides a case for 
positive  reinforcement  of  energy  and  water  policies,  which  can  help  to  reduce  conflicts  on 
those sectors. 

As  discussed  above,  the  savings  potential  of  shower  heads  and  water  taps  is  estimated  to 
reach an annual 3.7 billion m3 and 885 PJ primary energy (equivalent to 98 TWh final energy) 
by 2030.  

What are the financial benefits? 
Assuming  a  constant  average  water  price  in  the  EU  of  €3.7  /m3,  the  savings  on  water  bills 
would  reach  €13.6  billion  per  year  in  2030.  The  energy  savings,  assuming  today’s  average 
price of €0.2 /kWh, would result in energy bill reductions of €19.6 billion per year. 

  Annual savings of €2.2 billion for each €1.0 billion invested to replace old shower 

heads and water taps with more efficient ones, and  

  Total savings 2015-2030 of €248.9 billion.  

What are the financial costs? 
The  savings  potential  has  been  calculated  assuming  normal  replacement  rates  of  shower 
heads and water taps, average product lifetime and assuming an average additional cost of 
€9.3 /unit for the higher performing products. 

  Annual investment costs of €1.0 billion in 2015 which reaches €3.0 billion in 2025, and 

  Total investment costs of €16.9 billion for the period 2015-2030 for replacing all old 

shower heads and water taps with more efficient ones. 

When  assessing  the  potential  costs  of  non-Europe  with  respect  to  water  metering,  the 
following rough estimations can be made. Using the water savings and cost data available for 
the  UK  as  presented  in  Box  1  some  rough  estimations  on  the  overall  benefits  and  costs  of 
water metering can be made.  

What are the financial benefits? 
Assuming a constant average water price in the EU of €3.7/m3 and water savings of 22m3 per 
household  per  year  the  estimated  annual  cost  savings  per  household  are  €81.4.  The  total 
number  of  households  in  the  EU28  reported  for  2013  by  Eurostat163  is  213  839.2  thousand. 
The exact number of households which already have a water meter installed is not available 
but assuming that only one-third164 of the total get water meters the potential in the EU28 is: 

  Annual savings of over €0.4 billion from investing €0.2 billion to install water meters, 

and  

163 Eurostat (2014) Number of private households by household composition, number of children and 
age of youngest child (1 000), last updated on 29.04.2014 and available at 
http://appsso.eurostat.ec.europa.eu/nui/submitViewTableAction.do 
164 This is a rather conservative estimate. Based on most expert judgment it is likely that over 50% of 
households are equipped with a water meter across the EU-28. 

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  Total savings of around €43.5 billion for the period 2015-2030 if one third of EU 

households had water meters installed. 

What are the financial costs? 
Assuming  the  additional  costs  of  water  metering  are  £30  or  around  €35.3 165  per  household 
per  year,  this  implies  the  costs  of  water  metering  add  up  to  around  50%  of  the  potential 
annual  savings.  Applying  the  assumption  that  only  one  third  of  the  households  in  the  EU 
install water meters the EU28 costs are: 

  New annual costs of €0.2 billion to install water meters in one third of EU households 

between 2015 and 20130, and 

  Total costs for the period 2015-2030 of €18.9 billion.  

Such illustrative projections have to be treated with care due to the system interactions and 
feedback  loops.  It  is  therefore  difficult  (without  extensive  additional  work)  to  present 
accurate  estimates  of  the  net  benefits.  Public  water  supply,  collection  and  treatment  are 
synonymous with high capital costs and low operational costs. Adjustment to a new system 
with  lower  water  demand  and  throughput  could  lead  to  even  higher  capital  and  lower 
operational costs. In the short run water unit prices could therefore increase and nullify large 
parts of the savings for households.  In the long run, the lower operational cost would then 
further  reduce  water  bills.  This  is  similar  to  the  energy  system  where  several  studies  have 
identified that different transition paths lead to similar total system costs. 166 The differences 
among  these  systems  can  be  measured  in  terms  of  their  co-benefits,  which  in  the  case  of  a 
water  supply  system  with  lower  demand,  would  be  higher  levels  of  water  protection  and 
ecosystem services, increased water security and resilience to climate and other changes. 

Finally it has to be mentioned that public and political acceptance of regulating performance 
of  water  taps  and  shower  heads  appears  to  be  important.  Complex  regulatory  designs  to 
address special products and uses and complementary measures to prepare the market will 
be required. In the case of water metering it is assumed that the number of households in the 
EU  will  remain  stable  until  2030.  Furthermore,  payback  time  is  assumed  to  be  relatively 
short, 1 year, but this is dependent on the type and cost of the metering device. 167  

3.4.4.  Synthesis of findings 

Both  eco-design  measures  with  regard  to  water  efficiency  and  water  metering  have  great 
potential  to  generate  savings  from  reduced  water  use,  primarily  for  households.  The 
associated  costs  of  these  measures  are  considerably  lower  than  the  potential  benefits. 
Nevertheless, estimations for the entire EU need to be made with caution. 

165 Estimated using the average ECB exchange rate for 2013 –0.85 £/€. Annual ECB exchange rates 
available at 
http://sdw.ecb.europa.eu/quickview.do;jsessionid=41684658E2CEACB9DABC182145CD8E8F?SERIES
_KEY=120.EXR.A.GBP.EUR.SP00.A 
166 E3Mlab (2014) Development and evaluation of long-term scenarios for a balanced European climate 
and energy policy until 2030. 
167 For example, EC [SWD(2012) 382 final](2012) IMPACT ASSESSMENT Accompanying the document 
(...) A Blueprint to Safeguard Europe's Water Resources, part 2, p.55 reports that the price of metering 
devices can vary between €35 and €350. 

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3.5.  Case study for economic instruments 

This section covers the case study for economic instruments. Firstly, the 
current problems and policy context related to the use of economic 
instruments are identified. Secondly, the magnitude of these issues and the 
potential for addressing them on an EU-level are presented. 

3.5.1.  The problem and the policy context 

Water stress and water pollution still pose serious problems for the achievement of the Good 
Status objective of the WFD. At present, water pricing levels do not appear to be high enough 
to  incentivise  sustainable  water  use,  although  the  use  of  economic  instruments  to  reduce 
water use is raised in the WFD. Article 9 of the WFD asks MSs to take account of the principle 
of cost recovery from water services and hence to ensure appropriate water pricing schemes 
and  contributions  from  all  users  to  enable  cost  recovery,  including  the  application  of  the 
polluter-pays-principle, by 2010. This aim is supported by the economic and impact analysis 
required under Article 5 by 2004.168 

The EC’s RBMPs report169 and the Blueprint170 state that the use of economic instruments is 
insufficient to achieve sustainable water use. The Blueprint reports that this is mainly due to 
subsidies  in  other  policy  areas  such  as  bioenergy,  agriculture,  construction  of  dams  etc., 
which  may  alter  relative  prices  and  thus  lead  to  excessive  consumption  or  pollution  of  the 
water bodies. Further impediments are posed by insufficient knowledge regarding the use of 
such economic instruments, lack of transparency in the calculation of costs and subsidies and 
lack  of  acceptance  or  historical  allocation  of  water  rights  that  prevents  the  introduction  of 
such  measures.171  Some  progress  in  improving  the  economic  transparency  of  water 
management  was  noted  for  France  but  also  for  some  German  states,  though  this  was  not 
necessarily reported to the European Commission.172 

The  assessment  of  the  submitted  RBMPs  shows  that  some  of  them  already  include 
modifications of the water pricing systems or measures to strengthen water metering in order 
to promote sustainable water use.173 The EEA report that the current water pricing schemes 
ensure a generally high rate of cost recovery in the domestic sector but a lower level of cost 
recovery in agriculture.174 The EEA also report that water service companies manage to cover 
their  costs  but  have  limited  extra  funds  for  renewal  and  replacements  of  existing 

168 EC (2003) Common Implementation Strategy for The Water Framework Directive (2000/60/EC) 
Guidance Document No 1: Economics and the Environment – The Implementation Challenge of the 
Water Framework Directive - guidance document on Article 5. EC (2004) Common Implementation 
Strategy Working Group 2B: Drafting Group ECO1 Information Sheet on Assessment of the Recovery of 
Costs for Water Services for the 2004 River Basin Characterisation Report (Art 9) – guidance document 
on Article 9 
169 EC [COM(2012) 670 final] Report (...) on the Implementation of the Water Framework Directive 
(2000/60/EC) River Basin Management Plans – pp.10-11 
170 EC [COM(2012) 673 final] A Blueprint to Safeguard Europe's Water Resources 
171 EC [SWD(2012) 382 final]]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to 
Safeguard Europe's Water Resources 
172 Interview with Pierre Strosser (25/9/14) 
173 EC [SWD(2012) 382 final]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to 
Safeguard Europe's Water Resources 
174 EEA (2013) Assessment of cost recovery through water pricing 

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infrastructure175 while the level of leakages from the distribution systems remains a serious 
issue in the EU.176 

The low level of economic instrument use (as defined in Article 9 of the WFD) has also been 
attributed  to  the  lack  of  clear  definitions  or  targets  for  the  recovery  of  the  costs,  which 
impedes  wider  implementation,  reporting  and  progress  monitoring.177  There  is  also  some 
debate  as  to  how  much  the  “polluter  pays  principle”  applies,  for  example,  with  regard  to 
domestic consumers. In the case of large industrial and agricultural consumers this principle 
can  be  applied  in  a  straightforward  way  –discharged  water  should  meet  the  quality  norms 
otherwise the user is fined. In the case of domestic users it is hard to link the exact user to the 
volume  of  polluted  water  that  is  discharged.  Therefore,  domestic  users  are  charged  by  the 
“user pays principle”.178  

In light of these findings, the proposed policy options in the Blueprint focused on providing 
further guidelines on economic instruments (including some voluntary labelling of products 
based  on  water  footprint  and  life-cycle  impacts  of  products  and  water  trading  schemes 179), 
better enforcement of existing legislation (primarily related to water quality standards) and 
including  water  efficiency  conditions  in  the  proposed  Common  Agricultural  Policy  (CAP) 
reform (see Box 2 below).  

Box 2 - The CAP and its reform180 

The  CAP  has  two  pillars:  pillar  1  relates  to  direct  payments  to  farmers,  while  pillar  2 
supports the development of rural areas through the Rural Development Programmes and 
the  European  Agricultural  Fund  for  Rural  Development  (EAFRD).  The  proposed  CAP 
reform  included  provisions  for  the  inclusion  of  environmental  indicators  as  conditions 
under  the  two  pillars.  In  the  context  of  the  European  water  policy  the  Blueprint  proposed 
the  inclusion  of  conditionality  regarding  ecological  focus  areas  under  pillar  1,  sustainable 
use of pesticides, reduction of illegal water abstraction and irrigation practices. In 2013 the 
European Council and Parliament agreed on the final reform and under the post-2013 CAP 
pillar  1  also  includes  “greening  rules”  for  farmers  (mainly  larger  farms).  The  “greening” 
component of the CAP requires: 

•  Crop diversification; 
•  Maintaining existing permanent grasslands; 
•  Having an ecological focus on at least 5% of the agricultural area. 

The IA carried out before the final agreement of the reform found benefits related to water 
quality  for  all  three  of  these  conditions.  However,  in  their  final  form,  these  conditions  are 
not specifically targeted to the status of water bodies.  

175 EEA (2013) Assessment of cost recovery through water pricing. EurEau (2014) Cost recovery in the 
WFD: WFD article 9, recovery of cost for water services.  
176 CEPS (2012) Which Economic Model For A Water-Efficient Europe? 
177 EurEau (2014) Cost recovery in the WFD: WFD article 9, recovery of cost for water services 
178 EWA (2008) The polluter-pays! But, for what? 
179 Trading schemes where stakeholders agree on mutually beneficial actions to transfer abstraction 
rights, share benefits etc. 
180 Source: EC (2014) Agriculture and rural development webpage: ec.europa.eu/agriculture/index_en.htm 

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3.5.2.  Potential impacts and role of EU coordination 

The exact size of the impacts from insufficient use of economic instruments within the WFD 
is unknown. For instance, the costs of water scarcity and droughts have not been estimated 
on  an  EU  level.  Total  costs  due  to  water  shortages  in  Cyprus  in  the  period  2010-2030  may 
reach  €200  million  (2009  prices).181  In  turn,  estimates  for  the  economic  costs  of  selected 
droughts in different regions of Europe in the period 1992-2011 range from €0.15 billion – to 
more than €11.6 billion.182  

Water  pricing  requires  a  volumetric  element  such  as  metering  in  order  to  ensure  that  there 
are  incentives  to  reduce  water  consumption  and  use  water  more  efficiently. 183  It  has  been 
estimated  that  both  households  and  farmers  who  pay  a  flat  rate  for  water  use  more  water 
than  those  who  pay  on  a  volumetric  basis  (1/3  more  for  households  and  10-20%  more  for 
farmers).  Flat  rates  are  still  widespread  in  the  EU  and  provide  no  incentive  for  sustainable 
water use.184 The manufacturing industry often directly abstracts water and the low or non-
existent prices they pay for abstraction do not provide an incentive for investments in water 
efficiency and savings.185 There are some concerns that without the introduction of dynamic 
elements, like bloc tariffs in water pricing the price signal becomes weaker over time which 
means that the long-term impact of water prices on households water demand should not be 
overestimated.186 

As incentive pricing is closely linked to water metering, which has already been discussed in 
section 3.4, the focus here is on economic instruments for addressing pollution and efficient 
water use. Water tariffs and pollution taxes targeting point-source pollution are some of the 
instruments  considered  most  appropriate  and  most  often  used  to  address  water  use  and 
quality.187  However,  as  evidenced  by  the  Dutch  example  (see  3  below),  taxes  may  also  be 
used  to  target  more  efficient  water  use.  In  Germany  and  Sweden,  taxes  also  serve  as 
incentives for investing in green infrastructure. Tax reductions and subsidies can also serve 
as  strong  incentives  to  improve  efficiency  of  water  use,  with  examples  of  such  schemes 
existing in the UK and Denmark.  

These  policy  options  are  only  applied  in  some  EU  countries  and  their  impacts  are  either 
unknown  or  are  only  available  for  the  Member  States  they  exist  in.  An  option  for  EU 
coordination is to use one or a combination of these examples and apply them on an EU-wide 
level. This could take the form of either guidelines (voluntary option) or binding legislation 
(a new directive – e.g. on NWRMs, or amendments to existing ones – e.g. WFD).  

3.5.3.  Potential building blocks for illustrating the costs of non-Europe 

It is important to note that the use of economic instruments is not a policy area but rather an 
approach to meet the water targets of the EU. Hence, making the same CoNE assessment as 
for the other case studies is not possible. Nevertheless, the other case studies examined in this 

181 EC [SWD(2012) 382 final]]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to 
Safeguard Europe's Water Resources 
182 Acteon (2012) Gap Analysis of the Water Scarcity and Droughts Policy in the EU, Final Report 
183 EC [SWD(2012) 382 final]]IMPACT ASSESSMENT Accompanying the document (...) A Blueprint to 
Safeguard Europe's Water Resources 
184 EEA (2013) Assessment of cost recovery through water pricing 
185 CEPS (2012) Which Economic Model For A Water-Efficient Europe? 
186 Interview with EurEau 9(/9/14) 
187 EEA (2013) Assessment of cost recovery through water pricing 

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chapter e.g. water metering, already present examples of building blocks for some economic 
instruments. 

3.5.4.  Synthesis of findings 

The use of economic instruments to promote efficient water use and reduce water pollution is 
closely  linked  to  other  issue  areas  such  as  water  metering  and  insufficient  integration  of 
water  into  other  policy  areas  such  as  agriculture.  Nevertheless,  experience  from  some 
Member  States  shows  that  different  economic  instruments  such  as  taxes  or  tax  abatements 
can contribute to meeting the goals of sustainable water use and reduce pollution. A first step 
at  the  EU  level  could  be  to  estimate  the  potential  effects  of  these  policies  if  applied  in  all 
Member States.  

Box 3 - Examples of economic instruments from selected Member States 

The Netherlands - addressing efficient water use188 
A  tap  water  tax  (2000)  is  charged  to  all  users  depending  on  quantity  used,  up  to  300m3  / 
year.  Taxes  are  charged  by  water  companies  and  paid  to  the  state  governments.  Taxes 
equate  to  approximately  €0.107  per  m3  (tap  water),  against  average  prices  of  €1.45  per  m3 
(households) and €1.07 per m3 (business). A groundwater tax (1995) is also charged to those 
that  abstract  groundwater  (mainly  water  companies  and  industry).  This  tax  equates  to 
approximately €0.131 per m3. Together the two taxes account for approximately 22% of the 
water price for industry and 16% of the water price for households, which has significantly 
increased  since  the  taxes  were  introduced.  These  taxes  have  contributed  to  reduced 
groundwater and  domestic water use since  1995, because of more efficient appliances and 
changing habits.  

The UK - addressing efficient water use189 
The Enhanced Capital Allowances (ECA) scheme allows businesses to write off 100% of the 
cost of certain water efficient technologies and products against taxable profits in the year of 
purchase. The objective of this scheme is to encourage businesses to invest in technologies 
and  products  that  use  water  in  a  sustainable  way.  The  UK  Government  provides  annual 
lists and key information on what technologies and products are eligible under the ECA. 

Denmark – addressing diffuse pollution from agriculture190 
Denmark introduced a pesticide tax in 1996 charging manufacturers and importers but also 
pesticide users. However, farmers get compensated for this tax through other instruments 
such  as  land  tax  abatements  and  agricultural  subsidies  resulting  in  no,  or  uncertain, 
reductions in pesticide use. A 2012 study considered an alternative approach –a subsidy for 
decreased  pesticide  use.  The  results  showed  that  farmers  respond  more  positively  to  this 
incentive than to a tax and almost twice as many farmers would reduce their pesticide use 
with a subsidy than with a tax. 

188 Source: Ecorys (2011) The role of market-based instruments in achieving a resource efficient economy 
189 Source: Defra(2014) ECA from www.gov.uk/government/publications/water-efficient-enhanced-
capital-allowances 
190 Sources: EPI Water (2011) Evaluating economic policy instruments for sustainable water 
management in Europe; EC Science for Environment Policy (2012) More than economic incentives 
needed to reduce pesticide use; The Danish Government (2013) Protect water, nature and human 
health: Pesticides strategy 2013-2015 

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Germany and Sweden – promoting the restoration of natural systems191 
One  third  of  German  cities  has  a  so-called  ‘rainwater  tax’.  This  tax  is  based  on  the 
permeability  of  the  ground  surface.  Tax  payers  can  receive  a  reduction  if  they  provide  for 
water retention and/or infiltration. This system is in part responsible for the amount of green 
roofs in the cities which have increased from 10 million m² in 1995 to 84 million m² in 1999. 

In Stockholm Sweden, the tax can be reduced by 50% if there is less or slowed-down run-off 
of  rainwater  to  the  urban  drainage  system.  If  the  building  has  no  need  for  the  public 
drainage system, one can receive a 100% reduction. 

3.6.  Case study for pharmaceutical residues 

This section presents the case study for pharmaceutical residues in water. It 
covers the current problems and policy context pertaining to the disposal of 
pharmaceuticals, establishes the magnitude of the identified problems, and 
consequently assesses proposed avenues for improvement and the 
advantages of addressing the issue on a European level. 

3.6.1.  The problem and the policy context 

Residue compounds from pharmaceuticals in water and soil have recently been identified as 
an  emerging  environmental  concern  by  a  number  of  organisations  including  the  European 
Environmental  Agency  (EEA)  and  the  World  Health  Organisation  (WHO).  Pharmaceutical 
substances  find  their  way  into  waters  and  soils  through  human  and  animal  discharge,  and 
disposal  of  unused  pharmaceuticals 
levels  of 
pharmaceuticals  in  water  are  very  unlikely  to  have  adverse  effects  on  human  health 
according to the WHO192, current trajectories of increasing concentration levels could lead to 
potentially harmful levels of substances in surface waters, sediments, and drinking water.  

into  sinks  and  toilets.  While  trace 

The  EU  policy  response  to  the  emerging  threat  is  slowly  gaining  traction.  The  main  policy 
vehicle  is  the  legislation  on  Priority  Substances  (PS).  Under  Article  16  of  the  Water 
Framework  Directive  (WFD,  2000/60/EU),  the  EU  decided  to  set  up  a  list  of  33  priority 
substances  that  were  considered  a  major  threat  to  European  waters  (see  decision 
2455/2001/EC). The list became annex II under the WFD. In 2008, the list was replaced with 
the  Priority  Substance  Directive 
(Directive  on  Environmental  Quality  Standards, 
2008/105/EC)  and  its  Annex  II.  The  Priority  Substance  Directive  sets  out  environmental 
quality standards (EQS) for surface waters and ranks the level of threat among the substances 
where  priority  hazardous  substances  are  of  most  grave  concern.  EQS  levels  are  to  be  met 
through  river  basin  management  plans.  The  goal  of  the  Priority  Substance  Directive  is  to 
reach ‘Good Chemical Status’ which entails that a water body must comply with EQS set out 
in the Annex to the directive. EQS set the maximum allowed concentration for the substances 
or pollutant in questions water, sediment or biota. The level set remains below a concentration 
that  has  proven  hazardous  for  human  health  and  the  natural  environment.  However,  ‘safe’ 

191 Sources:  International Green Roofs Policies from http://livingroofsworld.com/page22.php;  
ARCADIS (2012), Comparison of cost price of water/ waste water/ rain water for users in different EU 
Member States;  Science for environment policy (2012), Soil Sealing, in depth report, European 
commission 
192 WHO (2012) Pharmaceuticals in drinking water 
http://apps.who.int/iris/bitstream/10665/44630/1/9789241502085_eng.pdf?ua=1 

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levels  are  difficult,  if  not  impossible,  to  establish  due  to  lack  of  observed  or  modelled  data 
regarding the long-term effects from exposure to different pharmaceuticals on humans. 

The list of priority substances was reviewed and amended in 2011, following the revision and 
updating  of  the  WFD  and  the  Priority  Substance  Directive.  The  new  proposal  adds  15  new 
substances,  designation  of  particularly  hazardous  substances,  stricter  EQS,  new  biota 
standards, improved monitoring and reporting, and improved monitoring and a “watch-list” 
mechanism  for  future  possible  priority  substances  to  support  monitoring  for  future 
amendments to the list (COM(2011) 876 final). The updated directive on priority substances, 
including the watch-list, was adopted on July 2, 2013. 

Following the adoption of the revised Priority Substances Directive, 12 new substances were 
added  to  the  watch-list  and  for  the  first  time  three  commonly  used  pharmaceuticals  were 
introduced  namely  two  hormones  (17alphaethinylestradiol  and  17beta-estradiol)  and  a 
painkiller  (the  non-steroidal  anti-inflammatory  drug  (NSAID)  Diclofenac).  The  introduction 
of  these  pharmaceuticals  to  the  watch-list  means  that  their  levels  and  effects  will  be 
monitored  to  determine  whether  to  include  them  on  the  list  of  priority  substances  or  not. 
While  the  revised  PS  Directive  is  a  step  in  the  right  direction,  the  overall  lack  of  stronger 
emission  controls  following  article  16.6  in  the  WFD  shows  that  the  Commission  could 
improve on its work in this area. This is discussed at length in chapter 2.  

EQS for the new substances takes effect in 2018 and the aim is reach to good chemical status 
by  2027.  The  central  mechanism  for  implementation  are  the  river  basin  management  plans 
that  ought  to  include  the  revised  EQS  for  existing  substances  by  2015,  i.e.  excluding  the 
pharmaceuticals just added to the watch-list. 

Article 8c of the newly adopted revision193 of the WFD and the Priority Substances Directive 
spells  out  specific  provisions  for  pharmaceuticals.  It  requests  the  European  Commission  to 
develop  a  strategy  to  deal  with  pollution  in  water  by  pharmaceutical  substances  within  2 
years. The strategy should consider introducing stricter norms for taking the environmental 
effects of pharmaceuticals into account before introducing them to the market. It is also likely 
to suggest action on a MS level to address the environmental harm done by pharmaceutical 
residue in water, taking human health into particular account. 

3.6.2.  Potential impact and role of EU coordination 

Establishing the size of the problem, and the associated costs, is hampered by lack of data, in 
particular  on  an  EU-28  level.  (Eco)toxicological  effects  of  pharmaceuticals  are  not  well-
understood  and the monitoring of their release and concentrations in European waters and 
sediments is patchy at best, as most are not part of national routine monitoring programmes. 
Even less is known about the effects of smaller doses of pharmaceutical discharge over longer 
periods  of  time  on  humans  or  the  environment.  The  interaction  between  compounds  in 
nature is also scarcely understood. 

193 European Parliament legislative resolution of 2 July 2013 on the 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)0876 – C7-0026/2012 – 
2011/0429(COD))  

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Overall,  the  introduction  of  pharmaceuticals  to  the  watch-list  of  priority  substances  has 
opened up a number of possibilities with regards to selection and monitoring of substances. 
For example, in preparation for the review of the WFD and the Priority Substances Directive, 
four  ad  hoc  technical  support  studies  were  carried  out  to  assess  the  specific  impacts  from 
each  of  the  substances.  Of  the  four  substances  assessed  -  Diclofenac,  17  betaestradiol,  17 
alphaethinylestradiol  and  ibuprofene  –  three  were  added  to  the  watch-list  for  future 
monitoring  and  assessments.  The  table  below  summarises  the  findings  in  the  Impact 
Assessment (COM_SEC(2011)1547) for the three potential priority substances. 

Table 6: Summary of findings from IA for the three potential priority substances 

Substance 
17 alphaethinyl-
estradiol (EE2) 

17 betaestradiol 
(E2) 

Diclofenac 

Type/Use 
Pharmaceutical; synthetic 
steroid hormone used 
mainly in oral 
contraceptives. No 
production data available. 
Approximately 32 million 
women in EU use EE2-
based contraception. 

Steroid hormone: 
excreted naturally 
(approximately 90%) in 
human and livestock 
urine but also (<10%) as a 
result of pharmaceutical 
use (of which 90% from 
HRT). 
Pharmaceutical, used as 
NSAID. Average 
consumption 0.46 
g/person/year. 

Concern 

State-of-play in MS 

Endocrine disruptive; 
prolonged exposure to low 
concentrations of EE2 has 
been shown to cause sex 
changes, alterations in 
reproductive capacity, and 
ultimately population 
collapse in fish (Kidd et al, 
2007). 
Endocrine disruptive; 
chronic studies show 
effects on sexual 
development and fecundity 
in fish. 

Monitoring database 
contains data from 3 
countries, 2 showing 
exceedance of EQS, 1 
likely exceedance; 
literature predicts 
exceedances more 
widely. 

Monitoring database (2 
countries) and literature 
show exceedance of 
EQS. 

Toxic, directly (e.g. chronic 
studies show effects on gills 
and kidneys in fish), and via 
secondary poisoning, e.g. 
vultures in India affected by 
veterinary use in cattle. 

Monitoring and 
predictions show 
exceedances of the EQS 
in water in 7 Member 
States. 

Source: Table adopted from COM_SEC(2011)1547] SWD IMPACT ASSESSMENT (...)  
as regards priority substances in the field of water policy, p.12 

Two  notable  observations  can  be  made  from  the  overview  table  above.  First,  the  problem 
appears  to  be  sizeable.  For  example,  32  million  women  in  Europe  use  EE2-based 
contraception. Diclofenac has been blamed for causing tens of millions of death in vultures in 
India194 there are also numerous reports195 of impacts of EE2 on the aquatic environment in 
Europe. Second, the data availability for all three substances is poor, both in terms of spread 
and trends in use as well as the effects on human health.  

In summary, without sufficient data to monitor trends or the correct understanding of which 
substance  does  what  to  human  health  and  the  natural  environment,  selecting  which 
substances to put on the priority list is challenging. 

194 EEA, 2010.Pharmaceuticals in the environment Results of an EEA workshop. EEA Technical report, 
No 1/2010 
195 For example: Emerging lessons from ecosystems - Ethinyl oestradiol in the aquatic environment. 
www.eea.europa.eu/publications/late-lessons.../late-lessons-ii-chapter-13 

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3.6.3.  Potential building blocks for illustrating the cost of non-Europe 

Increased  EU  policy  coordination  on  pharmaceuticals  could  follow  a  number  of  scenarios 
with  different  cost  and  benefit  implications.  The  main  point  of  contention,  which  divides 
industries  with  a  stake  in  this  issue,  is  whether  the  problem  should  be  addressed  through 
water  legislation,  pharmaceutical  legislation  or  a  combination  of  both.  The  pharmaceutical 
industry  argues  for  covering  water  pollution  via  pharmaceutical  rather  than  environmental 
legislation  to  avoid  dual  legislation196  and  proposes  a  combination  of  upstream  measures  - 
such  as  use  controls  via  hospitals  -  when  found  relevant  in  combination  with  downstream 
measures; while the water industry and environmental NGOs argue for measures to prevent 
pollution at source, including product authorisations.197 The current policy trajectory, where 
three substances are put on the watch-list, could lead to their integration and addition to the 
list of Priority Substances. This would have legal requirements for Member States to monitor 
their  concentrations  in  surface  waters  and  to  test  if  they  exceed  EQS.  However,  this  would 
also mean that the allowed EQS would need to be established and agreed upon.  

The increased attention to pharmaceuticals requires different policy options to be considered. 
There  are,  broadly  speaking,  two  (non-mutually  exclusive)  policy  options:  end-of-pipe 
solutions and/or source (preventive) solutions. 

First,  technical  solutions  could  be  sought  to  filter  out  the  substances  in  water  treatment 
plants.  The  UWWTD  already  provides  a  legal  instrument  to  this  end.  Data  on  costs  for 
different options to reduce and remove pharmaceutical substances from water are scarce. The 
IA for the revision of the WFD and the Priority Substances Direction mentions two estimates 
for upgrading Urban Waste Water Treatment Plants (UWWTPs) to be able to handle E2,: in 
England  and  Wales,  €18  per  capita,  and  in  Switzerland  from  5%  to  25  %  higher  treatment 
costs compared to conventional treatment costs, or about €11 to €18 per capita per year.198 In 
another  study199,  researchers  at  the  Swiss  Federal  Institute  of  Aquatic  Science  and 
Technology (Eawag) argued that installing new end-of-pipe treatment in wastewater plants 
could  cost  €5  and  €30  annually  per  person.  The  numbers  show  the  large  uncertainty  range 
attributed to costs for technical solutions in treatment plants, but at least indicate that there 
are  substantial  investments  needed,  which  is  compounded  by  another  major  challenge  for 
end-of-pipe  solutions  which  is  that  different  compounds  may  require  different  treatment 
techniques.  The  Swiss  study  also  argued  that  the  new  treatment  technologies  also  involve 
10%  to  25%  higher  energy  use  than  conventional  technology,  and  this  needs  to  be  factored 
into  the  cost-analysis.  Some  pharmaceuticals  may  thus  be  removed  through  conventional 
technology currently in use for treatment of waste water, whereas others require completely 
new techniques yet to be developed, which implies high costs for research and development 
(R&D).  Besides  these  high-tech  solutions  there  are  experiments  and  examples  with 
alternative  solutions.  In  the  US,  for  example,  the  Minoa  Facility  has  been  described  as  an 
example  of  a  low  tech,  low  cost  and  high  impact  approach  to  address  pharmaceuticals.  It 
currently  removes  60  %  of  ibuprofen  and  20  to  30  %  of  estradiol  in  local  waste  water  by 

196 Interview with EFPIA (25/9/14) 
197 Interviews with EEB (5/9/14) and EurEau (9/9/14) 
198 EC [COM_SEC(2011)1547]SWD IMPACT ASSESSMENT (...) as regards priority substances in the 
field of water policy,p.49 
199 Adriano Joss (2008), quoted in 'Something in the water'. Chemistry World. Royal Society of Chemistry. 
Can be accessed at www.rsc.org/chemistryworld/Issues/2008/September/SomethingInTheWater.asp 

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filtering it through a constructed wetland containing a mix of bacteria. 200 This example shows 
the large differences in price, type, technology used and effectiveness of different approaches 
available to waste water treatment managers which makes the calculations of a global cost for 
implementing  end-of-pipe  solutions  inherently  difficult  to  make  without  very  large 
uncertainty  ranges.  Therefore,  all  cost-calculations  in  this  area  should  be  carefully 
understood  as  rough  approximations  of  introducing  one  technology  based  on  scarce  data 
instead of a robust input to a cost-benefit analysis. 

A  complement,  and  even  substitute,  to  end-of-pipe  solutions  are  those  options  where  the 
problem  can  be  addressed  at  source.  For  example  by  preventing  users  from  disposing  of 
unused  pharmaceuticals  in  sinks  and  toilets,  substituting  harmful  drugs  with  less  harmful 
drugs  and  challenging  producers  to  devise  new  drugs  with  less  harmful  effects  on  human 
health  or  nature  (sometimes  called  “green”  chemistry).  Other  user  side  solutions  include 
take-back (of unwanted medicine) schemes which could have a substantial impact given that 
some  studies  claim  that  80  %  of  pharmaceuticals  entering  the  waste  water  streams  comes 
from private households.201 Directive 2004/27/EC (Art. 127b), requires all Member States to 
ensure that there are appropriate take-back systems in place for consumers to return human 
medicine that is unused or expired. Data on the functioning of take-back schemes are highly 
fragmented  but  indicate  that  the  quality  and  the  success  of  the  schemes  vary  substantially. 
For example, an EEA survey of all EU 28 states and neighbouring countries, found that states 
collect between 10 million and 100 million tonnes per capita.202 While estimates are difficult 
to make, the study estimates that some 50 % of unused packages are not returned in a safe 
way. Older studies also point towards large discrepancies between EU countries. In 2006, the 
then  Swedish  state-run  pharmacy  chain  Apoteket  reported  that  73  %  of  unused 
pharmaceuticals  are  returned  to  be  correctly  disposed.  However  this  high  figure  could  be 
compared  with  Germany,  where  one  study203  reported  that  only  14  %  of  the  unused 
pharmaceuticals were returned appropriately. 

Besides  having  costumers  return  their  unused  pharmaceuticals,  producer-side  measures  to 
enhance  drugs’  environmental  and  health  performance,  could  be  addressed  in  the  Market 
Authorisation  (MA)  processes  for  new  medicines  and  their  associated  compulsory 
Environmental  Risk  Assessments  (ERA).  ERA  was  introduced  on  a  large  scale  in  2005.  For 
veterinary  products  it  is  mandatory  and  taken  into  the  risk-benefit  analysis  in  the 
authorisation  process.  For  human  medicinal  use  however,  a  negative  ERA  advice  is  not 
considered enough for denying market access. A related problem is that many of the drugs 
introduced before ERAs became commonplace, so called “legacy drugs”, have unknown and 
possibly negative effects on the environment.204 

200  Adams, J. (2013) In a tiny NY village, bacteria do a big job on drugs in wastewater. ENSIA. (), more 
information can be found via: www.esf.edu/trinity  
201 Tuerk J, B.Sayder, A. Boergers, H. Vitz, TK. Kiffmeyer, S.Kabasci, (2010) Efficiency, costs and benefits 
of AOPs for removal of pharmaceuticals from the water cycle. Water Science & Technology—WST Vol 
61 No 4 pp 985–993 © IWA Publishing 2010 doi:10.2166/wst.2010.004 
202 EEA, 2010.Pharmaceuticals in the environment. Results of an EEA workshop. EEA Technical report, 
No 1/2010 
203 KNAPPE, 2008.State-of-art review of policy instruments to limit the discharge of pharmaceutical 
products into European waters. Deliverable D3.1 from the KNAPPE project (Knowledge and Need 
Assessment on Pharmaceutical Products in environmental Waters) 
204 BIO Intelligence Service (2013), Study on the environmental risks of medicinal products, Final Report 
prepared for Executive Agency for Health and Consumers 

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Table 7 below describes the different policy options and assesses the associated costs. 

Table 7: Policy options and costs to address pharmaceutical residues 

Policy measure 
1. “Down-stream” 
end-of-pipe 
measures, e.g. fitting 
existing water 
treatment plants 
with additional 
treatment methods 
to address 
pharmaceuticals, in 
particular in 
hospitals. 

2. “Up-stream” 
preventive measures, 
e.g. awareness 
raising among 
hospitals and general 
public to foster 
substitution and safe 
disposal of unused 
drugs  
3. Product Design 
and production 
measures, e.g. 
introducing 
environmental 
requirements into 
market authorization 
procedures 

4. Monitoring, e.g. 
adding common 
monitoring 
procedures and 
measure on an EU 
level 

Cost 

Few estimations but to 
remove E2 through water 
treatment estimated in 
England and Wales to €18 
per capita, and in 
Switzerland from 5 to 25 
% compared to 
conventional treatment 
costs translated into 
about €11 to €18 per 
capita per year.205 Some 
studies indicate a range 
from €5 to €30 per capita 
per year. 
Campaign and education 
costs for national and EU-
level information drives. 

Added R&D costs for 
drug-companies to ensure 
environmental qualities. 
Drug-discovery process 
could amount to $ 802 
million207 (approx. €630 
million) however difficult 
to estimate how much 
would be spent on 
environmental 
considerations. 
The Commission 
calculates monitoring 
costs range of € 1 – 2.4 
million annually equalling 
22 – 52 % of current 
estimated costs for EU 27 
monitoring.208 

Benefits 
Installing new 
filters for 
pharmaceuticals 
could create co-
benefits by 
filtering out other 
harmful 
substances and 
thus improve 
overall water 
quality.  

Assessment of EU level costs 
Highly expensive option. Costs 
likely to be passed on to 
consumers and will differ widely 
across the EU depending on 
status of local water treatment 
facilities. Very rough estimations 
for the EU 28 equal to €9.1 
billion for 1 substance and €27.3 
billion for all 3 substances (could 
be less in case the treatment is 
similar for different 
substances).206 

Highly cost-
effective and 
yields synergies if 
combined with 
other measures 
since it lowers the 
pressure, on for 
example, end of 
pipe measures. 
Removing the 
harmful effects of 
drugs in water or 
stop residues from 
reaching water 
bodies makes 
above measures 
redundant. 
Innovation and 
developing new 
markets. 
Better and more 
comprehensive 
monitoring will be 
essential to assess 
policy impacts on 
an EU level. 

Behavioural change is always 
cumbersome to instigate and it 
would be difficult to attribute 
policy implementation to 
impacts however should be a far 
more cost-effective measure 
than, for example, end-of-pipe 
measures. 

Very difficult to estimate. The 
costs of drug development and 
testing are high but to extract 
the costs of amending the 
environmental standards for 
market authorization is not 
possible with current data 
availability. 

Would be important to include 
for all the options above in order 
to measure success. Hence a cost 
of € 1 – 2.4 million times the 
number of substances should be 
added to all the options above. 

Source: Authors’ own analysis 

205 EC [COM_SEC(2011)1547] SWD IMPACT ASSESSMENT (...) as regards priority substances in the 
field of water policy,p.49 
206 Based on England and Wales costs €18/capita and assuming 507.4 million inhabitants in EU28. 
207 Dickson, M and J.P. Gagnon, 2009.The cost of new drug discovery and development. Discovery 
Medicine, June 09, 2009 
208 EC [COM_SEC(2011)1547]_EN , SWD IMPACT ASSESSMENT (...) as regards priority substances in 
the field of water policy, p.46 

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3.6.4.  Synthesis of findings 

To  sum  up,  there  is  very  little  information  on  the  costs  imposed  by  the  current  level  of 
pharmaceutical  concentrations  in  European  waters.  First,  there  is  very  little  information  on 
overall  concentration  levels  of  different  drugs  in  water  on  a  European  level.  Second,  most 
cost-estimates are very approximate with large uncertainty ranges for end-of-pipe solutions 
only calculated for a few places in a few countries, mainly involving installation of high-tech 
waste  water  treatment  in  existing  facilities.  These  are  likely  to  be  very  high  estimates  for 
public  spending  compared  to  other  policy  alternatives  such  as  information  campaigns  or 
take-back  schemes.  Hence,  a  first  step  towards  improving  the  European  response  to  the 
emerging problem of pharmaceuticals would be to improve the monitoring and oversight on 
a European level, both on the level of concentrations of pharmaceuticals in surface water as 
well as the risks to human health associated with exposure. The current legislative step to put 
the  three  pharmaceuticals  –  17  alphaethinyl-estradiol  (EE2),  17  betaestradiol  (E2)  and 
Diclofenac – on the watch-list is clearly a step in the right direction. 

As this overview has shown, current legislation and instruments at the disposal of the EU are 
quite  diverse  and  thus  provide  a  range  of  possible  policy  interventions  to  apply  for  future 
purposes.  Should  the  health  effects  of  pharmaceuticals  become  more  visible  and  our 
knowledge  increase  on  how  the  causal  pathways  from  compound  to  organism  works,  then 
the functional and political pressures on policy action would increase and lead to the possible 
activation of policy instruments. 

than 

improved  wastewater 

It  seems  clear  that  interventions  at  source-level,  i.e.  prevention,  offer  a  more  cost-efficient 
the  concentration  of 
approach 
pharmaceuticals  in  water.  One  point  for  further  action  and  research  could  be  on  how  to 
improve the performance of take-back schemes across the EU by consumer education, spread 
of best-practices, and possibly more stringent regulation. 

in  reducing 

treatment 

It  could  be  useful  to  think  of  a  “building  blocks”  approach  towards  the  pharmaceutical 
residue  problem.  First,  upgrading  and  extending  monitoring  will  be  necessary  in  all  policy 
scenarios in order to assess the impact of measures. Second, information campaigns among 
doctors,  pharmacies  and  the  general  public  to  promote  safe  disposal  of  unused  drugs  and 
find  substitute  drugs  could  reduce  the  amount  of  pharmaceuticals  in  water.  Third  and 
finally, both end-of-pipe measures and increasing the environmental requirements are likely 
to create substantial costs which in turn are likely to be passed on to consumers and public 
authorities.  However,  it  is  plausible  to  assume  that  the  costs  for  end-of-pipe  solutions 
outweigh  the  costs  for  product-design  and  use  measures,  which  also  deliver  benefits  from 
lead innovation and developing new markets. 

3.7.  Summary of case study results 

Additional EU-level policies could be pursued in all five of the case study areas; however, the 
potential benefits and costs differ per case. The following examples are used to illustrate the 
size of costs of non-Europe in water protection:   

85 

 
 
 
 
 
 
 
Cost of Non-Europe Report 

•  Flood  plain  restoration:  This  is  marked  by  long-term  economic  benefits  mainly  due  to 
reduced  flood  damage  and  water  supply  costs  worth  between  €500  to  €10,000  annually 
per ha of restored floodplain. This compares favourably with the (albeit) high investments 
costs of €5,000 to €100,000 per ha. The variability of the numbers is large and depends on 
the specific local situation. Depending on the available restoration potential in the EU the 
long-term annual economic benefits of a full realisation of the potential could reach some 
€39  billion.  EU  action  in  this  area  could  include  better  integration  of  ecosystem  service 
consideration  in  EU  agriculture  and  cohesion  policies  and  additional  support  and 
incentives for river basin authorities including: 

o  Management  tools  in  order  to  better  define  obsolete  infrastructure,  which  has 
outlived its original purpose and/or where maintenance costs outweigh benefits; 

o  Governance principle for successful restoration projects; and  
o  Prioritisation and financing tools, including use of EU structural and agriculture 

funds. 

•  EU  Eco-design  measures  for  water  taps  and  showerheads  and  mandatory  water 
metering:  marked  by  payback  of  usually  well  below  a  year  and  leading  to  substantial 
annual savings on water and energy bills of €2.2 billion by 2030 for eco-design measures 
on water taps and showerheads and €66.4 per household for water metering, with today’s 
water and energy prices. Those savings are likely to overlap and will be lower in the short 
term because of the high transition costs of public water supply, collection and treatment 
systems, (where water charges have been based on historic demands and need to support 
a sector which has high capital costs but relatively low operating costs). 

•  Combination  of  upstream  measures  to  reduce  pharmaceutical  residues:  The  down-
stream  costs  of  removing  pharmaceutical  residues  from  urban  waste  water  streams  are 
significant.  Estimates  from  two  countries  for  upgrading  treatment  systems  suggest  that 
total annual costs for the EU could be as high as €9 billion, which is likely to be recovered 
from  increasing  water  bills.  In  order  to  avoid  those  costs  it  appears  worthwhile  to 
investigate  the  costs  and  benefits  of  upstream  measures  such  as 
introducing 
environmental aspects in the EU authorisation system for pharmaceuticals and EU wide 
campaigns to foster substitution and safe disposal of unused drugs.  

Comparing our findings with the Blueprint it appears that our ex-post assessments are rather 
similar but the ex-ante assessment shows significant differences. The political choice made in 
the  Blueprint  was  to  focus  on  quantitative  aspects  and  the  use  of  EU-level  guidance 
documents. The current relevance of this focus has been questioned by several of the experts 
we interviewed. 

Based  on  our  findings  we  recommend  focussing  EU  water  protection  actions  on  the 
following areas (Table 8). 

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Table 8: Recommended focus for EU water protection actions 

Area 

Example analysed / baseline 

1. Strengthening EU 
wide emission 
controls for 
pollutants vis-a-vis 
environmental 
quality standards; 

2. Reduce water and 

energy use 

3. EU coordination to 

support and 
incentivise 
floodplain 
restoration,  

Pharmaceutical residues: costs of end of pipe 
removal. The baseline scenario is that growing 
pressure to reduce levels of a growing number 
of micro-pollutants will sooner or later 
necessitate new treatment levels, which could 
be avoided by upstream  measures, including 
product and service designs  

Water taps and shower heads performance and 
water metering requirements complemented by 
development pathways for public water 
systems. 
The baseline scenario is that water and energy 
prices remain constant at today’s levels 

Providing better governance, CBA and financing 
tools for projects, which are well coordinated 
with flood risk and agriculture policies. 
The baseline scenario is that 8.8 million ha of 
floodplain area are available in the EU for 
restoration  

Indication of monetised 
benefits 

€9 billion annually for 
avoidance or postponement of 
new treatment levels across 
Europe. 
Investment costs for upstream 
measures are not known or 
quantifiable 

€2.2 billion annually due to 
reduced water and energy bills 

€1.0 billion annual investment 
costs  

€39 billion annually mainly due 
to reduced flood damages, 
public water supply costs and 
increased tourism and 
recreation activities. 

€361.8 billion total investment 
costs mainly for land purchase 
and infrastructure works. 

Source: Authors’ own analysis 

Given  the  high  variability  in  the  quality  of  national  implementation  including  slow  and 
wrong application of EU water protection laws, the identified actions should be accompanied 
and  be  supported  by  better  implementation  and  policy  integration  activities.  It  is  also 
important to point out that the estimates of costs and benefits in these options are based on a 
number of assumptions and extrapolations and as such they should be treated as indicative. 

87 

 
 
 
 
 
 
 
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4.  Conclusions 

This chapter provides a summary of the main report findings. First, the chapter 
offers a comparison of the study findings with the Blueprint findings. Second, the 
chapter wraps up the analysis with concluding remarks and indications on lessons 
learned for potential future policy recommendations. 

4.1.  Comparison with the Blueprint findings209 and actions 

This section presents a comparison of our assessment with the Blueprint 
findings and actions. We can identify differences and similarities regarding 
the three main Water Status elements. 

4.1.1.  Quality – different findings, different solutions 

A  successful  policy  design  is  available,  but  this  requires  emission  controls  to  catch  up  with 
work on quality standards and that gaps in assessing and addressing risk of certain pollutant 
groups are closed. 

The  Blueprint  comes  to  different  findings,  focussing  on  the  lack  of  information  about 
chemical status in river basins and less on policy and implementation gaps. Consequently it 
proposes  strengthening  the  enforcement  of  measures.  The  Blueprint  only  recognises  that 
there  could  be  a  more  fundamental  regulatory  interaction  issue  and  proposes  a  report 
regarding  the  risk  of  pharmaceuticals.  With  regard  to  diffuse  pollution  it  proposes  CAP 
conditionality for pesticide uses. 

4.1.2.  Quantity – similar findings, similar direction of solutions 

Limited progress and incomplete implementation, typified by weak targets and tools. Those 
issues could be tackled by better policy integration, reinforcement of EU resource efficiency 
strategy and strengthening targets and tools. 

The  Blueprint  reaches  similar  findings  and  proposes  a  long  list  of  actions  to  overcome  the 
problems. The majority of actions would lead to a series of further implementation guidelines 
for the WFD. The effectiveness of guidelines has not yet been established. 210 At the screening 
phase for the IA for the Blueprint a wide range of legislative options, including amendments 
to the WFD, have been looked at211, but these options were dropped early on due to political 
concerns.212 Only one proposal for regulatory action emerged, related to maximising the re-

209 With the Blueprint to Safeguard Europe's Water Resources published in 2012 the EC looked into the 
effectiveness, gaps of implementation of the WFD and potential solutions in four general areas – land 
use and ecological status, chemical status and pollution, water efficiency and vulnerability of EU waters 
210 Interviews with EEB (5/9/14), Ecologistasen Accion (9/9/14) in writing and Pierre Strosser 
(25/9/14)  
211 IEEP et al. (2012) Service Contract To Support The Impact Assessment Of The Blueprint To 
Safeguard Europe’s Waters Assessment Of Policy Options For The Blueprint, Final Report 
212 As reported by several of the interviewees. 

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Water Legislation 

use of waste water. The Blueprint also makes several proposals to establish conditionality for 
the CAP and funding priorities. 

4.1.3.  Space – slightly different findings, few solutions 

Limited  progress  and  incomplete  implementation,  reflecting  weak  targets  and  tools.  These 
issues could be tackled by better policy integration, reinforcement of EU resource efficiency 
strategy and strengthened tools. 

The Blueprint offers some similar findings but differs in that it does not consider the use of 
economic  instruments  as  important  and  does  not  identify  the  lack  of  clarity  of  the  WFD 
targets  and  missing  WFD  measures  as  an  issue.  The  only  concrete  actions  proposed  are  a 
guidance  document  on  green  infrastructure,  enforcement  of  the  Floods  Directive  and 
Greening the CAP. A link with the EU Strategy for a Resource Efficient Europe has not been 
established. 

4.2.  Conclusions on progress to date and remaining challenges 

This section summarises the findings of the report as a whole – covering 
progress to date and key remaining challenges.  

The  WFD  introduced  a  number  of  innovative  policy  instruments  and  stringent  goals  to 
improve the quality and management of European waters, and by providing a framework for 
a  range  of  water-related  legislation,  the  EU  has  created  an  impressive  and  comprehensive 
body  of  regulation  and  guidance.  The  results  of  the  assessment  of  the  progress  towards 
reaching the WFD goals and implementing its instruments which was made in the run up to 
the Blueprint, however, showed significant gaps. While the progress was visible and rapid in 
the beginning with the reduction of pollution levels falling as a result, further progress has 
been  limited.  This  is  notwithstanding  that  several  tools  are  available  to  control  emissions. 
Regarding  the  quantitative  aspects  of  water,  new  tools  have  come  in  place  yet  progress  is 
difficult to assess. Finally, the spatial aspects of problems pertaining to the implementation of 
the  WFD  have  been  difficult  to  address  in  particular  when  dealing  with  infrastructure  and 
land use.  

The reasons for the implementation gap in the WFD can be attributed to five main challenges: 

•  First, there has been a slow and incomplete implementation of the entire 

framework at MS level. The speed of progress, stringency and level of detail in 
the RBMPs for example, differ widely between catchment areas and competent 
authorities which creates large disparities in the institutional framework for 
implementing the FWD in European countries.  

•  Second, the cost-effectiveness of Programmes of Measures (PoMs) is not 

always clear and it can be assumed that it is difficult to attract funding for 
large scale restoration project. Data on these issues are however, scattered and 
this is an issue that would benefit from further urgent research. 

•  Third, there are insufficient linkages between the RBMPs and other policy 
domains and legislation such as agriculture and flood management. For 
instance, the current design of the CAP remains geared towards intensive 

89 

 
 
 
 
 
 
Cost of Non-Europe Report 

agriculture which in some places is a large source of water contamination and 
loss of floodplain functions.  

•  Fourth, a gap in the deployment of EU-level instruments to control emissions 

of pollutants.  

•  Fifth, there is weak overall integration between water protection and energy 
and agricultural policy resulting in sometimes counter-productive policy 
measures and instruments. 

4.3.  Policy recommendations 

This section summarises the proposed recommendations for potential future 
actions, based on the findings of this study (the recommendations are 
discussed in more detail in section 3.7). 

Based  on  the  overall  analysis,  the  study  identifies  four  promising  areas  for  further  water 
policy  action:  PoMs,  Eco-design,  water  metering  and  up-stream  pollution  controls,  next  to 
improving  policy  integration  at  EU  and  national  levels  in  order  to  achieve  better 
implementation.  

•  Strengthen EU-wide emission controls for pollutants vis-à-vis water quality 

standards; 

•  Reduce water and energy use via water-related eco-design standards (for 

shower heads and water taps), while promoting water metering to improve 
progress on water quantity targets; and 

• 

Improve PoMs and EU coordination to support floodplain restoration to 
further space-related water targets. 

These  proposed  actions  would  need  to  happen  in  combination  with  improving  policy 
integration  at  EU  and  national  levels  in  order  to  achieve  better  implementation.  This  final 
aspect has not been covered in detail by our work. 

We  have  prepared  high  level  estimates  of  costs  and  benefits  (presented  in  the  following 
figures)  to  indicate  the  potential  scale  of  these  actions  but  should  stress  that  these  are 
extrapolations  based  on  various  assumptions  and  should  be  treated  with  caution.  The 
selected  examples  have  different  payback  times  and,  therefore,  represent  very  different 
investment  cases.  The  payback  times  of  water  saving  measures  are  short,  while  flood  plain 
restoration  is  a  long-term  investment  whose  return  will  depend  on  the  supporting  policy 
framework,  local  prices  and  legislation  (e.g.  regarding  land  purchase)  and  further 
investigation  of  more  detailed  cost  and  benefit  aspects.  Generally,  information  about  costs 
has  been  more  readily  available  than  data  about  benefits.  Nevertheless,  the  costs  of  the 
proposed actions may decrease in the future e.g. the price of more efficient shower heads and 
water taps is likely to fall as production volumes increase. 

90 

 
 
 
 
 
 
 
Water Legislation 

Figure 9: Potential benefits from EU policy measures for 2015-2030 and annually 

Figure 10: Potential investment needs of EU policy measures for 2015-2030 and annually 

Source: Authors’ own analysis 

Source: Authors’ own analysis 

91 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost of Non-Europe Report 

Table 9: Overview of ex-post assessment and Blueprint to Safeguard Europe’s Water Resources 

Water  
status 

Overall 

Quality 

Blueprint findings and proposed actions 

This report’s analysis 

Findings 

Actions - ongoing 

Actions 
delivered 

Actions failed 

Progress 

Effectiveness 

Main issues identified 

Water status not 
good enough, 
but no need for 
major legislative 
work 

Insufficient 
information and 
monitoring 
regarding WFD 

Good progress 
with pre WFD 
Directives 

Gap in 
addressing risks 
from 
pharmaceuticals 

Better national implementation and increased policy integration 

Enforcement 

Cross-
compliance 
CAP, 
postponed 

Report on 
pharmaceuticals 

92 

Limited progress in 
reaching Good Status 
and moving toward 
sustainable water 
management 

Weak evidence about 
cost-effectiveness of EU 
and national policies 

Incomplete EU policies, 
weak national 
implementation and river 
basin governance 
remains a big challenge 

Progress to protect 
human health 

Mixed progress in 
reducing 
environmental 
pollution 

Diffuse pollution 
remains a problem 

Effective use of quality 
standards and emission 
controls  

National implementation 
deficits 

EQS without 
accompanying emission 
controls ineffective 

Lack of EU emission 
controls and product 
requirements 

Weak policy integration  

Contradicting agriculture, 
energy and transport 
policies 

Lack of knowledge 
about chemical risks 

Gaps for chemical 
cocktails, endocrine 
disrupting effects, or 
pharmaceutical residues 

Gaps in EU level 
assessment of chemical 
risks 

Effective policy design - good targets, but missing instruments 

 
 
 
 
  
  
 
  
  
 
  
  
 
  
  
  
 
  
  
  
 
  
  
  
  
 
  
  
 
WFD 
enforcement 

Monitoring 
support 
and 
inspections 

Ecodesign, 
Labelling and 
Procurement 

Funding 
priorities 

4 Guidance 
(trading, 
leakage, e-
flows, targets) 

Waste 
water re-
use 
regulation 

Cross-
compliance 
CAP, 
postponed 

2 Guidance 
(Green 
Infrastructure) 

WDF/Floods 
enforcement 

Greening CAP 
Pillar I: Crop 
diversification; 
Maintaining 
existing 
permanent 
grasslands; at 
least 5% 
ecological focus 
area 

Over-
abstraction: 2nd 
most important 
pressure on  
Status 
Illegal 
abstractions, 
narrow and weak 
economic 
assessments 
Some progress in 
WS&D policies, 
but high 
untapped 
potentials 

Main pressure on 
the Water Status 
originates from 
dams and dykes 
serving energy, 
agriculture, 
transport and 
flood protection 

Focus so far 
mainly on new 
infrastructure 
developments, 
little on existing 

Quantity 

Space 

Source: Authors’ own analysis 

93 

Water Legislation 

Limited progress in 
increasing water 
efficiency 

Ineffective overall EU 
policy design due to 
Treaty limitations 

Contradicting agriculture, 
energy and transport 
policies 

Limited progress of 
economic assessments 
and instruments 

Mixed effectiveness of 
water pricing, lack of EU 
instruments 

Reinforcement of EU 
resource efficiency 
strategy 

Little progress in 
supporting Good 
Status 

Ineffective EU target 
design 

Strengthen WFD specific 
targets and tools 

Ineffective EU policy design - Weak targets, weak tools 

Limited progress in 
increasing space and 
improving structure 

Ineffective 
overall EU 
policy design 
due to Treaty 
limitations 

Contradicting  agriculture,  energy 
and transport policies 

Limited progress of 
economic assessments 
and instruments 

Missing cost-
effective 
national PoMs 

Reinforcement  of  EU  resource 
efficiency strategy required  

Little progress in 
supporting Good 
Status 

Ineffective EU 
target design 

Strengthen  WFD  specific  targets 
and tools 

Ineffective EU policy design - Weak targets, no tools 

 
  
 
  
 
  
  
 
  
  
  
  
  
 
 
 
 
 
 
 
 
 
  
  
 
  
  
  
  
 
 
  
  
  
  
  
  
Cost of Non-Europe Report 

Annex A – Water policies factsheets 

The  following  factsheets  present  key  information  about  the  most  relevant  EU  water  policy 
documents. 

Table 10: Water Framework Directive (WFD) factsheet213 

Document name 
Level of implementation 

Water Framework Directive (2000/60/EC) - WFD 
EU (Priority substances, Groundwater) and MS (RBMPs and PoMs) 

Year of entry into force 

2000 

Type of policy  

Command & control & governance 

Area of focus 

Umbrella Directive – multiple aspects of whole river basins 

Main policy tool  

River Basin Management Plans (RBMPs); Programmes of Measures (PoM) 

Context 

Objectives 

Costs214 

The WFD addresses the increased pressure on EU’s water resources from the 
“continuous growth in demand for sufficient quantities of good quality water 
for all purposes” 
General objectives: 
•  To prevent further deterioration and protect and restore the ecological 

and chemical status of the aquatic environment and ecosystems 

•  To promote sustainable water use 
•  To ensure the reduction and prevention of further groundwater pollution 
•  To mitigate the effects of floods and droughts 

Intermediate goals: 
•  2000-2012 – transposition; analysis of pressures and impacts on river basin 
districts (RBDs); establishment of monitoring programmes, RBMPs and 
accompanying PoM to address the identified pressures 

•  By 2015 - To achieve “good status” as defined in Annex V of the 

directive(good chemical and ecological status for surface waters and good 
quantitative and chemical status of groundwaters) for all water bodies  

•  Administrative burdens(e.g. the reporting cycles of the UWWTD and 

Nitrates Directive are not synchronised with the WFD) 

•  Investment costs (e.g. installation of metering in all irrigated EU land, on 
the basis of French experience, could cost around €243 million, full scale 
implementation of metering for the whole EU would cost €3080 million); 
(different green infrastructure project costs vary between €50 000 and €4 
billion)  

213 Information in factsheet based on: EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT 
Accompanying the document COMMUNICATION (...) A Blueprint to Safeguard Europe's Water 
Resources; 
EC [COM(2012) 670 final]]REPORT FROM THE COMMISSION (...) on the Implementation of the Water 
Framework Directive (2000/60/EC) River Basin Management Plans;  
EC [SEC(2009)415]]SWD accompanying the Report from the Commission (...)  on programmes for 
monitoring of water status;  
EC [COM(2007) 128 final]]COMMUNICATION (...) Towards sustainable water management in the 
European Union - First stage in the implementation of the Water Framework Directive 2000/60/EC 
EEA (2012) European waters — current status and future challenges Synthesis 
214 EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources, part 1 (p.56) and part 2 
(pp.21-22) 

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Document name 

Water Framework Directive (2000/60/EC) - WFD 

Benefits 

•  Consolidation of EU water laws 
•  Flexibility on national level as to how the objectives of the directive are 

Impacts – Economic216 

Impacts – Social 

Impacts – 
Environmental 

Data availability 

achieved 

•  Improved water quality 
•  Preserved aquatic biodiversity 
•  Avoided costs (e.g. in France the economic benefits of natural water 

storage in terms of the replacement costs of building grey infrastructure 
like dams ranges from € 37/ha/year to € 617/ha/year)215 

•  Internalise externality costs 
•  Reduce costs of flood damages(e.g. economic damage from floods in EU 
are estimated at €6400 million/year for the period 2006-2010, while the 
total additional damage from climate change scenarios ranges €7700 – 
15000 million/year) 

•  Reduce costs of water shortages and droughts(e.g. scarcity costs for 

households, industry and tourism in Cyprus imply that the present value of 
total costs due to water shortages in the period 2010-2030 may reach €200 
million (2009 prices)) 

•  Reduce costs of water treatment (e.g. for conventional waste water 

treatment the operational cost is on the average €1.9/m3 and the capital 
investment is €474 – 593/m3 per day) 
•  Create a level-playing field within the EU 
•  Increase productivity of commercial fisheries and aquaculture 
•  Foster research and innovation 
•  Access to safe drinking water and sanitation 
•  Access to safe bathing water  
•  Recreational value of preserved aquatic biodiversity 
•  Improved safety regarding floods, water scarcity and droughts  
•  Improved water quality 
•  Safeguarding of aquatic biodiversity 
•  Mitigation of climate change effects 
The  impact  assessment  (IA)  accompanying  the  Blueprint217is  the  most  recent 
IA available and it contains estimates of different costs and benefits related to 
specific measures in the following areas: 
•  Measures for controlling diffuse pollution, protecting ecosystems and 
promoting natural water retention (e.g. green infrastructure projects, 
Natural Water Retention Measures (NWRMs) etc.) 

•  Measures improving water availability (e.g. desalination, water transfers 

etc.) 

•  Water efficiency measures (e.g. water savings in buildings, household 

appliances etc.). 

Information  on  implementation  progress  is  available  from  the  EC  periodical 
reports and accompanying SWD.218 

215 Ibid. part 2, p.23 
216 Ibid. part 1, p.28 and part 2, p. 25 
217 EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 
218 EC [COM(2012) 670 final] REPORT FROM THE COMMISSION (...) on the Implementation of the 
Water Framework Directive (2000/60/EC) River Basin Management Plans;  
EC [SEC(2009)415] SWD accompanying the Report from the Commission (...)  on programmes for 
monitoring of water status;  
EC [COM(2007) 128 final]]COMMUNICATION (...) Towards sustainable water management in the 
European Union - First stage in the implementation of the Water Framework Directive 2000/60/EC 

95 

 
 
                                                 
Cost of Non-Europe Report 

Document name 

Implementation 
progress 

Monitoring system / 
techniques 

Relevance for CoNE case 
study? 
Reference 

Water Framework Directive (2000/60/EC) - WFD 
The  1st  6-year  management  cycle  is  in  progress  –  23  Member  States  have 
submitted  complete  RBMPs.  The  EC  has  received  124  RBMPs  out  of  the 
expected 174 (approx. 70%).The Court has ruled against Belgium, Greece and 
Portugal for not having adopted and reported the plans. A judgment on Spain 
is pending.219 

However the 2015 target for “good status” will not be reached for a significant 
number  of  water  bodies.  The  EAA  (2012)220reports  that  almost  50%  of 
Europe's  surface  water  is  likely  to  be  in  poor  ecological  status  by  2015.  The 
picture  is  more  difficult  to  assess  for  chemical  status  as  more  than  40%  of 
Europe's surface waters have unknown chemical status. Nevertheless, by 2015 
more  than  90%  of  Europe's  groundwater  is  expected  to  be  in  good  status  in 
terms  of  both  quantity  and  quality.  Analysis  of  the  pressures  causing  poor 
status  shows  that  30%  -  50%  of  the  surface  water  bodies  are  affected  by 
diffuse  pollution  (principally  due  to  agriculture).  More  than  40%  of  the  river 
and  coastal  water  bodies  are  affected  by  diffuse  sources,  whilst  20–25%  of 
them  are  also subject  to  'point  source'  pollution.  Lack  of ambition,  extensive 
use of exemptions in an arbitrary way (e.g. extending the deadline for reaching 
good status or setting lower environmental objectives without justification or 
i.e.  technical  feasibility,  proportionality, 
explaining  the  conditions  used 
affordability)  and  hydromorphological  pressures  (abstractions,  land  use,  flow 
regulation  and  dykes)  are  reported  as  the  main  reasons  for  failing  good 
ecological status.221 

Other  existing  issues  related  to  the  implementation  of  the  WFD  have  been 
identified in the Commission report on RBMPs (2012)222and grouped under the 
following categories: 
•  Insufficient use of economic instruments to address market failures(e.g. 

49% of RBMPs include modification of the water pricing system to foster a 
more efficient use of water, 40% of the RBMPs include measures to 
enhance water metering which is a precondition for incentive water pricing) 

•  Lack of policy integration in support to specific measures 
•  Ineffective water governance to tackle coordination problems 
•  Knowledge gaps 
At MS level 
•  Surface waters: surveillance, operational and investigative monitoring for 

chemical and ecological status;  

•  Groundwater: ground level, chemical and operational monitoring for 

quantitative and chemical status 

•  Additional monitoring in protected areas 
•  The number of monitoring stations installed varies per MS 
At EU level – Member States submit RBMPs in 6-yearly cycles to EC for review 
No revision of the directive is expected before 2019. Relevant for all 5 issues. 

DIRECTIVE (2000/60/EC) establishing a framework for Community action in the 
field of water policy 
DIRECTIVE 2013/39/EU amending Directives 2000/60/EC and 2008/105/EC as 
regards priority substances in the field of water policy 

219Ibid. 
220EEA (2012) European waters — current status and future challenges Synthesis 
221EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources– part 1, chapter 2.5.1 and 
part 2, page 6. 
222EC [COM(2012) 670 final] REPORT FROM THE COMMISSION (...) on the Implementation of the 
Water Framework Directive (2000/60/EC) River Basin Management Plans 

96 

 
 
 
                                                 
Water Legislation 

Table 11: Urban Waste Water Treatment Directive (UWWTD) factsheet223 

Document name 

Level of implementation 

DIRECTIVE (91/271/EEC) concerning urban waste water  
treatment - UWWTD 
EU (setting standards) and MS (implementation) 

Year of entry into force 

1991 

Type of policy  

Area of focus 

Main policy tool 

Context 

Objectives 

Costs224 

Benefits 

Impacts – Economic 

Impacts – Social 

Impacts – Environmental 

Data availability 

Implementation progress 

Command & control 

Waste water 

Minimum requirements for collection and treatment of waste water. 
National programmes for implementation and periodical reports to the 
EC. 
It addresses the pollution related to waste water discharge from urban 
areas and certain industry sectors 
To protect the environment from the adverse effects of urban waste 
water discharge and treatment and of biodegradable industrial waste 
water from the agro-food sector 
•  Administrative burdens(e.g. the administrative burden that the 

reporting cycles of the UWWTD are not synchronised with the WFD) 

•  Investment costs especially those related to sewage systems and 

treatment facilities(e.g. for conventional waste water treatment the 
operational cost is on average €1.9/m3 and the capital investment is 
€474 – 593/m3 per day) 
•  Improved water quality 
•  Improved public health 
•  Investment in infrastructure 
•  Foster research and innovation 
•  Improve productivity of commercial fisheries and aquaculture 
•  Job creation 
•  Access to sanitation 
•  Access to safe bathing water 
•  Improved public health 
•  Recreational value of preserved aquatic biodiversity 
•  Improved water quality 
•  Safeguarding of aquatic biodiversity 
The IA accompanying the Blueprint225 is the most recent IA available and 
it contains estimations of different costs and benefits related to specific 
measures such as waste water treatment and waste water re-use.  
Information on implementation progress is available in the EC periodical 
reports, the most recent being from 2013.226 
With regard to collecting systems, secondary and more stringent 

223 Information in factsheet based on:EC [COM(2013) 574 final] Seventh Report on the Implementation 
of the Urban Waste Water Treatment Directive (91/271/EEC);  
EC [SWD(2012) 393 final] SWD The Fitness Check of EU Freshwater Policy;  
EC [SWD(2012) 382 final]  SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 
224 EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 
225Ibid. 
226EC [COM(2013) 574 final] Seventh Report on the Implementation of the Urban Waste Water 
Treatment Directive (91/271/EEC) 

97 

 
                                                 
 
 
Cost of Non-Europe Report 

Document name 

DIRECTIVE (91/271/EEC) concerning urban waste water  
treatment - UWWTD 

treatment there are overall high compliance rates by 2010.  

Compliance rates regarding  
Collecting systems 
secondary treatment 
more stringent treatment 

EU15  
97% 
88% 
90% 

EU12  
72% 
39% 
14% 

Generally the Member States which joined after 2004 (EU12)227 are 
trailing behind but they are also subject to different compliance 
deadlines. There is also lower level of compliance with these standards 
in big cities in the majority of Member States.228 

With regard to pollution a recent JRC report (2011)229 concluded that the 
total nitrogen export from the land to the sea had decreased by 9%, 
while the total phosphorus load had decreased by around 15% for 2005 
compared to 1991 mainly due to a decrease in point source emissions. 
Moreover the high decrease observed in the North and in the Baltic Sea 
was mainly related to the implementation of advanced waste water 
treatment. The improvement in the quality of EU bathing waters in the 
last decades is also to a large extent due the implementation of the 
UWWTD. 
Monitoring and waste water treatment on MS level 

This directive is relevant particularly with respect to issue of waste water 
re-use (issue 2). 
Council Directive (91/271/EC) concerning urban waste water treatment 

Monitoring system / 
techniques 
Relevance for CoNE case 
study? 
Reference 

227Croatia has not been included in the last available report 
228EC [COM(2013) 574 final] Seventh Report on the Implementation of the Urban Waste Water 
Treatment Directive (91/271/EEC) 
229JRC (2011) Long term nutrient loads entering European seas 

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Water Legislation 

Table 12: Ecodesign directive factsheet230 

Document name 

DIRECTIVE (2009/125/EC) establishing a framework for the setting of 
ecodesign requirements for energy-related products 

Level of implementation 

EU (setting standards) and MS (surveillance) 

Year of entry into force 

2009 

Type of policy  

Command & control 

Area of focus 

Energy-using products (EuPs) excluding transport 

Main policy tool 

Context 

Objectives 

Costs  

Benefits 

Impacts – Economic 

Impacts – Social 

Impacts – 
Environmental 

Working plans set out by the EC indicating the list of EuP groups with priority 
for the adoption of implementing measures and following directives and 
regulation regarding a particular group of products 
Energy-related products account for a large proportion of the consumption of 
natural resources in the EU 
•  To set ecodesign requirements for energy-related products with the aim of 
ensuring the free movement of such products within the internal market. 

•  To provide for criteria and conditions for the setting of ecodesign 

requirements which the regulated EuPs must fulfill in order to be placed on 
the market 

•  To increase energy efficiency and the security of energy supply 
•  Administrative burdens 
•  Investment costs (e.g. costs for renovation of buildings range €200-2000 to 

replace toilet flushes or toilet equipment, €800-3500 to install water 
efficient cooling system etc.) 
•  Improved environmental quality 
•  Increased resource efficiency 
•  Uniform rules for the products within the internal market 
•  Level-playing field and free movement of goods within the internal market 
•  Investment in research and innovation 
•  Energy savings 
•  Improved health 
•  Improved environmental quality 
•  Increased energy efficiency 
•  Increased water use efficiency (e.g. between 56 to 64 million m3 of water 
per year are expected to be saved in 2020 thanks to the dishwasher 
ecodesign regulation and between 64 to 83 million m3 per year from the 
washing machines regulation, which amounts to twice the total domestic 
water use in the EU in one day) 
•  Mitigation of climate change effects 

230 Information in factsheet based on: EC [SWD(2012) 434 final] SWD Establishment of the Working Plan 
2012-2014 under the Ecodesign Directive;  
EC [COM(2008) 660 final] COMMUNICATION (...) Establishment of the working plan for 2009-2011 
under the Ecodesign Directive;  
EC [SEC(2010) 1357 final] SWD SUMMARY OF THE IMPACT ASSESSMENT Accompanying document 
to the Draft Commission Regulation (...) with regard to ecodesign requirements for household 
dishwashers; 
EC (2010) SWD SUMMARY OF THE IMPACT ASSESSMENT Accompanying document to the Draft 
Commission Regulation (...) with regard to ecodesign requirements for household washing machines;  
EC (2010) REGULATION(EU) No 1016/2010 (...) implementing Directive 2009/125/EC with regard to 
ecodesign requirements for household dishwashers;  
EC (2010) REGULATION (EU) No 1015/2010 (...) implementing Directive 2009/125/EC with regard to 
ecodesign requirements for household washing machines;  
EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 

99 

 
                                                 
Cost of Non-Europe Report 

Document name 

Data availability 

Implementation 
progress 

Monitoring system / 
techniques 

Relevance for CoNE case 
study? 
Reference 

DIRECTIVE (2009/125/EC) establishing a framework for the setting of 
ecodesign requirements for energy-related products 

The IA accompanying the Blueprint presents some estimates of investment 
costs and economic and water savings for renovation of buildings and certain 
water using products. 
Currently the 2nd Working Plan for the period 2012-2014 is in place. Ecodesign 
regulations for domestic dishwashers and washing machines have been 
adopted in 2010. For dishwashers no stringent minimum requirements with 
regard to water consumption are set but they are nonetheless defined for the 
Best Available Technology (BAT). While for washing machines minimum 
requirements for water consumption are set in the Regulation. Ecodesign 
regulations for water -related products such as showers and taps etc. and 
water-using products such as irrigation equipment etc. have not been adopted 
yet but are under consideration.  

Market surveillance problems in Member States – the general level of 
surveillance activities undertaken by a number of EU countries has been 
considered low. Significant activity is reported in 5 Member States, moderate 
to low activity in most, and no activity reported for 2010 in 6.231 Meanwhile, 
the EU-funded "Involvement of Civil Society in Market Surveillance of 
Ecodesign and Energy Labelling" (MARKETWATCH)232 project aims to increase 
the involvement of civil society in market surveillance activities related to 
Ecodesign and Energy Labelling, with the ultimate goal to increase the level of 
compliance in the EU.233  
Monitoring on MS level: National authorities in Member States are in charge 
of monitoring the compliance with the ecodesign and labelling requirements 
for products covered by the Ecodesign Directive 
This framework directive and its daughter directives for the different product 
groups are relevant for the ecodesign and water metering issue (issue 3). 
DIRECTIVE (2009/125/EC) establishing a framework for the setting of 
ecodesign requirements for energy-related products 

231 European Council for Energy Efficient Economy (ECEEE) webpage: 
http://www.eceee.org/ecodesign/Horizontal-matters/eceee-pages-on-ecodesign-and-labelling-
market-surveillance/MSreport 
232 Involvement of Civil Society in Market Surveillance of Ecodesign and Energy Labelling" 
(MARKETWATCH)  (2014) homepage: http://eaci-
projects.eu/iee/page/Page.jsp?op=project_detail&prid=2644 
233 The project includes a number of specific activities and operations that civil society organisations 
will conduct towards this objective, including large campaigns of verification of the proper 
implementation by manufacturers and retailers of some of the Ecodesign and Energy Labelling 
requirements through physical and on-line shop visits. – ibid. 

100 

 
 
 
 
                                                 
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Table 13: Environmental quality standards (EQS) directive factsheet234 

Document name 

DIRECTIVE (2008/105/EC) on environmental quality standards in the 
field of water policy and following amendment by DIRECTIVE 
2013/39/EU as regards priority substances in the field of water policy 

Level of implementation 

EU(setting standards) and MS (implementation) 

Year of entry into force 

2009 

Type of policy  

Command & control 

Area of focus 

Surface waters 

Main policy tool 

Context 

Objectives 

Costs and benefits  

Benefits 

Impacts – Economic 

Impacts – Social 

Impacts – Environmental 

Data availability 

Implementation progress 

Member States publish regular inventories of the emissions which are 
included in their RBMPs 
It addresses the chemical pollution of surface waters 

To set environmental quality standards (EQS)for priority substances and 
certain other pollutants with the aim of achieving good surface water 
chemical status  
•  Administrative burdens 
•  Surveillance costs(e.g. the 2011 IA has estimated that the overall cost of 
current monitoring of existing PS in the EU27 is on average €69 million 
per year) 

•  Improved water quality 
•  Improved public health 
•  Improved aquatic biodiversity 
•  Uniform rules for industry in EU 
•  Reduced cost of treatment for drinking and industrial process water(e.g. 
estimated unit costs for removal of pesticides from drinking water were 
reported to be €0.028 /m3 in the 2006 IA) 

•  Reduced cost of dredging(e.g. management costs are heavily dependent 

on the sediment quality and vary from €1 - 45 /m3) 

•  Potential for more productive commercial fisheries and aquaculture 
•  Fostering research and innovation 
•  Reduced exposure to hazardous chemicals for humans both in case of 

occupational and recreational purposes 

•  Improved quality of fish and shellfish in commercial fisheries and for 

recreational fishing 

•  Improved amenity value of water bodies 
•  Cleaner drinking water for livestock and reduced accumulation of 

hazardous chemicals in animal products 

•  Reduced potential for accumulation of hazardous chemicals by crops 
•  Improved chemical status of water bodies 
•  Improved aquatic biodiversity 
Description of associated costs for the new proposed PS is available in the 
accompanying IA 
Still under implementation   
However, the chemical status of 40% of surface waters remains unknown, 
implying insufficient monitoring by Member States. Furthermore, effects of 
emerging pollutants are not yet known. 

234 Information in factsheet based on: EC [SEC(2011) 1547 final] SWD IMPACT ASSESSMENT (...) as 
regards priority substances in the field of water policy;  
EC [SWD(2012) 393 final] SWD The Fitness Check of EU Freshwater Policy 
EEA (2012) European waters — current status and future challenges Synthesis 

101 

 
                                                 
Cost of Non-Europe Report 

Document name 

Monitoring system / 
techniques 
Relevance for CoNE case 
study? 
Reference 

DIRECTIVE (2008/105/EC) on environmental quality standards in the 
field of water policy and following amendment by DIRECTIVE 
2013/39/EU as regards priority substances in the field of water policy 

Monitoring of the chemical status of water bodies at MS level 

This directive is relevant for the pharmaceutical residues issue (issue 5) 

DIRECTIVE (2008/105/EC) on environmental quality standards in the field of 
water policy  
DIRECTIVE 2013/39/EU amending Directives 2000/60/EC and 2008/105/EC 
as regards priority substances in the field of water policy 

Table 14: List of priority substances (PS) factsheet235 

Document name 

DECISION No 2455/2001/EC establishing the list of priority substances 
in the field of water policy and amending Directive 2000/60/EC 

Level of implementation 

EU 

Year of entry into force 

2001 

Type of policy  

Command & control 

Area of focus 

Surface waters 

Main policy tool 

RBMPs 

Context 

Objectives 

Costs and benefits  

Impacts – Economic 

Impacts – Social 

Impacts – Environmental 

Data availability 

It addresses chemical pollution of surface water bodies 

To list the priority hazardous substances related to the WFD 2000/60/EC 

•  Costs: administrative burdens; investment costs 
•  Benefits: improved water quality; improved public health; improved 

aquatic biodiversity 

•  Uniform rules for industry in EU 
•  Reduced cost of treatment for drinking and industrial process water 
•  Potential for more productive commercial fisheries and aquaculture 
•  Fostering research and innovation 
•  Reduced exposure to hazardous chemicals for humans both in case of 

occupational and recreational purposes 

•  Improved quality of fish and shellfish in commercial fisheries and for 

recreational fishing 

•  Improved amenity value of water bodies 
•  Cleaner drinking water for livestock and reduced accumulation of 

hazardous chemicals in animal products 

•  Reduced potential for accumulation of hazardous chemicals by crops 
•  Improved chemical status of water bodies 
•  Improved aquatic biodiversity 
Quantitative estimate of surveillance cost of PS is available in 2011 IA 

Implementation progress 

Added as an Annex to the WFD 2000/60/EC 

Monitoring system / 
techniques 

Monitoring of the chemical status of water bodies on MS-level 

235 Information in factsheet based on: EC [SEC(2011) 1547 final] SWD IMPACT ASSESSMENT (...) as 
regards priority substances in the field of water policy 

102 

 
 
 
                                                 
Water Legislation 

Document name 

DECISION No 2455/2001/EC establishing the list of priority substances 
in the field of water policy and amending Directive 2000/60/EC 

Relevance for CoNE case 
study? 
Reference 

This list is of relevance to the pharmaceutical residues issue (issue 5) 

DECISION No 2455/2001/EC establishing the list of priority substances in the 
field of water policy and amending Directive 2000/60/EC 

Table 15: Floods Directive factsheet236 

Document name 

DIRECTIVE 2007/60/EC on the assessment and  
management of flood risks 

Level of implementation 

EU (providing guidelines) and MS (implementation) 

Year of entry into force 

2007 

Type of policy  

Command & control 

Area of focus 

Flood risks within river basins and coastal areas 

Main policy tool 

Flood risk management plans submitted to the EC 

Context 

Objectives 

Costs  

Benefits  

Impacts – Economic 

Floods pose various threats to human lives, cultural heritage and the 
economy. The probability of flood events and related human and economic 
vulnerability have been increasing due to climate change and human activity. 
To establish a framework for the assessment and management of flood risks, 
aiming at the reduction of the adverse consequences for human health, the 
environment, cultural heritage and economic activity. 
•  Administrative burdens 
•  Investment costs (e.g. investment costs for NWRMs differ per measure 
and can range from €48/ha for buffer strips to around €783000 /ha for 
urban infiltration measures, while the annual O&M costs range from 
€2/ha for re-meandering measures to around €73000 /ha for the urban 
infiltration ones)237 

•  Lives saved;  
•  Improved human health (less injuries or diseases);  
•  Improved environmental quality 
•  Improved resilience; 
•  Economic benefits (e.g. some estimations suggest that NWRMs bring 
flood protection benefits of around €740 million  for the period 2010-
2100) 

•  Reduce costs of flood damages (e.g. economic damage from floods in EU 
are estimated at €6400 million/year for the period 2006-2010, while the 
total additional damage from climate change scenarios ranges €7700 – 

236 Information in factsheet based on: EC [SEC(2006) 66] SWD Annex to the Proposal for a 
DIRECTIVE(...)on the assessment and management of floods - Impact Assessment;  
EC (2014) Implementation of the Floods Directive 
http://ec.europa.eu/environment/water/flood_risk/timetable.htm;  
EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 

237A list of different NWRMs and their associated investment and O&M costs can be found in EC 
[SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources, part 2, p.22 

103 

 
 
 
                                                 
 
Cost of Non-Europe Report 

Document name 

DIRECTIVE 2007/60/EC on the assessment and  
management of flood risks 

15000 million/year) 

•  Reduce disruptive effects to the properties market, tourism and other 

business activities in affected area 

•  Foster research and innovation 
•  Improved physical and psychological health of humans 
•  Reduced number of casualties and injuries 
•  Protected cultural heritage 
•  Improved water quality 
•  adaptation to climate change effects 
•  Safeguarding of biodiversity 
Quantification of flood costs and damages for the Rhine region and the UK in 
the accompanying IA. Estimates of investment and other costs of NWRMs 
are available in the IA accompanying the Blueprint. 
So far all Member States are on track with the transposition of the directive 
and the preliminary flood risk assessments. Member States are expected to 
submit flood risk management plans by December 2015. 
Monitoring on MS-level 

This directive is related to PoM issue (issue 1) 

DIRECTIVE 2007/60/EC on the assessment and management of flood risks 

Impacts – Social 

Impacts – Environmental 

Data availability 

Implementation progress 

Monitoring system / 
techniques 
Relevance for CoNE case 
study? 
Reference 

Table 16: Water scarcity and droughts (WS&D) policy factsheet238 

Document name 

COM [(2007) 414] Addressing the challenge of water scarcity and 
droughts in the European Union and the latest review COM [(2012) 
672)] Report on the Review of the European Water Scarcity and 
Droughts Policy 

Level of implementation 

EU (guidelines) and MS (adoption & implementation) 

Year of entry into force 

Various depending on related binding legislation 

Type of policy  

Guidelines for action 

Area of focus 

General 

Main policy tool 

Guidelines and proposed policy options in 7 areas: 
•  Putting the right price tag on water 
•  Allocating water and water-related funding more efficiently 
•  Improving drought risk management 
•  Considering additional water supply infrastructures 
•  Fostering water efficient technologies and practices 
•  Fostering the emergence of a water-saving culture in Europe 
•  Improve knowledge and data collection. 
Member States are to include WS&D considerations in their RBMPs 

238 Information in factsheet based on: EC [SEC(2007) 993] SWD IMPACT ASSESSMENT Accompanying 
document to the COMMUNICATION (...) Addressing the challenge of water scarcity and droughts in 
the European Union;  
EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 

104 

 
 
 
                                                 
 
Water Legislation 

Document name 

Context 

Objectives 

Costs and benefits  

COM [(2007) 414] Addressing the challenge of water scarcity and 
droughts in the European Union and the latest review COM [(2012) 
672)] Report on the Review of the European Water Scarcity and 
Droughts Policy 

Water scarcity and droughts pose threats to human health and economic 
activity while the number of droughts in the EU has increased over the past 
30 years 
To present policy options at EU, national and regional levels to address and 
mitigate the effects of water scarcity and droughts  
•  Costs: when policy action is taken - administrative burdens on MS-level; 

investment costson MS-level 

•  Benefits: improved human health; improved quantitative status of water 

bodies; efficient use of resources 

Impacts – Economic 

•  Reduce costs associated with water scarcity and drought effects (e.g. 

scarcity costs for households, industry and tourism in Cyprus imply that 
the present value of total costs due to water shortages in the period 
2010-2030 may reach €200 million (2009 prices)) 

•  Internalise externality cost 
•  Develop tourism sector and other business activities related to water 

bodies 

•  Foster research and innovation related to sustainable water use 
•  Improved physical and psychological health of humans  
•  Access to drinking and bathing water 
•  Amenity value of bathing water sources 
•  Recreational value of preserved biodiversity 
•  Improved quantitative status of water bodies 
•  Mitigation of climate change effects 
•  Safeguarding of biodiversity 
•  Resource efficiency 
Economic costs of droughts; investment costs for some water-saving 
measures in accompanying IA as well as in IA accompanying the Blueprint 
Limited implementation related to all 7 areas. Meanwhile the EAA239 reports 
that there is an imbalance in much of Europe's surface waters with water use 
often exceeding water availability and this leads to water stress across much 
of Europe. Water scarcity is reported for nearly all river basin districts in the 
Mediterranean area. 
Specific monitoring depending on policy option on MS-level 

This policy is related to issue 1 – PoM, issue 2 – re-use of waste water, issue 
3 – ecodesign and water metering as well as issue 4 – economic instruments 
COM [(2007) 414] Addressing the challenge of water scarcity and droughts in 
the European Union  
COM [(2012) 672)] Report on the Review of the European Water Scarcity and 
Droughts Policy 

Impacts – Social 

Impacts – Environmental 

Data availability 

Implementation progress 

Monitoring system / 
techniques 
Relevance for CoNE case 
study? 
Reference 

239EEA (2012) European waters — current status and future challenges Synthesis 

105 

 
 
                                                 
Cost of Non-Europe Report 

Table 17: Drinking Water Directive (DWD) factsheet240 

Document name 

Level of implementation 
Year of entry into force 
Type of policy  
Area of focus 
Main policy tool 

Context 
Objectives 

Costs  

Benefits 

Impacts – Economic 

Impacts – Social 

Impacts – Environmental 

Data availability 

Implementation progress 

Monitoring system / 
techniques 

DIRECTIVE (98/83/EC) on the quality of water intended  
for human consumption 

EU (for minimum standards), MS (for implementation and monitoring) 
1998 
Command & control 
Water intended for human consumption with certain exceptions 
MS Reports on the quality of the water intended for human consumption 
every 3 years 
Clean drinking water is vital for human health 
To protect human health from the adverse effects of any contamination of 
water intended for human consumption by ensuring that it is wholesome 
and clean 
•  Administrative burdens;  
•  Investment costs(e.g. For treatment) 
•  Surveillance costs(e.g. the 2011 PS IA has estimated that the overall cost 
of current monitoring of existing PS in the EU27 is on average €69 million 
per year) 

•  Improved human health 
•  Improved water quality 
•  Create level-playing field in the EU 
•  Healthier and more productive population 
•  Improved human health 
•  Reduced exposure to contaminants in water 
•  Access to safe drinking water 
•  Recreational value of preserved biodiversity 
•  Improved chemical status of water 
•  Safeguarding of biodiversity 
No quantification of treatment costs found so far, costs of surveillance for PS 
is available in the PS IA.241 Information on implementation is available in the 
periodical EC reports, the last being from 2014.  
Overall high compliance levels and hence high quality of water for human 
consumption. The compliance rates related to microbiological and chemical 
parameters for large suppliers are higher than 90% in most Member States, 
some achieving 99-100% compliance (only 3 Member States did not achieve 
such compliance for the chemical parameters). Compliance rates for small 
suppliers are lower with 6 Member States exhibiting compliance rates for 
these parameters below 90%.So far three 3-year derogations have been 
granted.  
Some issues which need to be addressed are: 
•  Improve the water supply in remote areas and from small water suppliers 
•  Achieve more cost-effective monitoring and parameter analysis 
•  Consider new scientific information regarding chemicals and 

contaminants  

•  Improve consumer access to environmental information 
•  Update derogation mechanisms and implementation timescales 
Monitoring stations on MS-level  

240 Information in factsheet based on: EC [COM(2014) 363 final] Synthesis Report on the Quality of 
Drinking Water in the EU examining the Member States' reports for the period 2008-2010 under 
Directive 98/83/EC 
241 EC [SEC(2011) 1547 final] SWD IMPACT ASSESSMENT (...) as regards priority substances in the 
field of water policy 

106 

 
                                                 
Water Legislation 

Document name 

Relevance for CoNE case 
study? 
Reference 

DIRECTIVE (98/83/EC) on the quality of water intended  
for human consumption 

This directive is related to issue 1 – programmes of measures and issue 5 – 
pharmaceutical residue 
DIRECTIVE (98/83/EC) on the quality of water intended for human 
consumption 

Table 18: Bathing Water Directive (BWD) factsheet242 

Document name 

DIRECTIVE 2006/7/EC concerning the management of bathing water 
quality and repealing Directive 76/160/EEC 

Level of implementation 

EU (for minimum standards), MS (for implementation and monitoring) 

Year of entry into force 

2006 

Type of policy  

Command & control 

Area of focus 

Bathing water 

Main policy tool 

Yearly national and EU reports on the quality of bathing water 

Context 

Objectives 

Costs  

Benefits 

Impacts – Economic 

Impacts – Social 

Impacts – Environmental 

Data availability 

Implementation progress 

The quality of bathing water needs to be monitored and protected 

To preserve, protect and improve the quality of the environment and to 
protect human health by complementing Directive 2000/60/EC with regard 
to bathing water 
•  Administrative burdens;  
•  Investment costs (e.g. for conventional waste water treatment the 

operational cost is on average €1.9/m3 and the capital investment is 
€474 – 593/m3 per day) 

•  Surveillance costs (e.g. the 2011 PS IA has estimated that the overall cost 
of current monitoring of existing PS in the EU27 is on average €69 million 
per year) 

•  Improved human health 
•  Improved water quality 
•  Develop tourism sector and other business activities related to bathing 

water bodies 

•  Improved health of humans  
•  Access to safe bathing water 
•  Amenity value of bathing water sources 
•  Recreational value of preserved biodiversity 
•  Improved chemical status of water bodies 
•  Safeguarding of biodiversity 
Costs of surveillance for PS are available in the PS IA, costs for waste water 
treatment are available in the Blueprint IA.243 Information on 
implementation is available in the periodical EC reports, the last being from 
2014. 
In 2013: 94.7 % of all bathing waters in EU met the minimum water quality 
standards set by the BWD; 82.6 % of the bathing waters achieved “excellent 
quality” (or complying with the most strict 'guide' values) 

242 Information in factsheet based on: EEA (2014) European bathing water quality in 2013 
243 EC [SEC(2011) 1547 final] SWD IMPACT ASSESSMENT (...) as regards priority substances in the 
field of water policy 
EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 

107 

 
 
                                                 
Cost of Non-Europe Report 

Document name 

DIRECTIVE 2006/7/EC concerning the management of bathing water 
quality and repealing Directive 76/160/EEC 

Monitoring system / 
techniques 
Relevance for CoNE case 
study? 
Reference 

Monitoring of parameters on MS-level 

This directive is relevant for issue 1 -  programmes of measures and issue 5 – 
pharmaceutical residues 
DIRECTIVE 2006/7/EC concerning the management of bathing water quality 
and repealing Directive 76/160/EEC 

Table 19: Groundwater Directive (GWD) factsheet244 

Document name 

DIRECTIVE (2006/118/EC) on the protection of groundwater  
against pollution and deterioration 

Level of implementation 

EU (for guidance); MS (for implementation and monitoring) 

Year of entry into force 

2007 

Type of policy  

Command & control 

Area of focus 

Groundwater 

Main policy tool 

Context 

Objectives 

Costs  

Benefits 

Impacts – Economic 

Impacts – Social 

Impacts – Environmental 

Data availability 

RBMPs - assessments of the status is published in the MS’ RBMPs, which are 
reviewed by the EC 
The quality and quantity of groundwater in the EU needs to be protected 
from deterioration and chemical pollution 
•  To establish specific measures to prevent and control pollution of 

groundwater 

•  To complement the WFD on the provisions preventing or limiting inputs 

of pollutants 

•  Administrative burdens 
•  Investment costs 
•  Surveillance costs (e.g. the 2011 PS IA has estimated that the overall cost 
of current monitoring of existing PS in the EU27 is on average €69 million 
per year) 

•  Improved water quality and quantity 
•  Improved human health 
•  Create a level-playing field within the EU 
•  Reduce costs of water scarcity and shortages 
•  Access to safe drinking water 
•  Reduced exposure to hazardous chemicals for humans and animals 
•  Reduced probability of chemical absorption by crops 
•  Improved chemical status of groundwater 
•  Improved quantitative status of groundwater 

No detailed quantification of costs found so far – costs of surveillance for PS 
are available in the PS IA.245 Information on implementation is available in 
the 2010 EC report and SWD. 

244Information in factsheet based on: EC [SEC(2010) 166 final] SWD accompanying the Report from the 
Commission in accordance with Article 3.7 of the Groundwater Directive 2006/118/EC on the 
establishment of groundwater threshold values 
EEA (2012) European waters — current status and future challenges Synthesis 
245EC [SEC(2011) 1547 final] SWD IMPACT ASSESSMENT (...) as regards priority substances in the field 
of water policy 

108 

 
 
 
                                                 
Water Legislation 

Document name 

Implementation progress 

Monitoring system / 
techniques 
Relevance for CoNE case 
study? 
Reference 

DIRECTIVE (2006/118/EC) on the protection of groundwater  
against pollution and deterioration 
26 Member States have reported on the establishment of threshold values in 
the required format.  Drinking water standards were most frequently 
reported as basis of threshold values, either laid down in the EU DWD or 
respective international or national standards. More than half of the 
Member States (56 %) also considered environmental quality objectives – 
international (e.g. EQS Directive) or national standards. 
By area, about 25 % of groundwater across Europe is in poor chemical status. 
From the total number of groundwater bodies reported in the RBMPs 6.4 % 
are classified as being in poor quantitative status. Poor groundwater status is 
distributed throughout several countries, namely Belgium, Cyprus, the Czech 
Republic, Denmark, Italy, Malta, and the United Kingdom. Nonetheless, by 
2015, almost 90% of groundwater bodies is forecasted to be in good 
chemical status and 96 % - in good quantitative status. 
The status of groundwater bodies is monitored on MS-level 

This directive is relevant for issue 1 – PoM, issue 5 – pharmaceutical residues 

DIRECTIVE (2006/118/EC) on the protection of groundwater against 
pollution and deterioration 

Table 20: Nitrates Directive factsheet246 

Document name 

DIRECTIVE (91 /676/EEC) concerning the protection of waters against 
pollution caused by nitrates from agricultural sources 

Level of implementation 

EU for standards, MS for implementation and monitoring 

Year of entry into force 

1991 

Type of policy  

Command & control 

Area of focus 

General 

Main policy tool 

4-yearly reports by Member States and a synthesis report by the EC 

Context 

Objectives 

Costs  

Benefits 

Impacts – Economic 

The nitrate content of water bodies has been increasing and the main cause 
of  pollution  from  diffuse  sources  in  the  EU  surface  and  ground  waters  is 
nitrates from agricultural sources 
•  To reduce water pollution caused or induced by nitrates from agricultural 

sources 

•  To prevent further such pollution 
•  Administrative burdens (e.g. the administrative burden that the reporting 

cycles of the Nitrates Directive is not synchronised with the WFD) 

•  Investment costs 
•  Improved environmental quality 
•  Preserved biodiversity 
•  Reduce cost of water treatment 
•  Create level-playing field 

246Information in factsheet based on: EC [COM(2013) 683 final] REPORT (...) on the implementation of 
Council Directive 91/676/EEC concerning the protection of waters against pollution caused by nitrates 
from agricultural sources based on Member State reports for the period 2008–2011;  
EC [SWD(2012) 382 final] SWD IMPACT ASSESSMENT Accompanying the document 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 

109 

 
 
 
                                                 
Cost of Non-Europe Report 

Document name 

Impacts – Social 

Impacts – Environmental 

Data availability 

Implementation progress 

Monitoring system / 
techniques 
Relevance  for  CoNE  case 
study? 
Reference 

DIRECTIVE (91 /676/EEC) concerning the protection of waters against 
pollution caused by nitrates from agricultural sources 

•  Access to safe drinking water 
•  Increase amenity value of water bodies 
•  Recreational value of preserved biodiversity 
•  Improved chemical status of water bodies 
•  Mitigation of climate change effects 
•  Safeguarding of biodiversity 
No  quantification  of  costs  found  so  far.  Information  on  implementation  is 
available in the periodical EC reports, the last being from 201334. 
The pressure from agriculture has decreased, although not uniformly, in the 
period 2008–2011 compared to 2004–2007 regarding the numbers of cattle, 
pigs and sheep and remained stable regarding poultry. At the same time, the 
consumption  of  chemical  fertilizers  has  decreased,  continuing  its  long-term 
trend. 
Monitoring  of  water  quality  has  improved,  with  an  increase  in  the  total 
number  of  monitoring  stations  for  groundwater  and  surface  water.  Of  all 
reported  groundwater  stations,  14.4%  exceeded  the  threshold  of  50  mg/l 
nitrates and 5.9% were between 40 and 50 mg/l nitrates, indicating a slight 
improvement compared to the previous reporting period.  
Nevertheless,  further  decrease  of  pollution  is  needed.  Another  challenge  is 
posed by the lack of synchronisationbetween the reporting periods under the 
Nitrates directive and the RBMPs of the WFD. 
Monitoring stations on MS-level 

This directive is relevant for issue 1 – programmes of measures 

DIRECTIVE  (91  /676/EEC)  concerning  the  protection  of  waters  against 
pollution caused by nitrates from agricultural sources 

110 

 
 
Water Legislation 

Annex B – Stakeholders interviewed 

•  European Environmental Bureau, Pieter de Pous (Policy Director) and 

Stephane Arditi (Senior Policy Officer: Waste & Products) 

•  EurEeau, Carl-Emil Larsen (President) and Bruno Tisserand (Chair of 

Commission on Wastewater) 

•  Ecologistas en Acción, Santiago Martin Barajas et al. in writing 

•  Scottish Environment Protection Agency, Peter Pollard 

•  European Federation of Pharmaceutical Industries and Associations, Dr 

Bengt Mattson, Co-Chair PIE taskforce 

•  Peter Gammeltoft, Former Head of Unit Water in DG Environment of the 

European Commission 

•  Eduard Interwies, consultant involved in Blueprint  

•  Thomas Dworak, consultant involved in Blueprint 

•  Axel Singhofen, Advisor of the Greens / European Free Alliance in the 

European Parliament 

•  Pierre Strosser, Acteon 

The European Chemical Industry Council (CEFIC)) and the European Association of Metals 
(EUROMETAUX), were invited for interviews, but were not available for interviews during 
the study time frame. 

111 

 
 
 
 
Cost of Non-Europe Report 

Annex C - Bibliography 

Author  

Acteon 

Acteon 

Arcadis 

Arcadis 

Bio Inteligence Service 

Bio Inteligence Service 

Bio Inteligence Service& 
Cranfield University 
Bixio, D. et al. 

Broekx S, et al. 

CEPS 

CSES & Oxford Research 

Danish Government 

DEFRA 

DEFRA - Walker, A. 

Year 

2012 

2012 

2012 

2012 

2013 

2012 

2009 

2006 

2011 

2012 

2012 

2013 

2014 

2009 

ref. code  

Title 

Project number 
11589 | February 
2012 

Comparative study of pressures and measures in the major river basin management plans in the 
EU: Task 4 b - Costs & Benefits of WFD implementation: Final report 

Gap Analysis of the Water Scarcity and Droughts Policy in the EU, Final Report 

The role of water pricing and water allocation in agriculture in delivering sustainable water use in 
Europe – FINAL REPORT European Commission 

Comparison of cost price of water/ waste water/ rain water for users in different EU Member 
States;  
Study on the environmental risks of medicinal products, FINAL REPORT, prepared for Executive 
Agency for Health and Consumers  
Water saving potential in agriculture in Europe: findings from the existing studies and application 
to case studies - Final Report 
Study on water efficiency standards, Final Report  

Wastewater re-use in Europe 

Designing a Long-Term Flood Risk Management Plan for the Scheldt Estuary Using a Risk Based 
Approach. Natural Hazards, 57 (2), 245‒266, www.springerlink.com/content/e43138836415t02n/ 
WHICH ECONOMIC MODEL FOR A WATER-EFFICIENT EUROPE? 

Evaluation of the Ecodesign  Directive (2009/125/EC)  Final Report 

Protect water, nature and human health: Pesticides strategy 2013-2015  

Water efficient enhanced capital allowances from www.gov.uk/government/publications/water-
efficient-enhanced-capital-allowances 
The Independent Review of Charging for Household Water and Sewerage Services, Final report 
from www.gov.uk/government/uploads/system/uploads/attachment_data/file/69459/walker-
review-final-report.pdf 

112 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ref. code  

Title 

Water Legislation 

Author  

De Stefano 

Year 

2010 

Dickson, M and J.P. Gagnon 

2009 

E3Mlab 

Ecologic 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

2014 

2007 

2014 

2014 

2014 

2014 

2014 

2014 

2014 

2013 

2013 

2013 

2013 

COM(2014) 363 
final 

COM(2014) 398 
final/2 

COM(2013) 249 
final 
SWD(2013) 155 
final 
COM(2013) 574 
final 
COM(2013) 683 
final 

Facing the water framework directive challenges: A baseline of stakeholder participation in the 
European Union. Journal of Environmental Management. Volume 91, Issue 6, June 2010, Pages 
1332–1340 
The cost of new drug discovery and development. Discovery Medicine, June 09, 2009 

Development and evaluation of long-term scenarios for a balanced European climate and energy 
policy until 2030 
EU Water saving potential (Part 1 –Report) 

Agriculture and rural development webpage: http://ec.europa.eu/agriculture/index_en.htm 

Economic assessment of the Ebro Water Transfer – ES webpage: 
http://ec.europa.eu/ourcoast/index.cfm?menuID=7&articleID=18 
Background document to the Public Consultation on Policy Options to optimise Water Re-use in 
the EU 
Synthesis Report on the Quality of Drinking Water in the EU examining the Member States' 
reports for the period 2008-2010 under Directive 98/83/EC 
Implementation of the Floods Directive, homepage 
http://ec.europa.eu/environment/water/flood_risk/timetable.htm 
Communication (…)Towards a circular economy: A zero waste programme for Europe 

2030 Framework for Climate and Energy: Outcome of the October 2014 European Council, 
presentation, available at: 
http://ec.europa.eu/clima/policies/2030/docs/2030_euco_conclusions_en.pdf  
COMMUNICATION (...) Green Infrastructure (GI) — Enhancing Europe’s Natural Capital 

SWD Technical information on Green Infrastructure (GI) Accompanying the document 
COMMUNICATION (...) Green Infrastructure (GI) — Enhancing Europe’s Natural Capital 
(...) Seventh Report on the Implementation of the Urban Waste Water Treatment Directive 
(91/271/EEC) 
REPORT (...) on the implementation of Council Directive 91/676/EEC concerning the protection of 
waters against pollution caused by nitrates from agricultural sources based on Member State 
reports for the period 2008–2011 

113 

 
 
 
 
 
 
 
 
 
 
Cost of Non-Europe Report 

Author  

EC 
EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC  

EC  

EC  

EC  

EC  

EC 

Year 

2013 
2012 

2012 

2012 

2012 

2012 

2012 

2012 

2012 

2011 

2011 

2011 

2011 

2011 

2011 

2011 

ref. code  

Title 

SWD(2012) 382 
final 
COM(2012) 673 
final 
SWD(2012) 393 
final 
COM(2012) 670 
final 
SWD(2012) 379 
final 
COM(2012) 672 
final 
SWD(2012) 434 
final 
COM(2012) 765 
final 
SEC(2011) 1547 
final 

SEC(2011) 338 
final 
COM(2011) 571 
final 

Resource and Economic Efficiency of Water Distribution Networks in the EU, Final Report 
SWD IMPACT ASSESSMENT Accompanying the document COMMUNICATION (...) A Blueprint to 
Safeguard Europe's Water Resources 
COMMUNICATION (...) A Blueprint to Safeguard Europe's Water Resources 

SWD The Fitness Check of EU Freshwater Policy 

REPORT FROM THE COMMISSION (...) on the Implementation of the Water Framework Directive 
(2000/60/EC) River Basin Management Plans 
SWD European Overview (1&2) Accompanying the document REPORT (...) on the Implementation 
of the Water Framework Directive (2000/60/EC) River Basin Management Plans 
COMMUNICATION (...) Report on the Review of the European Water Scarcity and Droughts Policy 

SWD Establishment of the Working Plan 2012-2014 under the Ecodesign Directive 

REPORT (...) Review of Directive 2009/125/EC (...) establishing a framework for the setting of 
ecodesign requirements for energy-related products (recast) 
SWD IMPACT ASSESSMENT (...) as regards priority substances in the field of water policy 

EC (DG Environment) Technical Support for the Impact Assessment of the Review of Priority 
Substances under Directive 2000/60/EC  Substance assessment: Diclofenac 
EC (DG Environment) Technical Support for the Impact Assessment of the Review of Priority 
Substances under Directive 2000/60/EC  Substance assessment: 17 beta estradiol 
EC (DG Environment) Technical Support for the Impact Assessment of the Review of Priority 
Substances under Directive 2000/60/EC  Substance assessment: 17 alpha ethinylestradiol 

EC (DG Environment) Technical Support for the Impact Assessment of the Review of Priority 
Substances under Directive 2000/60/EC Substance assessment: Ibuprofen 
SWD Accompanying document to the Third Follow up Report to the Communication on Water 
Scarcity and Droughts in the European Union COM (2007) 414 final 
Roadmap to a Resource Efficient Europe 

114 

 
 
 
 
 
 
 
Author  

EC 

EC  

EC  

EC  

EC  

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

Water Legislation 

Year 

2011 

2010 

2010 

2010 

2010 

2009 

2009 

2009 

2008 

2007 

ref. code  

Title 

COM(2011) 21 

SEC(2010) 1357 
final 

SEC(2010) 166 
final 
COM(2010)228 
final  
CIS Guidance 
document 24 
COM(2009) 156 
final 
SEC(2009)415 

COM(2008) 660 
final 
COM(2007) 128 
final 

Communication (…)A resource-efficient Europe – Flagship initiative under the Europe 2020 
Strategy 
SWD SUMMARY OF THE IMPACT ASSESSMENT Accompanying document to the Draft Commission 
Regulation (...) with regard to ecodesign requirements for household dishwashers 
SWD SUMMARY OF THE IMPACT ASSESSMENT Accompanying document to the Draft Commission 
Regulation (...) with regard to ecodesign requirements for household washing machines 
SWD accompanying the Report from the Commission in accordance with Article 3.7 of the 
Groundwater Directive 2006/118/EC on the establishment of groundwater threshold values  
REPORT (...) Second Follow-up Report to the Communication on water scarcity and droughts in 
the European Union COM (2007) 414 final  
CIS FOR WFD (...) Technical Report - 2009 - 040: Guidance document No. 24 RIVER BASIN 
MANAGEMENT IN A CHANGING CLIMATE 
REPORT FROM THE COMMISSION (...) in accordance with article 18.3 of the Water Framework 
Directive 2000/60/EC on programmes for monitoring of water status 
SWD accompanying the Report from the Commission (...)  on programmes for monitoring of 
water status 
COMMUNICATION (...) Establishment of the working plan for 2009-2011 under the Ecodesign 
Directive 
COMMUNICATION (...) Towards sustainable water management in the European Union - First 
stage in the implementation of the Water Framework Directive 2000/60/EC 

2007 

SEC(2007) 362 

2007 

2007 

COM(2007) 414 
final 
SEC(2007) 993 

2006 

SEC(2006) 66 

SWD Accompanying (...) the COMMUNICATION (...) 'Towards Sustainable Water Management in 
the European Union' First stage in the implementation of the Water Framework Directive 
2000/60/EC 
COMMUNICATION (...) Addressing the challenge of water scarcity and droughts in the European 
Union 
SWD IMPACT ASSESSMENT Accompanying document to the COMMUNICATION (...) Addressing 
the challenge of water scarcity and droughts in the European Union 
SWD Annex to the Proposal for a DIRECTIVE(...)on the assessment and management of floods - 
Impact Assessment 

115 

 
 
ref. code  

Title 

Cost of Non-Europe Report 

Author  

EC 

EC - OIE & Ecologic 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

EC 

ECB 

EC Science for Environment 
Policy  

Year 

2005 

2005 

2004 

2004 

2003 

2003 

2003 

2003 

2003 

2003 

CIS Guidance 
document 14 

COM(2004)472 
final 
CIS info sheet 

CIS Guidance 
document 13 

CIS Guidance 
document 10 

CIS Guidance 
document 6 

CIS Guidance 
document 5 

CIS Guidance 
document 4 

CIS Guidance 
document 1 

2001 

CIS 

2014 

2012 

Guidance on the intercalibration process 2004 - 2006 

Evaluation of the impact of floods and associated protection policies, Final Report 

COMMUNICATION (...) Flood risk management: Flood prevention, protection and mitigation 

Common Implementation Strategy Working Group 2B: Drafting Group ECO1 Information Sheet 
on Assessment of the Recovery of Costs for Water Services for the 2004 River Basin 
Characterisation Report (Art 9) 
Overall approach to the classification of ecological status and ecological potential 

River and lakes – Typology, reference conditions and classification systems 

Towards a guidance on establishment of the intercalibration network and the processon the 
intercalibration exercise 

Transitional and Coastal Waters - Typology, Reference Conditions and Classification Systems 

Identification and Designation of Heavily Modified and Artificial Water Bodies 

COMMON IMPLEMENTATION STRATEGY FOR THE WATER FRAMEWORK DIRECTIVE (2000/60/EC) 
Guidance Document No 1 Economics and the Environment – The Implementation Challenge of 
the Water Framework Directive 
COMMON IMPLEMENTATION STRATEGY FOR THE WATER FRAMEWORK DIRECTIVE (2000/60/EC) 
and following guidance documents from http://ec.europa.eu/environment/water/water-
framework/facts_figures/guidance_docs_en.htm 
ECB reference exchange rate, UK pound sterling/Euro available at 
http://sdw.ecb.europa.eu/quickview.do;jsessionid=41684658E2CEACB9DABC182145CD8E8F?SER
IES_KEY=120.EXR.A.GBP.EUR.SP00.A 
More than economic incentives needed to reduce pesticide use from 
http://ec.europa.eu/environment/integration/research/newsalert/pdf/284na3_en.pdf 

116 

 
 
 
 
 
Author  

EC Science for Environment 
Policy  
ECA 

ECA 

ECEEE 

Ecorys 

ECSA 

EEA 

EEA 

EEA 

EEA 

EEA 

EEA 

EEA 

EEB 

EEB 

EEB 

Water Legislation 

Year 

2012 

2014 

2014 

2014 

2011 

2014 

2014 

2014 

2013 

2013 

2012 

2011 

2010 

2012 

2012 

2010 

ref. code  

Title 

Soil Sealing, in depth report 

Press Release: 
ECA/14/19 
Special Report 
No 4 

The common agricultural policy should take better account of water concerns, say EU Auditors 

Integration of EU water policy objectives with the CAP: a partial success 

European Council for Energy Efficient Economy (ECEEE) webpage: 
www.eceee.org/ecodesign/Horizontal-matters/eceee-pages-on-ecodesign-and-labelling-market-
surveillance/Msreport 
The role of market-based instruments in achieving a resource efficient economy 

ECSA Bulletin 62 - Winter 2014, Estuaries in Focus – Sigma Plan Proves Efficiency 

Policies and measures to promote sustainable water use from 
www.eea.europa.eu/themes/water/water-resources/policies-and-measures-to-promote-
sustainable-water-use 
European bathing water quality in 2013 

Assessment of cost recovery through water pricing 

ENVIRONMENTAL INDICATOR REPORT 2013: NATURAL RESOURCES AND HUMAN WELL-BEING IN 
A GREEN ECONOMY 
European waters — current status and future challenges Synthesis 

Hazardous substances in Europe's fresh and marine waters 

Pharmaceuticals in the environment — Results of an EEA workshop 

EEB recommendations for the European Council on the Blueprint to Safeguard Europe’s Water 
Resources 
Ten Rivers:  A review of Europe’s New Water Protection 

10 years of the Water Framework Directive: A Toothless Tiger? - A snapshot assessment of EU 
environmental ambitions 

EEA Technical 
report No 
16/2013 

EEA Report - No 
9/2012 
EEA Technical 
report No 8/2011 
EEA Technical 
report No 1/2010 

117 

 
 
 
 
 
 
 
 
 
 
 
Cost of Non-Europe Report 

Author  

EEB, RSPB and Pond 
Conservation 
EEB - editor Scheuer, S. 

Eftec 

EP 

EPI Water 

EPRS 

EurEau 

EurEau 

EurEau 

EurEau 

EurEau 

EurEau 

EurEau 

EurEau 

EurEau 

EurEau - Angelakis, A. et al. 

Year 

2006 

2005 

2010 

2014 

2011 

2014 

2014 

2014 

2012 

2012 

2012 

2011 

2011 

2010 

2009 

2007 

ref. code  

Title 

NGO Technical Review of the Water Framework Directive Intercalibration Process 

EU Environmental Policy Handbook: A Critical Analysis of EU Environmental Legislation - Making it 
accessible to environmentalists and decision makers 
Scoping Study on the Economic (or Non-Market) Valuation Issues and the Implementation of the 
Water Framework Directive 
Mapping the Cost of Non-Europe 2014-2019, July 2014 edition  
www.europarl.europa.eu/the-secretary-general/resource/static/files/files/2014-july---mapping-
the-cost-of-non-europe--en-.pdf 
Evaluating economic policy instruments for sustainable water management in Europe, WP3 EX-
POST Case studies  The Danish Pesticide Tax from  
www.feem-project.net/epiwater/docs/d32-d6-1/CS4_Denmark.pdf 
Mapping the Cost of Non-Europe, 2014 -19, from  
www.europarl.europa.eu/the-secretary-general/resource/static/files/files/mapping-the-cost-of-
non-europe--march-2014-.pdf 
EurEau’s Contribution to the European Commission Strategic Approach on Pharmaceuticals in the 
Environment 
Cost recovery in the WFD: WFD article 9, recovery of cost for water services 

EurEau POSITION ON THE WATER BLUEPRINT 

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 POSITION PAPER on how the revision of the Fertiliser Regulation should promote 
sustainable use of sludge in agriculture 
Methodological guide on Tariffs, Taxes and Transfers in the European Water Sector, Final Report 
for the WWF6 
EurEau Position Paper Water re-use and other alternative resources at home: rainwater 
harvesting and greywater recycling for domestic purposes 
EurEau Position on Control at Source 

EurEau position on water re-use for irrigation as a water scarcity solution 

WASTEWATER RECYCLING AND RE-USE IN EUREAU COUNTRIES: With Emphasis on Criteria Used 

118 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Water Legislation 

Author  

EUWI 

Eurostat 

EWA 
EWA 

EWA 

EWA 

Year 

2012 

2014 

2012 
2011 

2008 

2007 

Global Water Intelligence 

2009 

ref. code  

Title 

Pricing water resources to finance their sustainable management: A think-piece for the EUWI 
Finance Working Group 
Number of private households by household composition, number of children and age of 
youngest child (1 000), last updated on 29.04.2014 and available at 
http://appsso.eurostat.ec.europa.eu/nui/submitViewTableAction.do 
The Water Framework Directive requires new tools for a better water quality monitoring 
Water re-use projects - technical and economic sustainability 

The polluter-pays! But, for what? 

WATER RE-USE IN EUROPE from: 
www.ewa-online.eu/tl_files/_media/content/documents_pdf/Publications/E-
WAter/documents/21_2007_07.pdf 
The truth behind Italy’s illegal abstraction  from 
www.globalwaterintel.com/archive/10/5/general/truth-behind-italys-illegal-abstraction.html 

Global Water Intelligence 

2007 

Desalination Markets from www.globalwaterintel.com 

Hardy, L., Garrido, A. & Juana, 
L.  
Hering, D. et al. 

Herrington, P 

IEEP, Acteon, Arcadis, Fresh 
Thoughts Consulting, Milieu 
IEEP, ECOLOGIC, GHK, SYZYGY, 
TAU, UNIVERSITY OF 
ANTWERP, VITO 
International Energy Agency 
International Green Roofs 
Policies 
JRC 
de Roo, A. et al. 

2012 

2010 

2006 

2012 

2010 

2013 
2014 

2012 

Evaluation of Spain’s Water-Energy, Nexus. International Journal of Water Resources 
Development. 28: 151-170 
The European Water Framework Directive at the age of 10: A critical review of the achievements 
with recommendations for the future. Science of the Total Environment, 408. 4007-4019 
Critical review of relevant research concerning the effects of charging and collection methods on 
water demand, different customer groups and debt 05/CU/02/1. UKWIR 
SERVICE CONTRACT TO SUPPORT THE IMPACT ASSESSMENT OF THE BLUEPRINT TO SAFEGUARD 
EUROPE’S WATERS ASSESSMENT OF POLICY OPTIONS FOR THE BLUEPRINT, FINAL REPORT 
Green Infrastructure In-Depth Case Analysis Theme 4: Freshwater And Wetlands Management 
And Restoration; TASK 4.1: IN-DEPTH CASE ANALYSIS – GREEN INFRASTRUCTURE 
IMPLEMENTATION AND EFFICIENCY – ENV.B.2./SER/2010/0059 
Energy Efficiency Market Report 
International Green Roofs Policies from http://livingroofsworld.com/page22.php 

A multi-criteria optimisation of scenarios for the protection of water resources in Europe, 
Support to the EU Blueprint to Safeguard Europe’s Waters 

119 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost of Non-Europe Report 

Author  

JRC 
Thieu, V. et al. 
JRC 
Burek, P. et al. 
JRC 
Bouraoui, F. Grizzetti, B. 
&Aloe, A. 
Kampragou, E. et al. 
Keessen, A. et al. 

KNAPPE 

Landesamt für Natur, Umwelt 
und Verbraucherschutz 
Nordrhein Westfalen 

Malaj, E. et al. 

MarketWatch 

OECD 

Ofwat 

Philip Lee Solicitors 

PILLS 

Year 

2012 

2012 

2011 

2011 
2010 

2008 

2013 

2014 

2009 

2011 

2009 

2010 

ref. code  

Title 

Scenario analysis of pollutants loads to European regional seas for the year 2020 Part I: Policy 
options and alternative measures to mitigate land based emission of nutrients 
Evaluation of the effectiveness of Natural Water Retention Measures, Support to the EU 
Blueprint to Safeguard Europe’s Waters 
Long term nutrient loads entering European seas 

Towards the harmonization of water-related policies for managing drought risks across the EU 
European River Basin Districts: Are They Swimming in the Same Implementation Pool? J 
Environmental Law (2010) 22 (2): 197-221. doi: 10.1093/jel/eqq003 
State-of-art review of policy instrumentsto limit the discharge of pharmaceutical productsinto 
European waters. Deliverable D3.1 from the KNAPPE project (Knowledge and Need Assessment 
on Pharmaceutical Products inEnvironmental Waters) 
Der Zustand der Gewässer in Nordrhein Westfalen from: 
www.umwelt.nrw.de/umwelt/pdf/monitoring.pdf 

Supporting Information for Organic chemicals jeopardize the health of freshwater ecosystems on 
the continental scale 
Involvement of Civil Society in Market Surveillance of Ecodesign and Energy Labelling" 
(MARKETWATCH) homepage:  
http://eaci-projects.eu/iee/page/Page.jsp?op=project_detail&prid=2644 
Managing Water for All, AN OECD PERSPECTIVE ON PRICING AND FINANCING: KEY MESSAGES 
FOR POLICY MAKERS 
Exploring the costs and benefits of faster, more systematic water metering in England and Wales 
from http://www.ofwat.gov.uk/future/customers/metering/pap_tec201110metering.pdf 
WATER FRAMEWORK DIRECTIVE 
Alice Whittaker, Partner, Council Review – Issue 30 (November 2009) 
Pharmaceutical residues in the aquatic system – a challenge for the future: Insights and activities 
of the European cooperation project PILLS 

120 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Author  

PôleÉco-conception et 
Management du Cycle de Vie 
& Institut de développement 
de produits 
Stella Consulting 

Sustainable Europe Research 
Institute 
TYPSA 

TYPSA 

UNECE 

VHK 

Water UK 

Water UK 

Water UK 
WHO 

WssTP 

WWF 

WWF&Adena 

Zachariadis, T. 

Year 

2014 

2012 

2009 

2013 

2012 

2009 

2011 

2014 

2014 

2012 
2012 

2013 

2010 

2006 

2010 

ref. code  

Title 

Water Legislation 

Profitability of Ecodesign: an Economic Analysis, Highlights from 
http://cloud.snappages.com/b0d6d10923becba07c0287d0b0af8fd47ed8a57d/Profitability%20of
%20ecodesign_highlights_1.pdf 

Costs, benefits and climate proofing of natural water retention measures (NWRM), Final Report 

How to measure Europe’s resource use - An analysis for Friends of the Earth Europe.;  

UPDATED REPORT ON WASTEWATER RE-USE IN THEEUROPEAN UNION 

Service contract for the support to the follow-up of the Communication on Water scarcity and 
Droughts - WASTEWATER RE-USE IN THE EUROPEAN UNION 
Guidance on Water and Adaptation to Climate Change 

Final Report Task 1-4 Study on Amended Working Plan under the Ecodesign Directive (remaining 
energy-using products and new energy-related products 
Water UK briefing: A revision of the Water Framework Directive 

Water UK position paper: pharmaceutical residues in drinking water 

Water UK Position Paper: Revision of Annexes II and II of the Drinking Water Directive 
Pharmaceuticals in drinking water 
http://apps.who.int/iris/bitstream/10665/44630/1/9789241502085_eng.pdf?ua=1 
Executive Summary Water Re-use Report 

Assessment of the restoration potential along the Danubeand main tributaries 

Illegal water us in Spain, effects and solutions 

The Costs of Residential Water Scarcity in Cyprus: Impact of Climate Change and Policy Options, 
available at 
http://works.bepress.com/cgi/viewcontent.cgi?article=1015&context=theodoros_zachariadis 

121 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
123 

 
 
 
 
 
 
125 

 
 
This 
‘Cost  of  Non-Europe’  study  examines  the  state  of 
implementation of current EU Water Legislation and identifies the 
cost of the lack of further European action in this field.  

The  assessment  made  of  existing  water  legislation  confirms  that 
there  are  still 
implementation  gaps  and  areas  of  poor 
performance. The examination of five case studies, where it was 
believed  that  a  significant  potential  for  further  EU  action  exists, 
served  to  demonstrate  that  there  are  several  barriers  which 
hinder  the  achievement  of  the  goals  set  in  the  legislation.  More 
European  action  would  accordingly  be  necessary  to  limit  the 
impact on Europe's water quality of flooding or of pharmaceutical 
residues. To limit the use of fresh water more generally, there is a 
need  for  European  coordination  to  increase  the  use  of  water-
efficient equipment and water-metering.   

This research makes a cautious estimate that the benefits of full 
implementation of existing legislation could reach 2.8 billion euro 
per  year.  The  study  also  demonstrates  that  further  European 
action in this field could provide further added value, representing 
a ‘cost of non-Europe’ of some 25 billion euro per year. 

This is a publication of the European Added Value Unit 
EPRS | European Parliamentary Research Service 
European Parliament 

PE 536.369 

ISBN:  978-92-823-7110-7 

DOI: 10.2861/303057 

CAT: QA-04-15-333-EN-N