COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Eighth Report on the Implementation Status and the Programmes for Implementation (as required by Article 17) of Council Directive 91/271/EEC concerning urban waste water treatment
Date: 2016-03-04
Institutions: Directorate-General for Environment, European Commission
Subjects: EU investment, application of EU law, environmental monitoring, innovation, urban area, wastewater, water management, water pollution, water protection, water resources

EUROPEAN 
COMMISSION 

Brussels, 4.3.2016  
SWD(2016) 45 final 

COMMISSION STAFF WORKING DOCUMENT 
Accompanying the document 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE 
COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE 
COMMITTEE OF THE REGIONS 

Eighth Report on the Implementation Status and the Programmes for Implementation 
(as required by Article 17) of Council Directive 91/271/EEC concerning urban waste 
water treatment 

{COM(2016) 105 final} 

EN 

   EN 

 
 
 
 
  
 
TABLE OF CONTENTS 

1.1- National and EU compliance rates as concerns collection, secondary treatment and 
more stringent treatment.........................................................................................................4 

1.2-Figures related to Individual or other Appropriate Systems (IAS)..................................5 

1.2.1- Percentage of agglomerations in which IAS is applied............................................5 

1.2.2- Percentage of generated load addressed through IAS..............................................5 

1.3- Compliance status of capital cities..................................................................................6 

1.4- Maps on compliance with the Directive at regional level...............................................7 

1.4.1- Compliance with the requirements of Article 3 of the Directive on regional level in 
EU-28 Member States ........................................................................................................7 

1.4.2- Compliance with the requirements of Article 4 of the Directive on regional level in 
EU-28 Member States ........................................................................................................8 

1.4.3- Compliance with the requirements of Article 5 of the Directive on regional level in 
EU-28 Member States ........................................................................................................9 

2- Information on legal procedures during the 8th reporting exercise......................................10 

2.1- Court judgments 2013-2015 .........................................................................................10 

2.2- Main infringement cases 2013-2014.............................................................................12 

Infringement Cases ...........................................................................................................12 

3 - Distance to compliance.......................................................................................................13 

3.1 - Introduction..................................................................................................................13 

3.2 - Expired deadlines of the UWWTD..............................................................................14 

3.2.1 - Connection to collecting systems and treatment through IAS ..............................14 

3.2.2 - Waste water connected, secondary treatment in place and performance 
requirements met ..............................................................................................................15 

3.2.3 - Waste water connected, more stringent treatment in place and performance 
requirements met ..............................................................................................................17 

3.3 - Varying deadlines of the UWWTD .............................................................................19 

3.3.1 - Connection to collecting systems and treatment through IAS ..............................20 

3.3.2 - Waste water connected, secondary treatment in place and performance met.......20 

2 

 
 
3.3.3 - Waste water connected, more stringent treatment in place and performance met 22 

3.4 - Conclusions..................................................................................................................22 

4 - Summary of assessment of Article 17 Report ....................................................................23 

3 

 
 
 
1- Details on implementation results presented in the 8th Implementation Report 

The  information  provided  in  Chapter  2  of  the  8th  Urban  Waste  Water  Treatment 
implementation report gives a good overview of the situation mainly at EU level. This annex 
provides  additional  tables,  graphs  and  maps,  illustrating  in  a  more  detailed  manner  the 
implementation results at (sub) national level.  

1.1- National and EU compliance rates as concerns collection, secondary treatment and 
more stringent treatment 

Member State 

Article 3                        compliance 
rate (%) 

Article 4                         

Article 5                         

compliance rate (%) 

compliance rate (%) 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

United Kingdom 

EU 15* 

EU 13** 

100

98

12

100

97

11

100

82

1

transition period pending

transition period pending

transition period pending

100

100

100

94

100

100

100

100

100

100

-

100

100

100

100

100

-

100

99

100

57

100

100

100

100

86

60

87

99

97

100

88

100

96

93

91

-

99

100

99

0

100

-

77

48

98

14

86

98

98

94

68

100

54

99

89

100

99

100

100

64

1

-

0

97

42

0

100

-

73

16

43

34

38

89

96

95

32

EU 28 
88
The  colours  in  the  table  above  show  ranges  of  compliance:  red:  0%  -  20%,  orange:  >20%  -  40%, 
yellow: >40% - 60%, green: >60 – 80%, blue: >80% - 100%, white: no data or transition period still 
pending. 

98

92

4 

 
 
1.2-Figures related to Individual or other Appropriate Systems (IAS) 

1.2.1- Percentage of agglomerations in which IAS is applied 

100

80

60

40

20

0

BG ES UK CY RO SI

IT DE GR CZ LT EE LV AT LU HU SK

1.2.2- Percentage of generated load addressed through IAS 

18

16

14

12

10

8

6

4

2

0

BG UK AT RO LU ES DE CY EE IT

SI CZ LT LV SK HU GR

5 

 
 
 
 
1.3- Compliance status of capital cities 

MEMBER 
STATE 

CAPITAL 
CITY 

Population 
equivalents 

Collection 
(Article 3) 

Secondary 
Treatment 
(Article 4) 

More stringent 
Treatment 
(Article 5.2 or 
5.4) 

FINAL 
Assessment 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Vienna 

Brussels 

Sofia 

Zagreb 

Nicosia 

Czech Republic  Prague 

Denmark 

Copenhagen 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Tallin 

Helsinki 

Paris 

Berlin 

Athens 

Budapest 

Dublin 

Rome 

Riga 

Lithuania 

Vilnius 

Luxembourg 

Luxembourg 

Malta 

La Valetta 

Netherlands 

Amsterdam 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 
United 
Kingdom 

Warsaw 

Lisbon 

Bucharest 

Bratislava 

Ljubljana 

Madrid 

Stockholm 

4,000,000 C 

1,460,000 C 

2,037,000 NC 

957,301 NR 

235,000 C 

1,140,489  C 

1,100,000 C 

468,000 C 

1,223,100 C 

9,577,285 C 

3,948,976 C 

5,200,000 C 

2,468,109  C 

2,362,329 C 

2,768,000 C 

762,739 C 

703,000 C 

228,741 C 

429,009 C 

901,908 C 

ND 

1,063,000 C 

2,159,995 NC 

600,032  C 

302,293 C 
4,072,507 C 

2,586,400  C 

C 

C 

NC 

NR 

NC 

C 

C 

C 

C 

C 

C 

C 

C 

C 

NC 

C 

C 

C 

NC 

C 

ND 

C 

NC 

C 

NC 

C 

C 

C 

C 

NC 

NC 

NR 

NA 

NC 

C 

C 

C 

C 

C 

C 

NA 

NC 

NA 

NC 

C 

NC 

NA 

C 

ND 

NA 

NC 

NC 

NA 

NR 

C 

C 

C 

NC 

NC 

NCO 

NC 

NC 

C 

C 

C 

C 

C 

C 

C 

NC 

NC 

NC 

C 

NC 

NC 

C 

ND 

C 

NC 

NC 

NC 

C 

C 

C 

London 

10,012,460 C 

Compliance status: C = compliance, NC = non-compliance, NR = not relevant as the deadline is 
not expired yet, either for Article 3, 4 or 5, NA = not applicable as agglomeration is discharging 
into  normal  area,  NCO  =  no  compliance  obligation  (in  general)  and  ND  =  no  data  available. 
Compliance with Article 5.4 refers to the area of discharge of the agglomeration.  

6 

 
 
 
  
 
 
1.4- Maps on compliance with the Directive at regional level 

1.4.1- Compliance with the requirements of Article 3 of the Directive on regional level in 
EU-28 Member States 

7 

 
 
 
1.4.2- Compliance with the requirements of Article 4 of the Directive on regional level in 
EU-28 Member States 

8 

 
 
 
1.4.3- Compliance with the requirements of Article 5 of the Directive on regional level in 
EU-28 Member States 

9 

 
 
 
2- Information on legal procedures during the 8th reporting exercise 
The  information  provided  in  Chapter  3.4  of  the  8th  Urban  Waste  Water  Treatment 
implementation  report  gives  general  information  on  the  legal  actions  the  European 
Commission  undertakes  when  non-compliance  with  the  Directive  is  suspected.  This  annex 
provides more details on ongoing and closed cases and on their status.  

2.1- Court judgments 2013-2015 

Case numbers1 

C-304/15 
Commission v 
United Kingdom 

Date of 
judgment 

pending 

Issue at stake / Short summary 

Failure to comply with Articles 3, 4 and 10 of UWWT 
Directive 

C-320/15 
Commission v 
Greece 

C-314/15 
Commission v 
France 

C-557/14 
Commission v 
Portugal 

C-398/14 
Commission v 
Portugal 

C-167/14 
Commission v 
Greece  

pending 

Failure to comply with Article 4 of UWWT Directive 

pending 

Failure to comply with Article 4 of UWWT Directive 

pending 

Failure to comply with Case C-530/07 (Article 260 TFEU 
case) 

pending 

15.10.2015 

Failure to comply with Article 4 of UWWT Directive (52 
agglomerations between 2000 and 10000 population 
equivalent) 

This is the Court's judgment in a case the Commission 
brought against Greece for failure to comply with the Court's 
ruling in Case C-440/06 (Article 260 TFEU case). The Court 
declared that Greece failed to implement the judgment and 
imposed a penalty payment of EUR 3 640 000 per semester 
from the day of the judgment until full compliance is 
achieved. The Court also imposed a EUR 2 million lump-sum 
penalty payment on Greece. 

This  is  the  Court's  judgment  in  a  case  the  Commission 
brought  against  Belgium  for  failure  to  comply  with  the 
UWWT  Directive  in  relation  to  57  agglomerations  with  a 
population  equivalent  of  more  than  2,000  and  less  than 
10,000.  The  Commission  abandoned  in  part  its  claim  for 
some agglomerations in light of the information provided by 
Belgium. The Court decided that Belgium failed to ensure the 

C-395/13 
Commission v 
Belgium 

6.11.2014 

1 The case number refers to the number attributed to the case when registered by the Court of Justice of the 
European Union. 

10 

 
 
                                                            
C-85/13 Commission 
v Italy 

10.04.2014 

C-576/11 
Commission v 
Luxembourg 

28.11.2013 

C-23/13 Commission 
v France 

7.11.2013 

C-533/11 
Commission v 
Belgium 

17.10.2013 

collection  and  treatment  of  urban  waste  waters  in  15 
agglomerations  and  failed  to  ensure  proper  treatment  in 
additional  33  agglomerations.  The  Court  also  clarified  that 
Member  States  are  required  under  Annex  I.D  to  ensure  12 
samples  over  the  course  of  the  first  year  of  operation  of  a 
facility to demonstrate compliance. 

This  is  the  Court's  judgment  in  a  case  the  Commission 
brought  against  Italy  for  failure  to  comply  with  the  UWWT 
Directive.  Italy  did  not  contest  this.  The  Court  decided  that 
Italy  failed  to  ensure  that  all  waste  waters  are  collected  and 
treated  according  to  the  applicable  requirements  in  41 
agglomerations. 

(non-compliance 

This  is  the  Court's  judgment  in  a  case  the  Commission 
brought  against  Luxembourg  for  failure  to  implement  the 
judgment  in  case  C-452/05  (Article  260  TFEU  case).  The 
Court  declared  that  Luxembourg  failed  to  implement  the 
in  6 
judgment 
agglomerations  out  of  12  that  were  subject  to  the  first 
judgment) and that it is justified to impose a penalty payment 
of EUR 2800 per day from the day of the judgment until full 
compliance  is  achieved.  The  Court  also  considered  that  a 
lump  sum  is  necessary  given  the  excessive  duration  of  the 
infringement (7 years) and imposed a EUR 2 million penalty. 

regarding 

treatment 

This  is  the  Court's  judgment  in  a  case  the  Commission 
brought against France for failure to comply with the UWWT 
Directive. France did not contest this. The Court decided that 
France failed to ensure that all waste waters are collected in 
one  agglomeration  and  that  all  waste  water  is  treated 
according 
five 
to 
agglomerations. 

requirements 

applicable 

the 

in 

This  is  the  Court's  judgment  in  a  case  the  Commission 
brought  against  Belgium  for  failure  to  implement  the 
judgment  in  case  C-27/03  (Article  260  TFEU  case).  The 
Court  declared  that  BE  failed  to  implement  the  judgment 
(non-compliance 
for  7 
regarding  collection 
agglomerations  and  treatment  in  21  agglomerations)  in 
relation  to  five  agglomerations  and  that  it  is  justified  to 
impose  a  penalty  payment  of  EUR 4,722  per  day  to  be 
calculated for six month periods, i.e. EUR 859,404 for every 
six  month-period  since  this  judgment.  The  Court  also 
considered  that  a  lump  sum  is  necessary  as  a  deterrent 
measure and imposed a EUR 10,000,000 penalty.  

systems 

C-517/11 
Commission v 

07.02.2013 

This  is  the  Court's  ruling  in  a  case  the  Commission  brought 
against  Greece  for  failure  to  take  comply  with  the  Habitats 

11 

 
 
Greece 

Directive  (92/43/EEC)  and  UWWT  Directive.  The  Court 
ruled that Greece failed to comply with the Habitats Directive 
as  it  had  not  taken  the  required  steps  to  avoid  the 
deterioration and pollution of Lake Koroneia. The Court also 
ruled,  as  acknowledged  by  Greece,  that  it  failed  to  comply 
with  the  UWWT  Directive  Articles  3  and  4  by  not  ensuring 
collection  and 
in  Langadas 
treatment  of  waste  water 
agglomeration. 

2.2- Main infringement cases 2013-2014 

Infringement Cases 

CASES RELATED TO LARGE TOWNS/CITIES (above 10,000 or 15,000 population equivalents)

Case number2 

Member State 

Court Ruling and related date (if applicable) 

1999/2030 

BE 

08/07/2004 (C-27/03) 

17/10/2013 (C-533/11) (Art 260) 

2002/2123 

ES 

Pending (no referral to the Court yet) 

2002/2125  

LU 

2002/2128 

2002/2130  

2004/2030  

2004/2031 

2004/2032 

2004/2035 

2004/2034  

2009/2034 

PT 

SE 

EL 

ES 

FR 

PT 

IT 

IT 

23/11/2006 (C-452/05) 

28/11/2013 (C-576/11) (Art 260) 

8/09/2011 (C-220/10) 

06/10/2009 (C-438/07) 

25/10/2007 (C-440/06) 

(Pending Art 260 - C-167/14)  

14/04/2011 (C-343/10) 

07/11/2013 (C-23/13)  

07/05/2009 (C-530/07) 

19/07/2012 (C-565/10) 

10/04/2014 (C-85/13) 

2 The case number refers to the reference number attributed by the European Commission to each infringement 
case. 

12 

 
 
 
                                                            
CASES RELATED TO SMALL AND LARGE AGGLOMERATIONS  

Case number3 

Member 
State 

Court Ruling and related date (if applicable) 

6/11/2014 (C-395/13) 

Pending before the Court (Case C-314/15) 

Pending before the Court (Case C-398/14) 

Pending (no referral to the Court yet) 

Pending before the Court (Case C-320/15) Referral to the Court 

Pending (no referral to the Court yet) 

Pending (no referral to the Court yet) 

Pending before the Court (Case C-304/15) Referral to the Court 

Pending (no referral to the Court yet) 

2009/2304 

2009/2306 

2009/2309 

2009/2310 

2011/2027 

2012/2100 

2013/2056 

2013/2055 

2014/2059 

BE 

FR 

PT 

SE 

EL 

ES 

IE 

UK 

IT 

3 - Distance to compliance 

3.1 - Introduction 

This  report  includes  for  the  first  time  a  new  concept,  "distance  to  compliance",  with  the 
objective  to  have  a  broader  view  on  the  situation  in  the  Member  States  on  collection  and 
adequate  treatment  of  the  generated  waste  water  load.  This  new  concept  does,  in  no  way, 
replace the formal assessment of the compliance with the requirements of Articles 3, 4 and 5 
of the Directive. It is meant to present the rate of waste water load that is:  

•  adequately  connected  to  a  centralised  urban  waste  water  collecting  system  (or 

• 

addressed via Individual or other Appropriate System – IAS) and then: 
treated at an adequate level (secondary or more stringent treatment) as required by the 
Directive, 

•  and with the performance requirements under tables 1 or 2 of the Annex I of Directive 

91/271/EEC (UWWTD). 

In  this  document,  all  EU  MS  have  been  considered  except  PL,  due  to  the  provision  of 
insufficient and poor quality data under the current reporting exercise, and HR, still without 
compliance  obligations  by  2012.    IT  was  partially  included  (information  from  two  regions 
was missing).  

3 The case number refers to the reference number attributed by the European Commission to each infringement 
case. 

13 

 
 
 
 
 
                                                            
Example of the difference between "compliance" and "distance to compliance" 
If in an agglomeration above 10,000 p.e. that discharges in a sensitive area for N and P, 10% 
of the load is neither connected to a collecting system nor addressed via IAS, but 90% of the 
load is connected to a collecting system and treated in a plant which applies a compliant more 
stringent treatment, this agglomeration will be considered as non-compliant under Articles 3, 
4 and 5, and the compliance rates will be 0%/0%/0%. 
If  the  "distance  to  compliance"  assessment  is  applied,  100%  of  the  connected  waste  water 
load  is  adequately  treated,  and  10%  of  the  waste  water  would  need  to  be  connected  or 
addressed via IAS to comply with the requirements of Article 3 of the Directive. 
Consequently,  the  "distance  to  compliance"  regarding  collection  or  treatment  through  IAS 
would be equal to 10% and "distance to compliance" concerning wastewater load connected 
as regards secondary and more stringent treatment would be equal to 0%. 

In the following sections, different sets of rates are compared and presented:  
- Comparison between "compliance" and "installations in place in which performance is met" 
at country level shows that the first concept is much more stringent than the second one and 
that  large  differences  between  both  values  (low  compliance  rate  versus  higher  good 
performance rate in the generated load) may be found. 
- Comparison between "non-compliance" (as the complementary rate of the "compliance"), 
and "distance to compliance" shows that large differences in their respective values are 
frequently found (the "distance to compliance" rate is usually much lower). This indicates 
that both concepts, which are addressed to measure the lack of implementation of the 
UWWTD, are conceptually different and that solely measuring "non-compliance" will give a 
stricter and more severe outlook on a Member State's implementation of the UWWTD. 

3.2 - Expired deadlines of the UWWTD  

This chapter concerns only the urban waste water that falls under specific deadlines already 
expired at the reference year (2011 or 2012). 

3.2.1 - Connection to collecting systems and treatment through IAS 

Differently from the (formal) Article 3 "compliance assessment", this calculation takes into 
account  all  the  urban  waste  water  that  is  adequately  connected  to  a  collecting  system  or 
addressed via IAS regardless of the proportion of waste water not collected/treated at all. 

14 

 
 
 
The results of this assessment, made for 26 Member States, show that a very small percentage 
(0.3%) of the total generated load is neither connected to collecting systems nor addressed via 
IAS. 

Only SI and BG show a "distance to compliance" above 2%, which in any case is far below 
the "non-compliance" rates:  

•  14.9%  in  Bulgaria  (88.4%  official  rate  of  non-compliance  under  Article  3,  i.e. 

compliance rate of 11.6%). 

•  6.1%  in  Slovenia  (43%  official  rate  of  non-compliance  under  Article  3,  i.e. 

compliance rate of 57%). 

3.2.2  -  Waste  water  connected,  secondary  treatment  in  place  and  performance 
requirements met 

This calculation only looks at the connected waste water, which should meet the requirement 
of  a  secondary  treatment  (treatment  level  and  performance).  Thus,  for  this  calculation  the 
waste water not connected or addressed via IAS is not considered. 

This assessment shows a more positive result than the related compliance assessment mainly 
due to the fact that in the latter a failure concerning Article 3 automatically entails a failure 
under  Article  4.  This  situation  is  particularly  relevant  in  SI,  BG  and  RO.  There  is  also  a 
similar situation in the agglomerations with several treatment plants in which only one plant 
does  not  meet  the  requirements  of  Article  4.  As regards "distance to  compliance",  only  the 
load  that  is  connected  but  not  adequately  treated  as  required  under  Article  4  is  taken  into 
account. 

15 

 
 
 
 
The  "distance  to  compliance"  at  EU  level  in  relation  to  the  secondary  treatment  level 
represents only about 1.8% of the total connected load. As regards treatment performance it 
represents about 6.9% of the total connected load.  

The difference in results between both concepts is particularly high in BG, CY, SI and RO. 

Member State 

Slovenia 

Bulgaria 

Romania 

Cyprus 

Distance to compliance 

Secondary treatment 
performance not correct 

(Rate of the total load 
connected) 

Non-compliance under  
Article 4 

(Percentage) 

16.3% 

21.7% 

23.3% 

26.4% 

85.9% 

88.8% 

52.5% 

41.2% 

16 

 
 
 
 
 
 
 
 
In MT, the "distance to compliance" as regards treatment in place is 0%, but the compliance 
assessment shows 100% "non-compliance" rate under Article 4. An explanation for this may 
be the following: all treatment plants in MT are relatively new and they should theoretically 
be  in  line  with  the  requirement  of  the  Directive  but,  due  to  an  excess  of  farm  manure 
discharges into the collecting system, the performance requirements are not met. A reduction 
in such discharges might solve the problem. 

Why performance results do not always respond to the requirements of the treatment in 
place? 

If  the  performance  results  are  below  the  treatment  in  place  requirements,  there  might  be 
several explanations: 

•  The waste water load or the volume entering the treatment plant is above its capacity 
and, as a result, performance is not good. This is the case of Malta. In other cases, the 
plant  may  be  obsolete  and  should  be  renewed  to  be  able  to  treat  correctly  the 
generated waste water. 

•  The treatment plant was  new by  the reported year and  worked well, but not enough 
samples  were  considered  (Annex  I.  D.3  of  the  UWWTD)  and  the  performance 
requirements were not met. 

•  Other  situations  not  falling  in  the  above  categories,  such  as  bad  operation  of  the 

treatment plant. 

3.2.3  -  Waste  water  connected,  more  stringent  treatment  in  place  and  performance 
requirements met 

This  calculation  only  looks  at  the  waste  water  connected  that  should  meet  more  stringent 
treatment requirements and performance results4.  

This assessment shows a more positive result than the compliance assessment mainly due to 
the fact that in the latter a failure concerning Article 3 automatically entails a failure under 
Articles 4 and 5. There is also a similar situation in the agglomerations with several treatment 
plants in which only one does not meet the requirements of Article 5. As regards "distance to 
compliance",  only  the  load  that  is  connected  but  not  adequately  treated  as  required  under 
Article 5 is taken into account.  

The "distance to compliance" as regards more stringent treatment in place represents 7.9% of 
the total connected load. As regards the performance requirements, it represents 8.3% of the 
total connected load. 

4For this calculation the waste water not connected or addressed through IAS is not considered. 

17 

 
 
 
                                                            
The  difference  between  compliance  with  Article  5  and  "distance  to  compliance"  is 
particularly  high  for  IT,  LU,  ES,  SK,  SI,  RO,  LV  and  BG.  For  MT,  the  explanation  is  the 
same as for the previous point. 

Member State 

Italy 

Luxembourg 

Slovenia 

Spain 

Slovakia 

Slovenia 

Romania 

Latvia 

Bulgaria 

Distance to compliance 

More stringent treatment 
performance not correct 

(Rate of the total load 
connected) 

Non-compliance under Article 
5 

(Percentage) 

8.1% 

22.4% 

24.7% 

28.1% 

32.8% 

46,1% 

61.5% 

64.3% 

77.5% 

66.3% 

58% 

66.1% 

62% 

56.7% 

66.1% 

84.5% 

100% 

99.3% 

18 

 
 
 
 
 
Why in occasions the performance results are "right" but more stringent treatment 
requirements are not met? 

This is the case of Slovakia, Romania and Latvia.  It is not an usual situation, which might be 
explained as follows:  

•  Bad  reporting  of  the  installation  in  place.  MS  have  declared  only  a  secondary 

treatment, but in fact there is more stringent treatment in place. 

•  High dilution of the incoming load. The concentration performance corresponding to 
a more stringent treatment could be met by applying only a secondary treatment. 

Whilst the first situation may simply be a reporting mistake, the second one, of more concern, 
could  mean  the  presence  of  a  huge  amount  of  clear  water  in  the  collecting  systems,  which 
might lead to discharges before entering the treatment plant, if the urban waste water system 
does not have enough capacity. 

3.3 - Varying deadlines of the UWWTD 

Most of the deadlines to meet different obligations set out by the UWWTD have expired.  

Nevertheless,  some  deadlines  have  not  yet  expired  for  some  of  the  countries  that  became 
members of the EU in or after 20045:  

•  Cyprus:  31 December 2012, concerning agglomerations of 15,000 p.e. and below, 
•  Bulgaria: 31 December 2014, concerning agglomerations of 10,000 p.e. and below, 
•  Latvia,  Hungary,  Slovakia  and  Slovenia:  31  December  2015  concerning 

agglomerations of 10,000 p.e. and below, 

•  Romania:  three  pending  deadlines,  31  December  2013,  2015  and  2018,  concerning 

various aspect of Articles 3, 4 and 5. 

RO  and  CY  are  the  only  MS  that  had  non-expired  deadlines  related  to  more  stringent 
treatment by the year reported upon.  

In RO, by end of 2012, 61% of the urban waste water load must be collected or addressed via 
IAS (Article 3), 51% of the urban waste water load must be treated by secondary treatment 
(Article  4)  and  51%  of  the  waste  water  load  must  be  treated  by  more  stringent  treatment 
(Article  5).  The  entire  waste  water  load  connected  and  adequately  treated  was  taken  into 
account for the assessment of the "distance to compliance" for those expired deadlines. Given 
that  the  targets  set  in  those  expired  deadlines  have  not  yet  been  achieved,  the  distance  to 
compliance related to targets set in the pending deadlines will necessarily be equal to 100% 
for collection, treatments and performance. Due to this situation and the weight of RO in the 
group  of  EU13  countries,  the  average  distance  to  compliance  for  the  various  Articles 
regarding EU13 is large, as can be seen in the graphs presented in the paragraphs below. 

5 Croatia not considered 

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Some EU15 MS like FR, UK and IT designated late certain areas as sensitive for the purpose 
of article 5 and the transitional periods of some of those sensitive areas have not expired yet. 

3.3.1 - Connection to collecting systems and treatment through IAS 

In  LV,  HU  and  SK,  more  than  98%  of  the  urban  waste  water  load  is  already  correctly 
collected or addressed via IAS. It can therefore be expected that the deadine for Article 3 for 
those countries will be respected. 

The objective is further away for SI, BG, CY and RO. 

3.3.2 - Waste water connected, secondary treatment in place and performance met 

In LV, SK and HU, more than 80% of the urban waste water load is already correctly treated 
in a way that the performance requirements under Article 4 of the Directive are met. 

The objective is further away for SI, CY, BG and RO. 

In  CY,  it  seems  that  secondary  treatment  is in  place,  but  performance  requirements  are  not 
yet met. 

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3.3.3 - Waste water connected, more stringent treatment in place and performance met 

FR,  UK  and  IT  have  still  pending  deadlines  as  regards  some  sensitive  areas  for  Article  5. 
Among  these  MS,  UK  is  the  country  that  is  the  furthest  away  from  the  implementation 
objective:  its  sensitive  areas  under  transitional  period  in  2012  were,  by  then,  still  far  from 
compliant with Article 5. 

As  explained  above,  there  are  only  two  MS  among  the  EU-13  in  which  the  "distance  to 
compliance"  concerning  more  stringent  treatment  (implementation  and  performance)  is 
applicable: CY and RO. 

In CY, already 100% of connected waste water receives more stringent treatment and meets 
the performance requirements. In RO, as explained under point 3.3, "distance to compliance" 
is still at 100%. 

3.4 - Conclusions 

Most  of  the  EU-MS  have  correctly  reported  information  under  Article  15,  even  in  cases  in 
which it was not officially required (pending deadlines).  Applying the concept of "distance 
to compliance" on this very large dataset shows in general a more positive picture than the 
result of the compliance assessment under the directive. In practical terms, this means that 
most of the MS are on good track to correctly implement the UWWTD. 

The most relevant conclusions that can be drawn are the following: 

Obligations  for  which  the  deadlines  have  already  expired  concern  26  MS  and  a  total 
generated  load  of  546  million  p.e..  To  fully  comply  with  the  Directive,  the  following 
additional effort is required:  

•  To  collect  and  treat,  or  address  via  IAS,  about  2  million  p.e.,  which  represents 

about 0.3% of the total urban waste water generated load. 

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•  For the urban waste water load already collected, to apply secondary treatment on 
about 10 million p.e. (1.8% of the total collected load) and to correctly operate about 
36  million  p.e.  (6.9%  of  the  total  collected  load)  in  order  to  reach  the  performance 
requirements under Article 4. 

•  For the urban waste water load already collected, to apply more stringent treatment 
on  about  24  million  p.e.  (8.3%  of  the  total  collected  load)  and  to  correctly  operate 
about  25  million  p.e.  (9.4%  of  the  total  collected  load)  to  reach  the  performance 
requirements under Article 5. 

Obligations that will have to be met when pending deadlines expire concern 10 MS and will 
require the following additional effort: 

• 

to collect and treat, or address via IAS, about 9 million p.e. which represents about 
72% of the total urban waste water  generated load. 

•  For the urban waste water load already collected to apply secondary treatment on 
about 11 million p.e. (85% of the total collected load) and to correctly operate about 
11.5 million p.e. (88% of the total collected load), in order to reach the performance 
requirements under Article 4. 

•  For the urban waste water load already collected, to apply more stringent treatment 
on about 13.5 million p.e. (40% of the total collected load) and to correctly operate 
about  14  million  p.e.  (6.4%  of  the  total  collected  load)  to  reach  the  performance 
requirements under Article 5. 

Caution 
As regards expired and pending deadline, the load not collected or addressed via IAS is not taken into 
account in the "distance to compliance" treatment targets. There are two reasons for that: 

•  There is no information about the future destination of this load (connection or IAS). At this 
stage, it is not possible to consider that it has to be treated in an urban waste water collective 
treatment plant. 

•  The information given is not sufficient to know if the treatment plant in place is already able 
to welcome this supplementary load. If it is adequately designed the work to do is to connect 
the buildings to a collecting system which could already exist or has to be created and not to 
create new treatment capacity. 

As a result of these two uncertainties, an unknown part of the 2 million p.e. for expired deadlines and 
9 million p.e. for pending deadlines will have to be added in the "distance to compliant" secondary 
and more stringent treatment objectives. 

Most of the works that have to be completed by MS to comply with the Directive are covered 
by  the  reports  submitted  by  MS  under  Article  17  of  the  Directive.  According  to  the 
information provided in those reports, full compliance with the Directive requires additional 
investments of about 22 billion EUR. 

4 - Summary of assessment of Article 17 Report 

The table below provides more detail information on what is described in chapter 3.2 of the 
8th Urban Waste Water Treatment implementation report.

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