COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Directive of the European Parliament and of the Council on the quality of water intended for human consumption (recast)
Date: 2018-02-01
Institutions: Directorate-General for Environment, European Commission
Subjects: consumer protection, drinking water, human nutrition, public health, quality standard, water management, water pollution, water protection, water supply

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 1.2.2018  SWD(2017) 449 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council  on the quality of water intended for human consumption (recast) {COM(2017) 753 final} - {SWD(2017) 448 final} - {SWD(2017) 451 final}  
 
 
Table of Contents 

1. 

1.1. 

2. 

2.1. 

Introduction .................................................................................................................. 3 

Context ......................................................................................................................... 3 

What is the problem and why is it a problem? ............................................................. 4 

Specific problems related to the current DWD identified in the Evaluation ............... 5 

2.1.1.  Regulatory failure - Outdated parameters .................................................................... 5 

2.1.2.  Regulatory failure - Outdated approach ....................................................................... 6 

2.1.3.  Obstacle to internal market - Materials and products in contact with drinking water . 7 

2.1.4. 

Information failure ....................................................................................................... 7 

2.2. 

2.3. 

3. 

3.1. 

3.2. 

4. 

4.1. 

4.2. 

5. 

5.0. 

Part of the population has no access to drinking water- problem identified in the ECI9 

Ranking of the problems ............................................................................................ 10 

Why should the EU Act ............................................................................................. 11 

Right to act ................................................................................................................. 11 

Subsidiarity ................................................................................................................ 11 

What should be achieved ........................................................................................... 13 

General policy objective ............................................................................................ 13 

Specific objectives ..................................................................................................... 13 

What are the various options to achieve the objectives ............................................. 13 

Baseline scenario – How would the problem evolve? ............................................... 14 

5.0.1.  Baseline assumptions ................................................................................................. 14 

5.0.2.  Expected baseline impacts on health.......................................................................... 15 

5.0.3.  Expected baseline impacts on affordability of drinking water for EU citizens ......... 16 

5.1. 

5.2. 

5.3. 

5.4. 

5.5. 

5.6. 

Set of options to achieve Objective 1: Updating the list of parameters ..................... 18 

Set of options to achieve Objective 2: Simplifying the approach .............................. 18 

Option to achieve Objective 3: Removing obstacles to the internal market .............. 19 

Set of options to achieve Objective 4: Ensuring transparency and information to the 
consumer .................................................................................................................... 20 

Set of options to achieve Objective 5: Improving access to drinking water .............. 21 

Synopsis sets of options ............................................................................................. 22 

5.6.1.  Options not further pursued ....................................................................................... 24 

6. 

6.1. 

Analysis of impacts .................................................................................................... 25 

Health Impacts ........................................................................................................... 25 

6.1.1.  Acute Health risks ...................................................................................................... 25 

6.1.2.  Chronic health risks ................................................................................................... 26 

6.1.3.  Associated health benefits in monetary terms ............................................................ 27 

1 

 
 
 
6.2. 

Economic Impacts ...................................................................................................... 27 

6.2.1.  Economic situation/baseline....................................................................................... 27 

6.2.2.  Comparison of economic impacts of each option ...................................................... 28 

6.2.3. 

Impacts on SMEs and on innovation ......................................................................... 28 

6.2.4.  Macro-economic impacts ........................................................................................... 30 

6.2.5. 

Impact on employment ............................................................................................... 30 

6.3. 

Social Impacts ............................................................................................................ 31 

6.3.1.  Affordability and social inclusion .............................................................................. 32 

6.4. 

Environmental impacts .............................................................................................. 33 

6.4.1.  Water Pollution .......................................................................................................... 33 

6.4.2.  Resource efficiency .................................................................................................... 34 

6.4.3.  Energy ........................................................................................................................ 35 

6.4.4.  Bottled water .............................................................................................................. 35 

6.5. 

7. 

7.1. 

7.2. 

Administrative Burden Reduction Impacts ................................................................ 36 

Comparison of options ............................................................................................... 37 

Health Protection versus Costs .................................................................................. 37 

Ranking overall .......................................................................................................... 38 

7.3.  Who will be affected? ................................................................................................ 40 

7.4. 

Presentation of possible policy packages ................................................................... 40 

8. 

9. 

9.1. 

9.2. 

9.3. 

9.4  

9.5.  

9.6. 

Monitoring and evaluation ......................................................................................... 47 

Annexes ...................................................................................................................... 49 

Annex 1  Procedural information concerning the process to prepare the Impact 
Assessment report and related amendment ................................................................ 50 

Annex 2  Synopsis report on the stakeholder consultation ........................................ 54 

Annex 3  Who will be affected by the preferred policy packages and how? ............. 68 

Annex 4   Development of the analytical model for the assessment of the options, 
underlying assumptions of the options and impacts assessed through application .... 79 

Annex 5  Monitoring ................................................................................................ 128 

Annex 6  Glossary .................................................................................................... 132 

2 

 
 
 
 
 
INTRODUCTION  

1. 
The revision of the Drinking Water Directive (DWD)1 is included in the Regulatory Fitness 
and  Performance  Programme  (REFIT).  The  preceding  REFIT  evaluation2  contributed  to 
identifying  the  strengths  and  weaknesses  of  the  Directive.  This  Impact  Assessment  report 
builds on the evaluation results. It analyses several options aimed at updating and simplifying 
the  Directive  in  order  to  ensure  that  its  objectives  can  be  reached  in  a  more  effective  and 
efficient  way.  Furthermore,  the  revision  is  also  one  of  the  follow-up  actions  to  the  first 
successful European Citizens' Initiative Right2Water.3 

1.1. 

Context 

Safe  drinking  water  is  essential  for  public  health  and  well-being.  Defects  in  quality  and 
quantity cause high social and economic costs. The DWD is the main piece of EU legislation 
in this regard. The DWD regulates the quality of water intended for human consumption. Its 
overall objective is to protect human health by ensuring that drinking water at the consumer 
tap is wholesome and clean. Drinking water in the EU stems from around 11 000 large water 
supplies4  and  85  000  small  supplies  serving  around  80  %  and  20  %  of  the  population, 
respectively. 

EU legislation on drinking water has existed for about four decades.5 The original Directive6 
was replaced in 1998 by the current DWD. The DWD provides a general framework and sets 
concrete  minimum  quality  standards  in  the  form  of  maximum  parametric  values.  The 
Directive lists a total of 48 parameters that must be monitored regularly. If the standards are 
exceeded (non-compliance), remedial measures are required. The selection of those is left to 
the  Member  States'  discretion.  The  DWD  also  requires  that  Member  States  ensure  the 
provision of appropriate information to consumers.  

While  the  DWD  regulates  water  quality  at  the  consumer's  tap,  the  EU  Water  Framework 
Directive  (WFD)7  regulates  the  abstraction  of  drinking  water  and  the  protection  of  water 
bodies  intended  for  this  purpose.  Article  7  of  the  WFD  requires  Member  States  to  identify 
bodies of water for the abstraction of drinking water and to protect them, so that the treatment 
regime will result in drinking water which meets the DWD requirements. 

1 
consumption,  

Council  Directive  98/83/EC  of  3  November  1998  on  the  quality  of  water  intended  for  human 

2 
of  

3  
4 

5 

6 

7 

OJ L 330, 5.12.1998, p. 32. 
The Commission published on 1 December 2016 a Staff Working Document on the REFIT Evaluation 

the Drinking Water Directive 98/83/EC, SWD(2016) 428 final. 
http://ec.europa.eu/citizens-initiative/public/initiatives/successful/details/2012/000003 
A water supply is an area of uniform water defined for monitoring purposes, often corresponding to one  
supplier. Small water supplies are those supplying less than 1 000 cubic meters per day or serving less 
than 5 000 people. Very small supplies with less than 10 cubic meters per day or serving less than 50 
people are exempted from the Directive. 
COUNCIL DIRECTIVE 75/440/EEC concerning the quality required of surface water intended for the  
abstraction of drinking water in the Member States (repealed by the Water Framework Directive.). 
Council Directive 80/778/EEC of 15 July 1980 relating to the quality of water intended for human con- 
sumption, OJ L 229, 30.8.1980, p. 11–29. 
Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a 
framework for Community action in the field of water policy (OJ L 327, 22.12.2000, p. 1). 

3 

 
 
 
                                                 
2. 

WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM? 

The EU has already achieved significant results through its efforts to ensure the provision of 
high  drinking  water  quality.  Before  the  changes  to  the  DWD  introduced  in  1998,  drinking 
water  compliance  with  the  majority  of  the  parametric  values  was  just  over  90 %.  In  1998, 
compliance rates rose on average to around 95 %8, but varied between Member States. Recent 
data shows that compliance continued to increase, from 97 % in 2005 to over 99 % for most 
parameters,  and  compliance  became  more  homogenous  across  the  EU.  The  latest 
Implementation  report9  based  on  around  30  million  analyses  shows  sustained  high 
compliance. 

The  reporting  results  and  the  REFIT  Evaluation  confirmed  that  the  Directive  is  well 
implemented  in  the  Member  States,  and  is  generally  achieving  its  objective  of  protecting 
human  health  from  the  adverse  effects  of  contamination.  The  evaluation  and  the  results  of 
stakeholder consultations confirmed that the DWD is a relevant tool to ensure that the quality 
of  the  water  consumed  in  the  EU  is  good,  and  that  it  fulfils  its  basic  purpose  to  enable  the 
enforcement of drinking water monitoring and the restoration of quality to the required level 
in the event of non-compliance. However, the evaluation was subject to several limitations10, 
most  importantly  that,  although  the  compliance  rates  are  high,  it  is  difficult  to  establish 
whether  the  existing  parameters  adequately  reflect  all  possible  (including  emerging)  health 
risks.  Stakeholders  also  argued  that  it  is  difficult  to  quantify  the  impact  of  the  DWD  on 
drinking  water  quality  in  comparison  with  other  influences  that  might  have  led  to 
improvements in drinking water quality. 

The  evaluation  concluded  that  the  following  four  areas  leave  room  for  improvement  and 
represent  weaknesses  of  the  current  DWD11:  (1)  the  list  of  drinking  water  parameters  and 
values has not been revised in the past 19 years, and could be partly not relevant anymore and 
not  fully  take  account  of  changed  or  emerging  pressures  according  to  the  latest  scientific 
knowledge,  (2)  risk-based  elements  are  not  sufficiently  considered  in  the  DWD,  (3) 
provisions related to materials in contact with drinking water constitute a burden and lead to 
non-recognition  of  such  materials  on  the  internal  market,  and  (4)  the  availability  of 
information to consumers is uneven, sometimes inadequate and insufficiently transparent. 

The results of the public consultation12, and of targeted stakeholder consultations13, confirmed 
the  finding  that,  despite  the  generally  good  outcomes  of  the  DWD  implementation,  some 
aspects of the Directive are in clear need of improvement. 

The  four  areas  of  improvement  outlined  above  represent  the  main  problems  to  be  tackled. 
Additionally, the ECI  'Right2Water'  identified  as a distinct problem the fact that part of the 

8 
9 

10 
11 

12 

13 

Triannual reports prepared since 1993-1995, data electronically available since 2005 until 2013. 
Report COM(2016) 666 final of 20 October 2016, 
http://ec.europa.eu/environment/water/water-drink/reporting_en.html 
For details see chapter 4.2 of the Evaluation SWD, see Footnote 2. 
For  detailed  information  please  refer  to  the  evaluation  SWD  (see  Footnote  3  above  of  this  Impact 
Assessment). 
Public  consultation  organised  in  response  to  the  European  Citizens'  Initiative  (ECI)  'Right2Water 
'http://ec.europa.eu/citizens-initiative/public/initiatives/successful/details/2012/000003 
See details in Annex 2 

4 

 
 
 
                                                 
population  has  no  access  to  drinking  water14.  Since  the  adoption  of  UN  Agenda  2030,  this 
problem is subject to EU Member States' obligation to implement Sustainable Development 
Goal (SDG) 6.15 Figure 1 depicts how these areas of improvement or problems are related to 
underlying drivers and what consequences they entail. 

Figure 1: Drivers, problems and consequences 

2.1. 

Specific problems related to the current DWD identified in the Evaluation 

2.1.1.  Regulatory failure - Outdated parameters 

The  list  of  parameters  and  values  has  not  been  revised  in  the  past  19  years.  The  evaluation 
found, correspondingly, that although compliance with the existing parametric values is high, 

14  
15 

The Directive does not regulate access to drinking water. 
Communication COM(2016) 739 final, Next steps for a sustainable European future - European action 
for sustainability {SWD(2016) 390 final} 

5 

 
 
 
 
                                                 
some are not relevant anymore16, and they do not fully take account of changed or emerging 
pressures  according  to  the  latest  scientific  knowledge.17,  18  The  results  of  stakeholder 
consultations  confirm  that  there  is  general  agreement  among  Member  States  and  industry 
experts that the parameter list is insufficient. This could mean that health risks are higher than 
currently accounted for. 

2.1.2.  Regulatory failure - Outdated approach  

The DWD method to regularly monitor water quality at the consumer's tap is not optimal as it 
is not comprehensive enough. This was underlined by some stakeholders, who raised the issue 
of  risks  to  health  from,  e.g.  legionella,  which  are  currently  not  monitored.  The  DWD  does 
neither require systematic preventive safety planning nor systematic risk assessments. Instead, 
the  current  DWD  requires  monitoring  at  regular  intervals  independent  of  the  level  of  risk. 
Such  an  approach  is  outdated.  Although  the  practice  on  the  ground  may  in  many,  or  the 
majority  of  the  cases,  be  adequate,  emerging  risks  might  bypass  the  matrix  of  the  current 
parameter list which constitutes a too uniform and generic monitoring approach. Furthermore, 
current  requirements  do  not  address  the  microbiologically-related  challenges,  such  as 
legionella and somatic coliphages. Under these circumstances an EU level playing field is not 
ensured. The current approach also does not promote cost-effective source control measures, 
even though the prevention of water pollution at source generally has a very high cost-benefit 
ratio  in  comparison  to  water  treatment.19  Therefore,  the  current  approach  has  led  to  more 
treatment  than  needed,  leading  in  turn  to  higher  costs  for  consumers.  Moreover, the  current 
fixed monitoring approach is burdensome and was therefore not always properly applied. 

An  alternative  method  for  monitoring  called  the  "risk-based  approach"  (RBA)  is  already 
implemented  to  a  certain  extent in  a  few  Member  States  such  as  Hungary,  the  Netherlands, 
and the UK. As the water supply sector is rather conservative and the RBA still considered a 
new  concept,  it  has  not  been  taken  up  as  much  as  one  would  expect  given  its  expected 
benefits. Prior to the revision of Annexes II and III of the DWD in 2015, the application of the 
RBA was under the current end-of-pipe approach of the DWD only possible to a very small 
extent  in  EU  Member  States.  Now  the  RBA  can  be  taken  up  by  Member  States  in  their 
legislation on a voluntary basis since 201520 and meetings with Member States showed that 
overall the RBA has been very positively received and the majority will take up this voluntary 
approach in their transposition of the Annexes. However, even with this revision of Annexes 
II  and  III,  the  RBA  remains  restricted  to  the  monitoring  Annexes  and  hence  is  not  fully 
integrated into the Directive, limiting its potential. 

16 
17  

18 

19 
20  

i.e. Benzene, Benzo(a)pyrene, 1,2-dichloroethane, Polycyclic aromatic hydrocarbons PAHs; 
i.e. Legionella, chlorate, chlorite, endocrine disrupting chemicals, per- and polyfluoroalkyl substances 
like PFOA and PFOS. 
See  also  for  Agricultural  Pressures:  SWD(2017)  153  final  on  Agriculture  and  Sustainable  Water 
Management in the EU; Pressures from emerging substances: Roadmap for the Commission's initiative 
on  a  strategic  approach  to  pharmaceuticals  in  the  environment:  http://ec.europa.eu/info/law/better-
regulation/initiatives/ares-2017-2210630_en; 
See evaluation SWD, Footnote 3, page 30; 
In  2015  the  revised  Annexes  were  introduced,  containing  the  monitoring  frequencies  and  analytical 
methods. 

6 

 
 
 
                                                 
2.1.3.  Obstacle to internal market - Materials and products in contact with drinking water 
A  third  problem  identified  and  often  raised  by  various  stakeholders21  concerns  materials  in 
contact  with  drinking  water.  Inappropriate  materials  can  contaminate  drinking  water.  An 
obstacle to the internal market arises from the non-recognition of national product approvals 
between  different  Member  States causing  high  administrative  burden. The  evaluation  of  the 
DWD concluded that Article 10, which imposes that 
Member States take all necessary measures to ensure 
that  materials  in  contact  with  drinking  water  do  not 
reduce  the  protection  of  human  health,  does  not 
work  well.  The  provision  represents  a  problem  of 
legal  uncertainty  as  interpretations  diverge  between 
Member States and provide too much flexibility, and 
therefore  constitutes  a  long-term  challenge  to  the 
provision of clean and healthy drinking water in the 
EU. 

One  international  manufacturer  with  a 
strong presence in Europe selling products 
in  contact  with  drinking  water  in  47 
countries  has  to  deal  with  more  than 
national  1300 approvals and  more than 40 
quality  marks,  and  has  to  spend  annually 
between  EUR  1.8  and  3.6  million  to  keep 
the  approval  process  alive, 
including 
double  and  tripling  tests  because  of  cross-
border  non-acceptance  of  existing  test 
results and certificates, additional costs and 
delayed market introductions. 

Many  materials  in  contact  with  drinking  water  are 
construction  products  that  can  be  harmonised  under 
internal  market  legislation,  in  particular  under  the 
Construction  Products  Regulation22  (CPR),  but 
standardisation efforts have so far been unsuccessful 
due to the complexity of the materials and products, 
unclear mandates and low priority attached to developing them.23 

This  example  is  representative  for  all 
manufacturers  in  the  EU  and  therefore 
gives  a  good  indication  of  the  (cross-
border) dimension of the problem.  

Box: Product Approval 

Most  affected  by  this  are  the  manufacturers  of  such  materials.  As  demonstrated  in  the 
representative  example  on  product  approval  for  manufacturers,  the  costs  incurred  by 
businesses through the inefficiency of Article 10 lead to clear obstacles for manufacturers in 
the internal market. More evidence is provided by a specific study.24 

2.1.4. 

Information failure 

21 

22 
down  

23  

24 

74 % of respondents of the public consultation identified the need for a harmonized regulation of the  
materials in contact with drinking waters (the highest score); 
Regulation (EU) No 305/2011 of the European Parliament and of the Council of 9 March 2011 laying 

harmonised  conditions  for  the  marketing  of  construction  products  and  repealing  Council  Directive 
89/106/EEC (OJ L 88, 4.4.2011, p. 5); 
Due to the link to the CPR, and the circumstance that product standardisation already started under the 
CPR, the implementation of this objective under the CPR is assumed. As the materials impact drinking 
water quality, this Impact Assessment was found to be the better place to analyse them rather than in the 
CPR REFIT. Moreover, an assessment of the current situation is needed due to stakeholder pressure and 
the intent to replace the non-functioning Article 10 with more concrete provisions; 
Study report – Product and Materials in contact with Drinking Water:  
https://circabc.europa.eu/w/browse/0b93e708-5e20-4c35-8fbd-8554a87e7cb5. 

7 

 
 
 
                                                 
 
 
 
A fourth problem identified in the evaluation of the DWD is the very heterogeneous level of 
(mostly  passive)  information  made  available  to  consumers.  The  open  public  consultation 
showed that only 58 % of the EU citizens feel that they are well informed on issues relating to 
drinking water. This is mainly due to the vague and passive DWD wording, which provides 
that 'Member States shall take the measures necessary to ensure that adequate and up-to-date 
information  […]  is  available…'  This  has  led  to  significantly  different  information  practices 
among Member States and also among water suppliers. This lack of information can lead to 
consumers turning away from tap water. 

is  acceptable  at  EU 

The  confidence  in  tap  water  is  rather  low: 
only  19  %  of  the  respondents  to  the  public 
consultation25  agreed  that  the  quality  of  tap 
water 
level.  Many 
consumers  do  not  trust  tap  water  and  rely 
partly  or  exclusively  on  more  expensive 
bottled  water.  To  be  able 
to  make  an 
assessment  of  the  options  that  are  suggested 
to  address  this  low  confidence,  this  Impact 
Assessment uses the purchase of bottled water 
in the EU as a simplified indicator to estimate 
the  level  of  non-confidence26.  The  2015 
average is 106 l of bottled water/ capita/ year, 
up to 170 to 180 l/ capita/ year in some Member States including Germany, Italy and Malta. 

Preferring  bottled  over  tap  water  has  many 
underlying  reasons,  among  others  this  preference 
can  be  explained  by  cultural  habits,  convenience, 
access  as  well  as  clever  and  attractive  marketing 
promoting the purchase of bottled water. Although 
tap water is highly regulated to ensure its quality, 
many  consumers  fear  pollution  (63  %  of  the 
Americans 
recent  Gallup  study)  and 
consequently  choose  bottled  water  instead  of  tap 
water  as  argued  by  Business  Insider  (2017)  "16 
facts  that  show  why  bottled  water  is  one  of  the 
biggest scams of the century". 

Box: Consumers' choice for bottled water and 
the link to confidence in tap water 

in  a 

Poor knowledge about tap water contributes to the low confidence shown by citizens, and to 
their  failing  to  participate  more  actively  in  water  management  decisions,  as  well  as  to 
scrutinize the efficiency and quality of supply services as well as water and energy savings. 
The evaluation also found that the current reporting provisions providing outdated compliant 
values are of no avail and do not tap the potential of modern information technology and data 
management  for  swift  und  multiple  use  of  information.  Providing  adequate  information  to 
consumers is an issue also identified as important by the European Court of the Auditors.27 

2.1.4.1 Lack of awareness of leakages 

25 

26  

27  

See Figure 12 of the Consultation Report: 
https://circabc.europa.eu/sd/a/0070b535-5a6c-4ee4-84ba-
6f6eb1682556/Public%20Consultation%20Report.pdf, the confidence in water quality is higher where 
the consumers live (73%). 
This is a proxy which has some limitations as bottled water consumption is also related to other reasons 
than the absence of confidence in the drinking water, such as personal preferences. 
Special  report  of  the  European  Court  of  Auditors  SR  12/2017:  "Implementing  the  Drinking  Water 
Directive: water quality and access to it improved in Bulgaria, Hungary and Romania, but investment 
needs remains substantial". 

8 

 
 
 
                                                 
 
for  a  general  underinvestment 

Another issue identified that is outside the scope of 
evaluation  by  the  Commission  was  that  the  public 
lacks awareness of water leakages that can lead, to a 
certain  extent,  to  health  problems28  but  are  mainly 
indicators 
in 
maintenance  and  renewal  of  the  drinking  water 
infrastructure29,  30. This underlying driver of lack of 
investment  can  be  strongly  seen  in  the  elevated 
leakage  rate  of  treated  water  during  its  distribution: 
23 % of treated water is lost in public water supplies 
in  Member  States31,  with  large  differences  between 
Member States.32, 33 

settlement  close 

In  Herford,  Germany  (64  000  citizens)  in 
Summer  2015:  Caused  by  two  pipe  bursts 
following  a 
to  an 
aerator/exhauster surface water could enter 
into the drinking water pipes during heavy 
rain  events.  It  took  several  weeks  to  find 
the  cause  and  to  solve  the  problem.  In 
addition  further  disinfection  plants  were 
installed. 

Box: Health problems caused by 
leakages 

2.2. 

Part  of  the  population  has  no  access  to  drinking  water  -  problem  identified  in 
the ECI 

The  current  DWD  does  not  include  any  provision  on  access  to  water  or  an  obligation  to 
supply  drinking  water  to  every  citizen.  The  ECI  'Right2Water'  supported  by  more  than  1.8 
million  signatories,  invited  the  Commission  inter  alia  "to  propose  legislation  implementing 
the human right to water and sanitation, and promoting the provision of water […] for all" to 
ensure that all inhabitants enjoy the right to water. The Commission replied officially to the 
European Citizens’ Initiative ‘Right2Water’ via a Communication34 recalling the principle of 
neutrality  in  relation  to  national  decisions  governing  the  ownership  regime  for  water 

28  

29 

30 
31 
32 
33  
of  

34  

can 

pipes 

(2015),  Leaky 

http://apps.who.int/iris/bitstream/10665/44584/1/9789241548151_eng.pdf 

The  WHO  points  out,  that  leakages  often  arise  when  water  pressure  is  low,  which  is  also  a  moment 
when hazardous substances or microbes can enter the pipes, making leakages a health issue: "A non-
revenue  water  programme  would  address  issues  such  as  intermittent  supply  and  low  water  pressure, 
both of which are contributing factors to contamination of drinking-water in the distribution system." 
(Source: 
; 
http://apps.who.int/iris/bitstream/10665/181592/1/Effective-approaches-drinking-water-quality-
surveillance-Oslo-report.pdf).  This  is  also  supported  by  other  (new)  scientific  findings.  University  of 
Sheffield 
drinking  water: 
https://www.sheffield.ac.uk/news/nr/leaky-water-pipes-contaminants-drinking-water-1.470248 
LeChevallier  et  al.  (2003)  The  potential  for  health  risks  from  intrusion  of  contaminants  into  the 
distribution  system  from  pressure  transients:  http://jwh.iwaponline.com/content/1/1/3  Teunis  et  al. 
(2010).  Enteric  Virus  Infection  Risk  from  Intrusion  of  Sewage  into  a  Drinking  Water  Distribution 
Network: http://pubs.acs.org/doi/abs/10.1021/es101266k; 
"High quality of urban water services in OECD countries is threatened by a massive investment backlog 
impending  the  upgrading,  renewal  and  maintenance  of  water-related  infrastructure."  (This  includes 
urban waste water and floods), OECD (2016), Water Governance in Cities; 
EU Commission Guidance Document on Leakage Management, (2015,), p. 5; 
Eurostat, 2015, referred to in the Impact Assessment Study adding up to 6.5 billion m3; 
Based on Eurostat, 2015, details per Member State see Annex 5 Table 7; 
Additionally, from a resource efficiency point of view, high levels of leakage are unacceptable in times 

contaminants 

allow 

into 

our 

climate  change  and  water  scarcity.  The  annually  lost  6.5  billion  m3  at  EU  level  amount  to  the 
consumption demand of entire Member States such as France and Germany together (Annex 5,  Table 
10); 
An underlying driver of this problem, namely the need for 'substantial' investments in the field of water 
supply has been highlighted in the Special Report of the European Court of the Auditors SR 12/2017. 
Particularly when EU funds are mobilised water losses are considered an issue. 
COM(2014)177 final. 

9 

 
 
 
                                                 
undertakings.  Whilst  the  Union  cannot  regulate  this  system  of  ownership  nor  the  means 
chosen  by  Member  States  for  the  provision  of  drinking  water  services,  the  Commission 
invited "the Member States, acting within their competences, to take account of the concerns 
raised by citizens through this initiative and encourages them to step up their own efforts to 
guarantee the provision of safe, clean and affordable drinking water and sanitation to all." (p. 
13).  The  human  right  to  water  corresponds  to  SDG  6  in  the  UN  Agenda  2030,  which  also 
concerns the availability of water and sanitation for all. Furthermore, lack of access to water is 
also  a  problem  from  a  health  perspective.  It  is in  this  general  context  that  this  problem  and 
possible options will be assessed in this Impact Assessment. This additional issue was not in 
the scope of the evaluation of the Directive.  

estimates 

"Does  the  human  right  to  water  help  the  poor  and  people 
that are not connected to a system? 

We are arguing for more public spending to extend water and 
sanitation  services  to  the  poor.  The  human  right  to  water 
obliges governments to ensure that everybody has (clean, safe, 
affordable, accessible) water and sanitation. That is contrary to 
a market-based approach that demands that people pay first for 
access to the service. You cannot ask the poor to pay upfront 
for connection to a water system. Putting the human right first 
helps the poor, a market for water doesn’t."  

In  the  ECI  it  is  argued  that  there 
are  "still  around  2  million  people 
in Europe that do not have proper 
access  to  water  or  sanitation"35. 
Based on Eurostat data this Impact 
that 
Assessment 
currently  23  million  people  or 
4.5 %  of  the  total  EU  population 
are not connected to Public Water 
Supply  (PWS)  systems  for  a 
variety  of  reasons:  on  the  one 
hand  many 
or 
dwellings, 
sporadically 
secondary residences and holiday homes are not connected because there is no need. On the 
other hand homeless people, Roma and nomadic communities often have no possibility to be 
connected  to  the  system.  Consequently,  it  can  be  said  that  the  underlying  drivers  of  this 
problem  are  diverse,  ranging  from  no  need,  over  the  remoteness  of  some  areas  to  social 
exclusion and poverty. Connection rates to PWS systems in Member States range from 57 % 
(Romania) to 100 % (Belgium, the Netherlands). 

(ECI Right2Water: http://water.tttp.eu/node/45/) 

Box: ECI Right2Water 

temporarily 

used 

The  continuous  support  to  the  topic  was  visible  in  the  open  public  consultation  for  which 
supporters  of  legislation  implementing  the  right  to  safe  water  and  sanitation,  among  others, 
submitted  186  times  the  same  text  to  the  survey  and  provided  41  position  papers  with  the 
same text to substantiate their position. 

2.3. 

Ranking of the problems 

In  terms  of  the  Directive's  main  objective  of  health  protection  the  outdated  parameter  list 
combined with the outdated end-of-pipe approach to monitoring are certainly the most urgent 
problems.  These  two  issues  are  closely  interlinked  and  need  to  be  viewed  together  when 

35  

Water is a human right: http://water.tttp.eu/node/45/.  
According  to  the  World  Water  Assessment  Programme  (WWAP)  referred  to  in  the  European 
Parliament's Resolution in reply to the ECI, in the EU28 more than 1 million people still lack access to 
a  safe  and  clean  drinking  water  supply.  (European  Parliament  Report  in  the  follow-up  to  the  ECI 
'Right2Water', Sept 2015, Resolution Nr 17 (2014/2239(INI)).  

10 

 
 
 
                                                 
thinking  about  solutions.  Key  is  the  anticipation  of  emerging  issues  such  as  new  types  of 
pollutants (e.g. pesticides, pharmaceuticals) that are more and more frequently found in raw 
water sources used for the production of drinking water. The other identified problems – lack 
of transparency and lack of information, lack of harmonisation of the materials in contact with 
drinking  water,  limited  access to  drinking water for some  parts  of the population  – have  an 
important  but  more  indirect  impact  on  citizens'  health.  These  issues  are  however  crucial  in 
terms of efficient governance and cost effectiveness of the sector, especially from a long-term 
and resource efficient perspective. 

3. 

WHY SHOULD THE EU ACT 

3.1. 

Right to act 

The proposed legislation is not a new intervention. It is based on Article 192(1) TFEU. This 
provision  was  the  legal  basis  of  the  current  DWD,  and  will  serve  as  a  legal  basis  for  the 
revised measure. The EU has shared competence with Member States to regulate environment 
and  health  in  the  field  of  water.  This  means  that  the  EU  can  only  legislate  as  far  as  the 
Treaties allow it, and with due consideration for the principles of necessity, subsidiarity and 
proportionality.36 

3.2. 

Subsidiarity 

The  current  DWD  was  designed  in  accordance  with  the  principle  of  subsidiarity,  and 
recognised  the  natural  and  socio-economic  differences  between  the  regions  of  the  EU.  The 
Directive  sets  EU  minimum  standards  and  the  legal  frame,  but  leaving  most  decisions  on 
monitoring, analysis and remedial measures to be taken at a local, regional or national level. 
Concrete  actions  (remedial  actions,  actual  monitoring  programmes,  etc.)  are  left  to  the 
Member States. 

Concerning  more  specifically  aspects  related  to  access  to  water,  the  revision  was  originally 
triggered  by  the  ECI  'Right2Water',  supported  by  more  than  1.8  million  signatories.  In  its 
reply  to  the  initiative,  the  Commission  underlined  the  importance  of  the  human  rights 
dimension  of  access  to  safe  drinking  water,  whilst  respecting  as  outlined  above  the 
subsidiarity  principle  and  the  EU's  neutrality  in  regard  to  national,  regional  and local  levels 
concerning  provision  of  water  services37.  Action  at  EU  level  was  also  demanded  by  the 
European Parliament in its response to the initiative.38 Moreover, the EU's commitment to the 

36  
37  

38  

Consolidated Version of the Treaty on the European Union [2008] OJ C115/13, Art 5 (3) and (4); 
As  stated  in  the  Commission's  Communication  on  the  topic:  "…the  decision  on  how  best  to  operate 
water services is firmly in the hands of the public authorities in the Member States. The provision of 
water  services  is generally the  responsibility  of  local  authorities,  which are  the  closest  to  the  citizens 
and  their  concerns  …  The  Commission  is  committed  to  ensuring  that  the  human  rights  dimension  of 
access  to  safe  drinking  water  and  sanitation,  which  must  be  of  high  quality  available,  physically 
accessible, and affordable, will continue to guide its future action". COM(2014)177 final.  
Para. 10: "Calls on the Commission, in line with the primary objective of the Right2Water ECI, to come 
forward  with  legislative  proposals,  and,  if  appropriate,  a  revision  of  the  WFD,  that  would  recognise 
universal  access  and  the  human  right  to  water;  advocates,  moreover,  that  universal  access  to  safe 
drinking  water  and  sanitation  be  recognised  in  the  Charter  of  Fundamental  Rights  of  the  European 
Union" (European Parliament resolution of 8 Sept. 2015 on the follow-up of the ECI 'Right2Water'); 

11 

 
 
 
                                                 
UN  Sustainable  Development  Goals  (SDGs)39  requires  the  Commission  to  consider  new 
approaches  to  drinking  water.  However,  any  considerations  on  access  to  water  will  have  to 
respect the Treaty principles of subsidiarity and neutrality, according to which the Treaties in 
no way prejudice Member States' rules governing the system of property ownership of water 
undertakings,  and  other  legislations  in  this  regard  such  as  the  Concessions  Directive40  and 
Services  Directive41,  which  excludes  the  application  of  the  cross-border  freedom  to  provide 
services  for  water  distribution  and  supply.  In  addition,  the  provision  of  water  services  is 
generally the responsibility of local authorities, which are the closest to the citizens and their 
concerns.42 

With water catchment areas43 and groundwater reservoirs being cross-boundary, an EU-wide 
approach  is  utterly  important  to  ensure  that  all  EU  citizens  benefit  from  the  same  level  of 
health  protection.  Also,  the  REFIT  evaluation  confirmed  the  added  value  of  the  drinking 
water legislation at EU level, achieving significant harmonisation of water quality over time 
across  Europe.  In  stakeholder  consultations  on  the  evaluation  and  the  quality  of  drinking 
water, Member States and businesses have called upon the EU to set and maintain up-to-date 
EU-wide common drinking water quality standards. Most Member States, particularly smaller 
ones that do not always have the resources and specific expertise, expect the EU to continue 
to  set  the  essential  chemical  and  microbiological  parameters  and  values.  Moreover,  many 
stakeholders see EU measures as best placed to address emerging health hazards from water. 
Establishing EU harmonised approaches for materials and products in contact with drinking 
water  can  contribute  to  improving  the  functioning  of  the  internal  market,  whereas  national 
approaches currently create obstacles to the internal market. Finally, the lack of transparency 
on  prices  and  leakage  affecting  consumers  is  also  to  be  addressed  at  EU  level,  to  ensure  a 
similar level of protection of consumers across the Union.  

In light of the above, it is clear that the objectives of the DWD and of the different options 
considered  in  this  Impact  Assessment,  namely  protection  of  human  health  and  of  the 
environment, removal of obstacles to the internal market, improving and promoting access to 
water  and  sustainable  management  of  water  distribution,  cannot  be  sufficiently  achieved  by 
Member States on their own, but can rather, because of the scale of the actions to be taken, be 
better achieved at Union level. There is, therefore, a clear demand and justification for action 
at EU level. 

39  
40  

41  

42  

43  

The Sustainable Development Goals, European Commission (2017); 
Directive 2014/23/EU of the European Parliament and of the Council of 26 February 2014 on the award 
of concession contracts; 
Directive 2006/123/EC of the European Parliament and of the Council of 12 December 2006 on 
services in the internal market; 
Public  authorities  are  entirely  free  to  perform  the  relevant  tasks  directly,  by  their  own  means,  or  to 
confer  them  on  legally  distinct,  completely  public,  "in-house"  entities.  They  may  also  decide  to 
outsource water services, partially or entirely, to private or mixed management. When doing so, public 
authorities  are  fully entitled  to  establish  clear  obligations for private  operators to  ensure  that services 
provided within their geographic area of competence  meet prescribed standards. The EU, for its part, 
takes care that key Treaty principles − such as transparency and equal treatment − are observed. At the 
same  time,  Treaty  rules  require  it  to  remain  neutral  in  relation  to  national  decisions  governing  the 
ownership regime for water undertakings (Commission Communication on Right2Water, March 2014); 
For instance: Danube, Rhine, Elbe, Maas etc. 

12 

 
 
 
                                                 
4. 

WHAT SHOULD BE ACHIEVED   

4.1. 

General policy objective 

The  general  objective  of  the  revised  initiative  is  to  contribute  in  the  most  effective  and 
efficient way to the protection of human health from the adverse effects of any contamination 
of water intended for human consumption by ensuring the continued high quality of drinking 
water in the long term in a cost effective way. The aim is also to modernise and simplify the 
current legislation - where this is feasible and without impairing the overall objective of the 
protection of health - and to move from an 'end of pipe' to a more preventive and integrated 
approach. By also using the possibilities offered by new technologies, the initiative also aims 
to  lower  the  administrative  burden  for  small  supplies  and  to  increase  transparency  for  EU 
citizens. 

4.2. 

Specific objectives 

Five  specific  objectives  were  defined  in  response  to  the  problems  identified  in  section  2, 
taking  into  account  the  need  to  meet  the  principal  health  objective  and  to  avoid  excessive 
costs and excessive impacts on affordability (Annex 4). 

1.  Update the parameter list in line with technical and scientific progress; 
2.  Simplify  the  approach  and  target  the  focus  of  monitoring  and  treatment  to  those 

contaminants that present health risks; 

3.  Remove  obstacles  to  the  internal  market  in  relation  to  materials  and  products  in 

contact with drinking water; 

4.  Increase transparency on water related topics that can be of interest  to the consumer 
and increase the availability of, and improve the access to, up-to-date information on 
drinking water; 

5.  Improve the access to drinking water. 

5. 

WHAT ARE THE VARIOUS OPTIONS TO ACHIEVE THE OBJECTIVES 

This  section  screens  the  possible  options  for  meeting  the  objectives  outlined  above.  The 
choice of possible options has been done through an iterative process. At the very beginning 
of the process, two far-reaching options were discussed, namely repealing and discontinuing 
the  DWD,  or  replacing  it  by  a  Drinking  Water  Regulation.  A  regulation  would  have  the 
advantage  that  the  same  parameters  and  values  would  apply  to  all  EU  citizens.  The  repeal 
option  could  refer  to  the  voluntary  but  comprehensive  WHO  Drinking  Water  Guidelines. 
However,  the  evaluation,  further  supported  by  the  2015  comitology  process  to  amend 
Annexes II and III44 of the DWD as a first step towards a risk-based approach, as well as the 
various stakeholder consultations (Annex 2), suggested that these options should be discarded 
upfront.  The  evaluation  firmly  underlined  that  the  DWD  is  a  relevant  legislative  tool  that 
works well. The amended Annexes II and III already pave the way towards a more risk-based 
approach  which  intrinsically  gives  Member  States  and  suppliers  more  flexibility  to  address 

44 

Commission Directive (EU) 2015/1787 of 6 October 2015 amending Annexes II and III to Council  
Directive 98/83/EC on the quality of water intended for human consumption; 

13 

 
 
 
                                                 
risks that matter. This approach is well-suited to an EU Directive, setting the frame for all, but 
leaving specific measures up to the local level. 

A  specific  stakeholder  consultation  on  possible  policy  options  was  held  including  a 
stakeholder conference on 8 December 2015.45 The options considered in this document were 
broadly  supported,  while  other  options,  e.g.  on  a  Safe  Drinking  Water  Label  or  on 
Responsible Service Operators were rejected because judged unrealistic. 

5.0. 

Baseline scenario – How would the problem evolve? 

5.0.1.  Baseline assumptions 

The baseline scenario assumes that the current DWD with its amended annexes will continue 
to be applied. The baseline considers certain changes that will take place in Europe between 
today  and  2050.  The  changes  are  linked  to  climate  change,  general  socio-economic 
developments, the uptake of innovative technologies, or migration linked in particular to war 
or  changes  in  the  political  situations  of  countries  that  are  geographically  or  economically 
connected to the EU. Some of these changes will affect directly or indirectly the functioning 
the 
of 
(Annex 3). 

'drinking  water  system' 

inter  alia  changes 

The main changes that are expected 
in  key  parameters  and  variables 
affecting the drinking water system 
between  now,  2030  and  205046 
in 
concern 
population  and  behaviour,  in  the 
quality  of  raw  water  resources,  in 
emission  of  emerging  substances 
in  an 
by 
increase  of  nitrogen  losses,  in  the 
management  of  drinking  water 
services,  and  in  better  monitoring 
and data management.47  

the  domestic  sector, 

is  yet 

in  consumer  behaviour  regarding 
in  consumer  behaviour  regarding 

Potential  change 
the 
the 
Potential  change 
purchase  of  drinking  water  is  based  on  expert  knowledge. 
purchase  of  drinking  water  is  based  on  expert  knowledge. 
This entails, the effects of the various options can be (slightly) 
This  entails  that,  the  effects  of  the  various  options  can  be 
(slightly)  under-  or  overestimated.  Quality  of  raw  water 
under-  or  overestimated.  Quality  of  raw  water  resources 
resources  depends  on  the  effectiveness  of  other  water 
depends on the effectiveness of other water legislation such as 
legislation such as the WFD, for which the assessment of the 
the  WFD,  for  which  the  assessment  of  the  river  basin 
to  be  conducted.  Emerging 
management  plans 
river  basin  management  plans  is  yet  to  be  conducted. 
Emerging substances in the domestic sector are accounted for, 
substances in the domestic sector are accounted for, but as the 
but  as  the  name  indicates  it  remains  to  be  seen  which 
name indicates it remains to be seen which substances emerge 
substances  emerge  and  how  hazardous  they  are  to  human 
and  how  hazardous  they  are  to  human  health  and  which 
treatments  are  existent  or  to  be  developed  to  tackle  these. 
health and which treatments are existent or to be developed to 
tackle these. Other uncertainties related to the development of 
Other uncertainties related to the development of technologies 
technologies  regarding  monitoring  and  data  management  in 
regarding monitoring and data management in drinking water 
drinking water services. With fast developing technologies in 
services.  With  fast  developing  technologies  in  nearly  all 
sectors,  it  can  only  be  assumed  in  the  model  how  these 
nearly  all  sectors,  it  can  only  be  assumed  in  the  model  how 
account for costs in 2050. 
these account for costs in 2050. 

An  important  assumption  for  the 
baseline  concerns  the  RBA.  This 
assumes  that  changes  in  the  management  of  drinking  water  services  will  take  place 
independently  of  the  implementation  of  the  DWD.  It  is  assumed  that  the  number  of  water 

Box: Inherent uncertainties in the assessment of future 
Box: Inherent uncertainties in the assessment of future 
health and cost implications 
health and cost implications 

45 
46  

47  

Documentation on: https://circabc.europa.eu/w/browse/3fccab4b-812d-46be-8efe-1f866cf556c5; 
The  comparison  of  the  2015  to  2030  and  2050  was  chosen  as  it  is  in  general  helpful  to  have  future 
reference points for the assessment of options. Moreover, an earlier comparison, i.e. five years in the 
future, is not sensible as the drinking water sector is impacted by long-time changes and drivers. For 
instance, changes in demographics (e.g. urbanization) have an effect on the future of the drinking water 
sector. Furthermore, water supplies are planned to last rather centuries than decades. At the same time 
an even later point in time than 2050 would make the assumptions less robust; 
These  main  uncertainties  could  have  some  impacts  on  the  costs  and  benefits  of  the  options  but  these 
uncertainties will not change the main lessons learnt from the analysis in terms of policy packages; 

14 

 
 
 
                                                 
suppliers implementing a RBA will continue to increase, but at an uneven manner across the 
EU. This is triggered by the revision of Annexes II and III of the DWD, and also promoted by 
the WHO and other national and water suppliers’ initiatives. It is expected that in 2050 74 % 
(2015:  47  %)  of  the  EU  population  will  receive  drinking  water  from  suppliers  that  have 
implemented  the  RBA.  Data  and  assumptions  for  the  current  situation  and  the  projections 
until 2050 are listed in Annex 4. 

Another  important  assumption  for  the  baseline  concerns  the  very  slow  development  of  the 
internal  market  for  products  in  contact  with  drinking  water  and  the  stagnation  on 
standardisation work. Due to the sensitive health issue some Member States insist on having 
their  own  high  level  approval  systems,  whereas  many  others  refrain  from  establishing  such 
systems  at all.  Apart  from  a  four-Member  State  initiative,  no  significant  progress  towards  a 
fully-functioning mutual recognition system has been made. 

Therefore, the baseline does not assume that positive developments on mutual recognition via 
product passports or in other sectors will spill over onto these products, but assumes that the 
current status quo in the baseline in 2030 and in 2050 will remain as it is now. 

5.0.2.  Expected baseline impacts on health 

The Evaluation already pointed at the difficulties for establishing direct causal and statistical 
relations  between  drinking  water  quality  and  risks  to  human  health.  This  is  particularly 
difficult  for  emerging  pollutants.  Therefore,  health  issues  in  this  Impact  Assessment  have 
been  addressed  through  a  specifically  developed  indicator  named  ‘Population  Potentially  at 
Health Risk’ (PPHR). 

What is PPHR? 

This indicator serves as an estimate of the share of the population that could potentially suffer 
from  health  problems  because  of  the  presence  of  contaminants  in  drinking  water.48  In 
summary,  five  levels  of  risk  have  been  defined  (no  risk,  marginal,  low,  medium,  high) 
depending  on  the  quality  of  the  water  consumed.  Different  assumptions  have  been  made 
regarding the quality of the water depending on whether the RBA is applied or not, the origin 
of the water (bottled/ tap water), and whether or not there is a connection to the public water 
system. The quality of the water was estimated on the basis of the possible contamination by 
substances  included  in  the  DWD  or  outside  its  current  scope  (emerging  pollutants).  For  the 
baseline and for each option having a health impact, the indicator PPHR was calculated. 

This  calculation  was  then  verified  by  available  data  on  causal  sickness  cases  attributed  to: 
Cryptosporidiosis, Campylobacteriosis, E.coli, Giardosis, Shigellasis, Legionella  - which are 
typically  present  in  unsafe  drinking  water.  This  verification  has  shown  a  good  correlation 
between the PPHR and data on diseases due to unsafe drinking water (Annex 4). 

48  

The PPHR was developed with a consortium of experts to be able to make a reasonable link between 
the different options suggested in this IA and their impact on health and to ensure that these options can 
be  compared  on  their  health  impacts.  The  methodology  used  of  creating  the  proxy  of  the  indicator 
PPHR was discussed with stakeholders who made remarks about the lack of scientific soundness of the 
theoretical indicator but agreed that for the underlying modelling purpose, for which it was developed, 
it is indeed valuable; 

15 

 
 
 
                                                 
Figure 2: Expected trend in the Population Potentially at Health Risk (in relative terms, % of 
the absolute national population, 2015, 2030 and 2050) 

According  to  the  PPHR  indicator,  it  is  estimated  that  in  2015  22.7  million  people  were 
potentially  at  health  risk  due  to  non-safe  drinking  water,  equivalent  to  4  %  of  the  EU 
population.  In  2015  the  societal  cost  of  the  estimated  17  000  cases  of  getting  sick  from 
drinking tap water in Europe was equal to EUR 220 million or EUR 0.43 per EU citizen and 
EUR  9.6  per  person  at  risk  (Annex  4).49  Using  the  PPHR  for  the  baseline  calculation,  the 
number of people potentially at health risk is expected to decrease by 2050, but the number of 
people potentially at risk will remain significant. Overall, 20 million people will potentially 
be  at  health  risk  due  to  drinking  water  quality  problems,  equivalent  to  3.8  %  of  the  EU28 
population  in  2050.  In  absolute  terms,  the  large  majority  of  Member  States  will  see  their 
situation (marginally) improve. The highest potential risk is likely to be observed in, among 
others, Bulgaria, Greece, and Lithuania. 

5.0.3.  Expected baseline impacts on affordability of drinking water for EU citizens  
The evaluation of the DWD has assessed the cost-effectiveness of drinking water policy.50 In 
different Member States there are different approaches on how water is paid for, for instance 
via  tariffs  or  taxes.  In  general  it  is  assumed  in  this  Impact  Assessment  that  water  operators 
transfer  all  costs  to  the  consumer  and  that  only  those  consumers  that  are  connected  to  the 
PWS in each Member State pay for the costs. In 2015, the average annual cost per household 
was  estimated  at  EUR  22951,  which  represents  an  EU  average  of  0.73  %  of  the  disposable 
income.52, 53 Figure 3 shows for each Member State how much of the income of a household 

49 
50 

51  

52 

The societal cost, in the short-run, is ranging between EUR 160 and EUR 239 million. 
Staff Working Document REFIT Evaluation DWD, SWD(2016) 428 final, and evaluation study on:  
https://circabc.europa.eu/w/browse/15386e9d-964e-4274-88ad-5be171c12bd2; 
For the purpose of later assessing the costs of the options and policy packages, the calculated household 
costs  reflect  the  sum  of  total  annual  operating  and  annualised  set-up  costs  divided  by  the  PWS-
connected population (a household constitutes at EU average 2.4 persons based on Eurostat data). It is 
assumed that all costs for drinking water are borne by those citizens that are connected to the PWS in 
the  given  Member  State.  Any  assessment  of  costs  is  based  on  assumptions.  They  do  not  necessarily 
depict the real situation in the individual Member State; 
The disposable income of private households is the balance of primary income (operating surplus/mixed  

16 

 
 
 
 
                                                 
 
is  spent  on  water  services.  This  is  assessed  by  comparing  the  share  of  spending  on  water 
services to average incomes (green bars) and to the incomes of the lowest income group of the 
Member State (violet bars). For instance, in Romania drinking water is assumed to require a 
share of 1.8 % of the disposable income, which is more than twice as high as the EU average. 
Bulgaria, Latvia and Lithuania also experience comparatively high figures with over 1.2 % of 
their  disposable  income  being  spent  on  drinking  water,  whereas  in  Finland,  Malta  and  the 
United  Kingdom  the  figure  is  only  around  0.5  %.  The  impact  on  the  lowest  quintile  of  the 
population is in comparison to the impact on all income groups higher and averages at 1.01 % 
for  the  EU  (Figure  3).  Looking  at  individual  Member  States,  in  2015  for  Romania  the 
spending of disposable income on drinking water is as high as 7.4 % for the lowest income 
group.  In  Bulgaria,  Hungary  and  Lithuania,  the  level  is  above  2.0  %  for  the  lowest  income 
group.  Under  the  baseline  scenario,  the  average  EU  household  spending  is  forecast  to 
decrease to EUR 228 by 2050. 

Figure 3: Affordability of drinking water 

The assessment found that costs to the consumer in the baseline scenario remain stable. The 
cost-effectiveness in achieving the objectives of the current DWD will slightly improve in the 
longer-term  as  a  result  of  the  progressive  application  of  the  RBA.  As  stated in  the problem 
definition,  the  Commission  is  bound  by  the  principle  of  neutrality  when  it  comes  to  water 
pricing. Detailed cost estimations and a cost breakdown can be found in Annex 4. 

The  baseline  scenario  includes  further  an  assessment  of  people  currently  without  access  to 
water  services.  The  EU  average  population  connected  to  a  PWS54  (currently  95.5  %)  is 
expected to increase by 18.5 million people (mainly due to increase in population size). The 
expected average connection rate in 2050 will be 95.9 %. 

income  plus  compensation of  employees  plus  property  income  received  minus  property income  paid) 
and the redistribution of income in cash; 
A poverty line for water has been set at a threshold of 3 % for the lowest three income deciles. (OECD, 
2009, Managing Water for All: an OECD perspective on pricing and financing). 
See problem definition chapter 1.3.2. 

53  

54 

17 

 
 
 
 
                                                                                                                                                         
5.1. 

Set of options to achieve Objective 1: Updating the list of parameters 

The  evaluation  and  the  stakeholder  consultations  identified  the  need  to  amend  the  list  of 
parameters of Annex I in line with latest scientific and technical developments and evidence. 
There  were  in  particular  suggestions  from  the  public  consultation  that  substances  used  in 
consumer products, pharmaceuticals and endocrine disrupting substances should be included. 
For a detailed review, a cooperation project with the WHO Regional Office for Europe was 
launched  in  December  2015  with  the  aim  to  integrate  the  most  recent  scientific  knowledge 
and  to  support  the  revision  of  Annex  I  of  the  DWD.  The  objective  of  the  project  was  to 
provide  policy-relevant,  science-based,  advice  to  inform  the  revision  of  the  parameters  and 
the limit values in the DWD, as the DWD standards should generally be based on the WHO 
Guidelines  (see  Recital  4  of  the  Directive)  that  are  amended  every  two  to  three  years.  The 
project  was  concluded  in  summer  2017.  Table  11,  in  Annex  4,  illustrates  the  results  of  this 
work. For each parameter a fact sheet that justifies the proposed changes is being developed.55  

Three options with different levels of ambition are presented to address this objective. Option 
1.1  is  a  simple  update  of  the  existing  list  of  parameters  on  the  basis  of  the  latest  WHO 
updates. Option 1.2 extends further than option 1.1 the list of parameters, in particular through 
additional  microbiological  reference  parameters,  perfluorinated  compounds  or  endocrine 
disrupting compounds. These additional parameters or stricter requirements under option 1.2 
are based on the precautionary  principle, and may be stricter  than what is  recommended by 
the WHO. This option 1.2 assumes the use of advanced treatment for instance with activated 
carbon adsorption. Option 1.3 reduces the list of parameters (Annex 4). 

5.2. 

Set of options to achieve Objective 2: Simplifying the approach 

As identified in the problem definition, the current DWD method, based on a rigid one-size-
fits-all  monitoring  approach,  is  not  sufficiently  comprehensive  on  the  one  hand,  nor 
sufficiently flexible  on  the  other.  Preventive  safety  planning  and  risk-based  elements  are  so 
far  under-exploited,  leaving  room  for  (new)  hazardous  substances  to  remain  undetected.  A 
new  concept  introduced  in  2004  by  the  World  Health  Organization  (WHO),  the  risk-based 
approach (RBA), would address these issues. The RBA is efficient, both from a health- and a 
cost  perspective.  The  current  approach  in  comparison  to  the  RBA  is  especially  for 
microbiological challenges not sufficient ("too little" and "too late") and the RBA presents an 
opportunity to move from an end-of-pipe approach to a holistic and modern management of 
water  supply.  The  RBA  is  a  comprehensive  approach,  from  abstraction  area  to  distribution. 
These  options  therefore  cover  the  introduction  of  a  mandatory  RBA  which  offers 
opportunities for simplification to concentrate time and resources on risks that matter, on cost-
effective  source  measures,  and  to  avoid  effort  (including  analyses)  on  non-relevant  issues 
without compromising a very high level of health protection.56, 57 Upholding very high levels 

55  

56 

The cooperation with the WHO is of importance as the parameters and threshold values of the existing 
Directive  were  based  on  its  assessment.  Nevertheless,  with  the  EU  following  the  Precautionary 
Principle and for some parameter stricter assessment values (e.g. 1 in 1 million sick cases instead of 1 in 
100 000 cases) the suggested list by the WHO will be thoroughly assessed and adjusted to stricter EU 
standards. The WHO is aware of the EU's stricter approach regarding parameters and will take it into 
account; 
See WHO Publication on the Water Safety Plan/Risk-Based Approach: 

18 

 
 
 
                                                 
 
of health protection will also be ensured through keeping a core list of parameters that always 
need  to  be  monitored.  Nevertheless,  the  overall  reduction  of  the  level  and  frequency  of 
required  analyses  and  the  treatment  can  be  adapted  to  real  risks  identified  by  the  RBA  and 
thereby  reduce  administrative  burden  for  national  authorities  and  save  resources  for  water 
suppliers. 

Under the RBA, Member States and/or water suppliers are required to conduct preventive risk 
assessments,  based  on  minimum  requirements  set  at  EU  level,  encompassing  a  hazard 
assessment of the abstraction area, a supply risk assessment, and also a risk assessment of the 
domestic  distribution  system.  The  RBA  needs  to  be  transposed  and  integrated  in  Member 
States'  national  legislations,  whilst  leaving  some  degree  of  flexibility  on  how  the  RBA  is 
implemented and who is responsible to conduct it. The baseline already considers a voluntary 
take-up of the RBA, which was triggered especially through the amendments of Annex II and 
III  in  2015.  As  noted  above,  this  objective  is  therefore  not  counteracting  a  negative 
development,  but  rather  supporting  and  accelerating  a  positive  one.  Additionally,  these 
options  lead  to  stronger  coherence  with  the  WFD,  which  under  Article  7  requires  the 
protection of water bodies used for drinking water abstraction, in order to ultimately reduce 
the level of purification treatment needed for the production of drinking water.58 

The  difference  to  the  baseline  is  that  the  RBA  is  mandatory  and  provides  for  uniform  risk 
assessment across  all Member States. Option  2.1 entails  a  compulsory  RBA  for large water 
suppliers (LWS). Option 2.2 goes further and entails a compulsory RBA for large and small 
water suppliers (SWS). Option 2.2, however, takes into account that a suitable time frame is 
needed for its implementation for small suppliers. 

5.3. 

Option to achieve Objective 3: Removing obstacles to the internal market 

This foresees replacing the ambiguous Article 10 provisions (see chapter 2.1.3.) by concrete 
provisions  related  to  the  wider  domestic  distribution  risk  assessment.  In  addition,  the 
development  of  product  requirements  and  standards  should  be  launched,  for  instance  under 
the Construction Products Regulation59, to overcome the non-functioning mutual recognition 
and stagnant standardisation work so far in that area. Position papers by business associations 
and industry representatives have shown strong support for harmonization and standardisation 
in this context. In the IA study, an option assuming full mutual recognition ensuring market 
access for such products that are not subject to EU harmonisation was considered. This option 
was  not  taken  over  in  this  Impact  Assessment,  against  the  background  that  (1)  the  baseline 
with Article 10 did not ensure a fully-functioning mutual recognition system and (2) a related 
4 Member States initiative60 to recognise their approval schemes was, despite some technical 

57  
58  

59  

60  

http://www.euro.who.int/en/health-topics/environment-and-health/water-and-sanitation/publications; 
RBA Benefits, https://gsd.spc.int/sopac/docs/MR0714_dwsp%20advocacy.pdf. 
W.  Bracket  et  al.  (2016).  Towards  the  review  of  the  European  Union  Water  Framework  Directive: 
Recommendations  for  more  efficient  assessment  and  management  of  chemical  contamination  in 
European surface water resources. Science of the Total Environment 576, p. 720 – 737, see p. 12; 
Regulation (EU) No 305/2011 of the European Parliament and of the Council of 9 March 2011 laying 
down  harmonised  conditions  for  the  marketing  of  construction  products  and  repealing  Council 
Directive 89/106/EEC; 
4 MS Initiative: https://www.umweltbundesamt.de/en/node/13888. 

19 

 
 
 
                                                                                                                                                         
progress,  not  yet  successful  after  10  years  of  cooperation.  Due  to  the sensitive  health  issue, 
also  simpler  mutual  recognition  options  introducing  product  passports  to  guarantee  that  any 
product lawfully sold in one EU Member State can be sold in another one, even if the product 
does  not  fully  comply  with  the  technical  rules  of  the  other  Member  State,  have  also  been 
discarded as they are not perceived as acceptable by Member States. Consequently, option 3 
entails  the  removal  of  an  obstacle  to  the  internal  market  facilitating  the  development  of 
harmonized  standards  for  products  in  contact  with  drinking  water  outside  the  scope  of 
Drinking Water Directive.  

5.4. 

Set of options to achieve Objective 4: Ensuring transparency and information to 
the consumer 

These options are derived from the results of the open public consultation which showed that 
the overwhelming majority of citizens wishes more up-to-date information on their tap water 
and  that  their  level  of  confidence  in  safety  of  water  supply  is  relatively  low.  In  addition, 
options under this objective aim at raising consumers' awareness and civil society's influence 
to address consumer concerns in the water sector. As consumers pay through their water bills 
for the water supply infrastructure, awareness of leakages and the state of the infrastructure 
can trigger citizens to pressure their water supplier or political parties to take action. Obliging 
water operators to provide information to their consumers on water leakages entails that they 
will have to regularly check their water supply systems and thereby acquire better knowledge 
about  it.  This  is  already  practice  in  some  Member  States  (see  Box)61,  62,  showing  that  an 
approach via information sharing and transparency requirements can be successful. 

Option 4.1 entails simplified automatic electronic reporting, combined with a very substantial 
reduction of the data to be reported, to the Commission. This option identifies simplification 
possibilities,  for  instance  with  the  use  of  on-line  database  (e.g.  Eionet),  which  the 
Commission and the European Environmental Agency (EEA) could consult, in line with the 
REFIT principles, and the results of the Fitness Check of Monitoring and Reporting63. There 
would not be direct reporting to the Commission as Member States would simply need, with 
for instance the help of the EEA, to update their databases. In addition, the actual information 
to  be  included  in  the  dataset  would  be  reduced,  by  limiting  it  to  cases  of  exceedances  of 
parametric values.  

61  

62  

63 

Ofwat  investigating  leakage  failure:  http://www.ofwat.gov.uk/ib-0811-ofwat-investigating-leakage-
failures: "As companies ask their customers to conserve water and use it wisely, customers have a right 
to expect that their water company meets its commitments and obligations. These failures send a poor 
signal about how companies value water".  
State of green, Danish Water Forum: https://stateofgreen.com/files/download/9809:  
"Awareness and understanding of the value of water is very weak in many countries and often the price 
for water does not cover the actual investment and operational costs. Political focus and priority from 
government institutions is required in order to make consumers aware of the value of a stable supply of 
clean and safe tap water". 
European Commission (2017) Monitoring and reporting of environment legislation: 
http://ec.europa.eu/environment/legal/reporting/fc_overview_en.htm 

20 

 
 
 
 
                                                 
In  the  UK  and  in  Denmark  both  governments 
use the relation between consumers' awareness 
and  investment  needs  on  the  side  of  the  water 
operator  to  reduce  water  leakages  in  the 
system.  For  instance,  in  the  UK,  the  national 
regulator  Ofwat  uses  'naming  and  shaming' 
practices  to  pressure  water  suppliers  to  reduce 
leakage  rate.  In  Denmark  heightening  the 
consumer's  awareness  of  leakages  is  used  to 
increase  the  consumers'  acceptance  of  higher 
bills  as  the  revenue  is  used  for  addressing 
infrastructure problems.  

Option  4.2  requires  basic  online  information  on 
water  quality  to  consumers,  and  option  4.3 
advanced  online  (and/or  via  water  invoices) 
access  to  a  wider  range  of  information  for 
example  on  sources  used,  water  quantity,  water 
price, waste water treatment and components of 
water pricing, overall performance of the system 
in terms of efficiency, leakage rates and actions 
taken  to  improve  the  infrastructure,  energy  use, 
or additional advice.64 For both options (4.2 and 
4.3) the size of the water supplier would be taken 
into  account  when  it  comes  to  frequency  and 
level  of  detail  of  information  requirements,  in 
to  avoid  overburdening  small  water 
order 
suppliers.  Both  options  will  also  trigger  the  market  penetration  with  better  digital  solutions 
and  smart  metering  technologies.  Transparency  of  water  prices  contributes  to  the 
implementation of the principle of cost recovery (Article 9 WFD), and considers the right of 
the individual to obtain adequate information (Annex 4). 

Box: Dealing with leakages through 
information provision. 

5.5. 

Set of options to achieve Objective 5: Improving access to drinking water 

The current DWD has no provisions on the obligation of supply or access to water. Choices 
on  those  are  currently  fully  left  to  the  Member  States.  Any  options  to  achieve  Objective  5 
must  respect  the  principle  of  neutrality  and  the  Treaty  as  noted  above.  Options  under 
Objective  5  therefore  suggest  approaches  to  improve  access  to  water,  whilst  leaving  the 
specificities of measures to the Member States. 

The  possibility  to  include  provisions  on  access  to  drinking  water  has  been  explored  in  line 
with the outcome of the ECI 'Right2Water' and the adoption of Agenda 2030, which includes 
Sustainable Development Goal 6.  

To  assess  the  problem  to  the  widest  extent  possible,  this  Impact  Assessment  has  taken  as  a 
starting  point  the  share  of  the  population  not  connected  to  the  PWS  (baseline  4.1  %  or  23 
million  people65).  By  doing  this,  it  may  have  overestimated  the  extent  of  the  problem  to  be 
solved,  but  this  conservative  assumption  allows  a  very  credible  assessment  of  the  maximal 
possible costs at the higher end of probability. No detailed data is available to analyse exactly 
the make-up of non-connected people.  

64 

65  

Further  details  on  the  information  are  included  in  Annex  5,  description  option  4.  Taking  into 
consideration national and regional distinctions, the methodology on pricing, on performance criteria, 
and  on  public  participation  in  decision  making  cannot  be  set  at  EU  level,  but  should  be  up  to  the 
Member States to allow for appropriate solutions close to the consumers and comparisons at national or 
regional level. Also details whether information should be provided on the water bill, and/or together 
with information on sewerage, will be left to Member States; 
There  is  a  difference  between  "people  without  access  to  drinking  water"  (around  2  million  people 
according to the ECI) and "people not connected to public water supplies (PWS)" (estimated around 23 
million). However, people that are part of the second category may have access to drinking water via 
other means (private wells for instance).  

21 

 
 
 
                                                 
On the basis of those conservative assumptions, two options for addressing the lack of access 
to  water  for  parts  of  the  population  are considered  in  this  Impact  Assessment.  Both  options 
aim  to  promote  access  to  drinking  water  and  to  support  Member  States'  commitment  to 
implement the SDGs.   

Option 5.1 envisages full connection of all EU citizens to the PWS systems and to extend the 
PWS everywhere as an EU level obligation. The means used by Member States to implement 
this option would be entirely left to national decision (in-house, public system, public-private 
partnership, procurement, etc.). 

Option 5.2 concerns a set of various measures to improve access to water including, (a) the 
provision  of  access  to  water  to  non-connected  citizens  with  self-supply  systems66  or 
alternative solutions, (b) other appropriate measures to provide access to more specific groups 
such as remote, vulnerable or marginalised groups, (c) promotional measures to encourage the 
use  of  tap  water,  and  (d),  other  measures  to  promote  access  to  water  for  instance  in  public 
places.  This  option  would  consequently  entail  an  obligation  addressed  at  Member  States  to 
provide access to vulnerable and marginalised groups. Given the heterogeneous nature of non-
access issues, it is foreseen that although Member States would have to meet the objective of 
providing  non-connected  citizens  with  solutions,  it  would  be  up  to  them  to  decide  which 
approaches and technologies would be best suited to their national situations. For the purposes 
of this assessment, calculations have been based on the conservative assumption that half of 
the non-connected citizens would be provided with individual solutions. It was not possible, 
in  the  context  of  this  Impact  Assessment,  to  exactly  assess  the  potential  impacts  of  other 
measures because of the lack of data on the causes of non-connection, but also because it is 
not  possible  to  anticipate  all  potential  measures  to  improve  access  to  water  of  the  Member 
States and because the conditions in different areas are too heterogeneous.  

Overall,  the  assumption  underlying  option  5.2  is  considered  as  very  representative  for 
assessing  the  total  potential  cost  of  possible  measures  (specific  measures  targeting  more 
specific groups, such as remote, vulnerable or marginalised group, or promotional measures to 
encourage use of tap water) taken under this heading.  

5.6. 

Synopsis sets of options 

The  different  options  described  in  the  above  Sections  are  summarised  in  Table  1,  already 
indicating some preliminary effects. Following the initial assessment potential options beyond 
the  baseline  were  maintained.  These  are  options  BL  (Baseline),  Option  1.1,  1.2,  2.1,  2.2,  3, 
4.1, 4.2, 4.3, and 5.2. Options 1.3 and 5.1 are discarded from further analyses as discussed in 
the  following  section.  Detailed  descriptions  of  the  assumptions  can  be  found  in  Annex  4. 
Annex 4 also contains tables where all assumptions of these options are listed.  

Option 

Short name 

66  

Self-supply  systems  for  the  provision  of  drinking  water  does  not  refer  to  a  specific  technology  but 
rather  to  "incremental  improvements",  improved  wells,  local  disinfection  plants,  local  distribution 
systems,  filtering  devices,  etc.  that  allow  small  communities  or  households  to  have  drinking  water 
provisions  close  to  their  premises.  This  approach  seems  to  be  generally  a  good  approach  to  achieve 
SDG 6.1 (Olschewski (2016).  

22 

 
 
 
                                                 
BL 

1.1 

1.2 

2.1 

2.2 

3 

4.1  

4.2 

4.3 

5.2 

Baseline 

Updated Parameter List 

Extended Parameter List 

RBA Mandatory for large water suppliers 

RBA Mandatory for large and small water suppliers 

Harmonization of contact materials' standards 

Simplified reporting   

Basic online information to consumers 

SMART information 

Alternative  self-supply  systems  and/or  measures  to  improve  access  to 
water 

Table 1: Numbering and abbreviations of retained options 

Figure 4: Objectives and options 

23 

 
 
 
 
5.6.1.  Options not further pursued 

Under the objective  of protection of human health  and the aim of doing so cost-effectively, 
two options of two different set of options can already at this point be discarded from further 
analysis.  

A short analysis of Option 1.3 of the set of options to achieve the objective of improving the 
current  parameter  list  shows  that  this  option  does  not  comply  with  the  overarching  aim  of 
achieving a high level of protection of human health. Quantitative assessments show that this 
option  only  very  marginally  supports  the  reduction  of  people  at  health  risk  but  far  below 
achievable  rates  in  comparison  to  Options  1.1  and  1.2.  Furthermore,  water  suppliers  and 
Member States strongly opposed a reduction of parameters during stakeholder consultations. 
Consequently, Option 1.3 is discarded from all further analysis.   

Option 5.1 of the set of options with the objective of improving access to water is discarded 
for a variety of reasons: first of all, a compulsory connection for millions of citizens including 
those who do not need nor demand it (e.g. remote secondary residences, remote residencies 
with  own sources) does not  make  sense.  Furthermore, it would be technically impossible to 
connect  all non-connected  parts  of the population to  the PWS because  of the remoteness of 
the area  or other  technical problems  making the connection not  feasible. Alternative locally 
based solutions are more effective than a systematic connection to PWS (see Option 5.2).   

Secondly,  from  an  economic  point  of 
view, and as also stated by the ECI and 
the  Commission's  response  to  it  (see 
Box),  affordability  is  a  very  important 
aspect  when  considering  how 
to 
to  water.  An 
improve 
that 
shows 
analysis 
affordability 
household  costs  would  substantially 
increase in many Member States – with 
some  of  them  being  the  host  to  large 
numbers 
and 
marginalised parts of the population67. 

vulnerable 

access 

of 

"Affordability is also a key element because it relates to 
effective access to water services for all. The EU has no 
role 
in  the  setting  of  water  prices,  which  are 
level.  EU  water-related 
determined  at  national 
environmental  legislation  does,  however,  establish  some 
basic  principles  for  water  pricing  policies  in  the  Member 
States. The Water Framework Directive requires Member 
States to ensure that the price charged to water consumers 
reflects  the  true  costs  of  water  use.  This  encourages  the 
sustainable  use  of  limited  water  resources.  EU  water 
policy is based on the principle that affordability of water 
services is critical. National authorities are competent for 
taking 
safeguarding 
disadvantaged  people  and  tackling  water-poverty  issues 
(e.g.  through  support  for  low-income  households  or 
through the establishment of public service obligations)". 

support  measures 

concrete 

With  an  EU  average  increase  of  the 
household  costs  by  EUR  21.40  per 
year,  Option  5.1  would  be  financially 
particularly  demanding  for  the  lowest 
income  groups.  In  general,  the  assessment  shows  that  in  Member  States  in  which  the  PWS 
connection rate is rather low, the impact on household costs would be substantial (Figure 5). 
For instance, in Romania Option 5.1 would entail an increase in household costs of EUR 94 
per year, and in Lithuania and Latvia an increase of above EUR 66 per household per year. 

Box: Communication from Commission on ECI 
Right2Water, March 2014 

67  

It is estimated that 80 % of all Roma live in Bulgaria, Croatia, the Czech Republic, Greece, Hungary, 
Portugal,  Romania,  Slovakia  and  Spain  (FRA  report  –  Second  European  Union  Minorities  and 
Discrimination Survey, 2016).  

24 

 
 
 
                                                 
 
The  adoption  of  Option  5.1  alone  would  already  mean  that  the  share  of  disposable  income 
spent on drinking water increases from 0.73 % (baseline 2050) to 0.77 % and to 1.06 % for 
the average income groups and for the lowest income groups respectively. 

On the basis of these reasons, Option 5.1 is therefore discarded from further analysis. 

Figure 5: Impact of Option 5.1 on household costs - in percentage change 

6. 

ANALYSIS OF IMPACTS  

This analysis of impacts is based on the methodology for Impact Assessments provided in the 
Commissions'  Toolbox  for  Better  Regulation.  As  a  first  step,  all  the  possible  impacts  have 
been screened68, and several of them have been identified for a more detailed analysis. Table 
13 in Annex 4 presents a synopsis of the impact categories that have been screened along with 
the outcome of this screening process. 

6.1. 

Health Impacts 

6.1.1.  Acute Health risks 

from 

recall, 

(2015) 

the  share  of 

the 
To 
population  that  potentially  suffers 
today 
health 
problems due to non-safe drinking 
water,  according  to  the  PPHR 
methodology,  is  estimated  at  22.7 
million  inhabitants  (or  4  %  of  the 
EU28  population  (Section  5.0.2). 
Considering the baseline scenario, 
the  PPHR  in  2050  is  estimated  at 
20  million  inhabitants  (3.8  %  of 
EU28  population),  thus  the  health 

Figure 6: Difference of the PPHR as comparison to the 
baseline (% in 2050) 

68 

In Particular IA Tools #16-31, see http://ec.europa.eu/smart-regulation/guidelines/toc_tool_en.htm. 

25 

 
 
 
 
                                                 
 
situation with no policy change would improve, but only slightly. 

Figure 6 presents the PPHR under the different options in 2050 in comparison to the baseline. 
It  represents  directly  the  difference  between  each  individual  option  in  percentage  of  the 
baseline  situation.  Furthermore,  it  shows  that  the  highest  reduction  of  health  risks  occurs 
through  option  1.2  'Extended  parameter  list',  which  reduces  the  PPHR  by  73.5 %  to  5.3 
million inhabitants (1 % of EU28 population). 

This can be explained by the high number of substances that would be monitored and treated 
under  this  option,  which  consequently  leads  to  a  significant  improvement  in  drinking  water 
quality. The second most effective option to limit negative health impacts on populations is 
option 4.3, followed by 4.2 and 1.1, with a reduction in the number of inhabitants accessing 
polluted  drinking  water  to  almost  8  million  at  the  EU28  scale  by  2050  as  compared  to  the 
baseline  (reduction  of  39  %  compared  to  the  baseline).  All  other  options  contribute 
significantly less to reducing negative impacts on human health. 

6.1.2.  Chronic health risks 

in 

the  PPHR,  which  considers 

In  addition  to  the  potential  short  or  mid-term 
health risks related to drinking water expressed 
by 
its 
methodology  low,  medium  and  high  levels  of 
risk,  each  option  will  also  influence  some 
possible chronic long-term health effects due to 
changes 
through 
carcinogenic  substances).  The  assessment  of 
these  non-acute  risks  is,  however,  both  hard  to 
measure  and,  if  measurable,  hard  to  causally 
relate  back  to  the  consumption  of  drinking 
water. 

in  water  quality 

(e.g. 

Figure 7: Difference in population facing a 
marginal health risk with baseline in 2050 
(millions of inhabitants (0-line = 131 mn)) 

Nevertheless,  a  variation  of  the  PPHR  data 
allows  approximating  such  chronic  long-term 
health  effects.  The  methodology  allows  identifying  the  population  potentially  facing  not  a 
high, medium and low risk, but just a marginal risk related to drinking water. This population 
is probably not facing health problems in the short or mid-term (e.g. becoming sick), but this 
share  of  the  population  could  suffer  from  chronic  effects  of  drinking  water  that  is  not 
completely safe. 

For  2015  the  population  potentially  facing  a  long-term  health  risk  related  to  drinking  water 
(i.e. the marginal risk indicator) is estimated to be 105 million of the EU inhabitants. In 2050, 
this  population  would  increase  up  to  131  million  inhabitants.  Compared  to  the  baseline 
scenario, Figure 7 shows how the options would impact long-term health effects. 

Comparing the information in Figure 6 with Figure 7 allows seeing that concerning long-term 
health  effects  variations,  options  are  not  ranked  in  the  exact  same  order  as  for  PPHR 

26 

 
 
 
(corresponding  to  short and  mid-term  health  risks).69  However,  the  options  with  the  highest 
reduction  of  health  risks  remain  ranked  in  the  same  order.  Option  1.2  is  still  the  most 
effective.  It  leads  to  the  highest  reduction  of  potential  long-term  health  problems  for  the 
population.  

Option  1.1  would  be  less  effective.  This  can  be  explained  by  the  fact  that  the  extended 
parameter list provides in the long-term a better protection against chronic effects than just an 
updated  list.  Option  4.2  and  option  4.3  rank  significantly  better  than  option  1.1.  Thus, 
appropriate consumer information leads to a more effective reduction of potential long-term 
effects  as  compared  to  their  impacts  on  short-  and  mid-term  risks,  and  also  relatively  to 
options other than 1.2. 

6.1.3.  Associated health benefits in monetary terms 

Based  on  the  2008-2012  average  number  of  illness  cases,  the  actual  number  of  reported 
people  falling  sick  as  a  result  of  contaminated  drinking  water  is  31  500  per  year.  Based  on 
these  figures,  the  hospital  and/  or  general  healthcare  costs  and  the  cost  due  to  loss  of 
production or productivity have been assessed, as well as the impact of the options.  

Option  1.2  (to  recall:  PPHR  reduction  of  15  million  people  at  risk)  will  have  an  annual 
healthcare  benefit  of  EUR  153  million,  making  it  the  option  with  the  highest  benefits, 
followed by Option 4.3 of EUR 92 million, Option 4.2 of EUR 80 million, and Option 1.1 of 
EUR 69 million in 2050. All other options have significantly lower impacts (Annex 4). Due to 
methodological  challenges,  no  monetary  benefits  arising  from  the  reduction  of  chronic 
illnesses are assumed, although they could be considerable. 

6.2. 

Economic Impacts 

6.2.1.  Economic situation/baseline 

The  Evaluation  estimated  the  total  annual  cost  for  supplying  drinking  water  in  the  EU  in 
2015  at  roughly  EUR 46.3  billion  of  which  18 %  (EUR 8.3  billion)  can  be  attributed  to  the 
implementation  of  the  DWD.  The  Impact  Assessment  has  re-calculated  these  total  annual 
costs70 that will increase from EUR 46.3 (2015) over EUR 47.1 (2030) to EUR 47.9 (2050) 
billion (Annex 4).71 The baseline for bottled water consumption assumes a decrease in bottled 
water consumption from 106 litres/ person/ year in 2015 to 100 litres/ person/ year in 205072 
(approximately – 6%). 

In  the  EU  water  supply  sector,  employment  is  relatively  stable.  For  2015  it  has  been 
estimated  that  there  are  413 000  people  working  in  the  water  supply  industry.  Within  the 
baseline scenario the number of people employed by the water supply sector is forecasted to 
slowly  decrease  to  409 000  in  2030  and  404 000  in  2050,  in  line  with  the  forecasted  total 
market  value  of  the  sector.  The  main  reason  for  this  minor  decrease  in  employment  is 

69 

70  
71  
72  

For  a  more  detailed  assessment  at  Member  State 
https://circabc.europa.eu/w/browse/52c9bdf7-9fbb-46da-aefe-1deea6311508 
These figures contain the annual operating and the annualised set-up costs.  
All cost figures also contain employment.  
Based on the current trend of a slow decrease in bottled water consumption - Unesda data, see also IA 
study pp. 37.   

IA  study: 

level,  we 

refer 

the 

to 

27 

 
 
 
                                                 
efficiency  gains.  There  is  a  large  difference  between  the  number  of  employees  per  10 000 
inhabitants in the Member States73 (for example high: Bulgaria, Hungary and Slovakia, low: 
The Netherlands, Germany and Austria). 

6.2.2.  Comparison of economic impacts of each option  

Figure 8: Economic impact on compared to baseline per Option74 

The  economic  impact  assessment  of  each  of  the  options  was  done  by  calculating the  set-up 
cost  (which  were  then  amortized  on  the  expected  life  time  of  each  investment)  and  the 
increase in operating cost at EU28 level (Annex 4). In summary, as shown in Figure 8, Option 
1.2 will lead to the largest increase of annual costs75 of EUR 3.1 billion. Option 3, Options 2.1 
and  2.2  lead  to  some  savings.  The  cost  of  Option  4.1  is  with  EUR 0.2  million  much  lower. 
(For pure set-up cost for each option see Table 2 below).  

6.2.3. 

Impacts on SMEs and on innovation 

It needs to be emphasized that water is not a commercial good, but a natural and regenerative 
resource. Thus all economic users of this source benefit from it.  

The  economic  effects  of  the  options  on  small  and  medium  sized  companies  (SMEs)  on 
innovation and on the sector’s competitiveness have been assessed. As water suppliers have a 
monopoly  position,  they  can  pass  costs  on  to  the  consumers  –  even  if  in  several  Member 
States water regulators are in place to control the water prices, take no market risks  and are 
eventually  overall  economically  not  affected.  The  financial  sources  of  the  water  sector  are 
Taxes, Tariffs, Transfers, the '3Ts' referred to by the OECD76.  

73 
74  

75  
76  

Study on the potential of the EU water industry sector (2010). 
The economic impact includes here annual operating costs and annualised set-up costs and is therefore 
comparable to the indicated baseline figures. 
Annual costs contain operating costs and annualised set-up costs.  
OECD – Managing Water for all, https://www.oecd.org/env/42350563.pdf; 

28 

 
 
 
 
                                                 
The most important economic sectors that depend on the PWS are notably the food industry 
and the tourism sector. The quality of water supplied by public systems can be an important 
feature for these companies. Although no statistics are available on the shares of SMEs in the 
Member States, it can be assumed that SMEs have a greater reliance on public water systems. 
It is assumed that the effects of the options will be similar for all sizes of enterprises. 

In  terms  of  possible  impacts  on  trade,  small  increases  of  imported  testing  equipment, 
appliances for treatment or services stand opposed to important export opportunities for EU 
firms  which  successfully  developed  new  treatment  technologies  for  example  in  membrane 
filtration and disinfection77. 

It  is  expected  that  Option  1.1  and  in  particular  Option  1.2  will  be  innovation-friendly  and 
increase  R&D  expenditures  on  new  water  treatment  technologies  of  facilities  specialised  in 
developing new treatment technologies. This type of research is carried out at EU or global 
level and increases in employment will be small, typically not more than a few hundred jobs. 
However,  for  those  technologies  that  can  be 
successfully applied, the potential for exports to 
other  countries  will  be  important  and  thus 
secondary employment effects can rise to 500 to 
1 000 jobs. 

With  particularly  Options  2  referring  to  source 
protection  and  to  measures  at  the  source,  this 
option  is  unlikely  to  have  a  negative  effect  on 
SMEs  and  other  companies  using  water,  except 
if they are affected by new measures established 
to reduce specific water pollution, or to contract 
consulting  services.  As  the  RBA  demands  more 
effective  management  and  open  potentials  for 
tailoring  treatments  to  local  threats,  Options  2 
are assumed to be innovation-friendly.   

Handling  the  pesticide  metaldehyde  under 
the  risk-based  approach  in  the  UK:  The 
water  operator  Anglian  Water  found 
the 
pesticide  metaldehyde  in  its  treated  drinking 
water  and  failed  to  meet  the  DWD  limit  value 
for  the  indicated  pesticide  threshold.  Treating 
for  metaldehyde  would  have  costed  612.4M, 
entailing  a  21%  increase  in  consumer  bills.  As 
an  alternative  to  treating  the  water,  Anglian 
Water  used  financial  incentives  to  address  the 
cost barriers to farmers to use an alternative to 
metaldehyde.  This 
the 
consumer 16.6M, which is only 3 % of treating 
the water.  

alternative 

costs 

Box: Cost savings through RBA 

Option 3 is expected to have a positive impact on manufacturers of materials in contact with 
drinking  water,  including  their  material  suppliers.  Among  these  manufacturers  are  many 
SMEs, and the whole installation sector is dominated by SMEs. It is assumed that the cost for 
certifications and approvals, which constitute up to 1-2 % of the turnover of companies, will 
be reduced significantly if product approvals are harmonised, and SMEs are expected to have 
somewhat higher benefits.78 Option 3 will have a positive impact on intra-EU trade, as current 
barriers to trade through national approval systems will disappear. Furthermore, Option 3 will 
reduce  barriers  to  innovation  and accelerate access to  markets, as  the slow and complicated 

77  

78 

EPEC 
https://ec.europa.eu/environment/ecoap/sites/ecoap_stayconnected/files/etv-
files/files/documents/EPEC_study/etv_final_report_market_annex1.pdf. 
Aqua Europa, 2015; 

Potential 

Market 

Report: 

29 

 
 
 
                                                 
 
approvals  so  far  discouraged  companies  to  develop  new  products  and  to  approach  new 
markets.79  

Options 4.2 and 4.3 are assumed to be innovation-friendly as new information platforms and 
systems will need to be developed. Both options will also lead to a small positive economic 
impact  for  those  SMEs  involved  in  setting-up  of  new  IT  systems  needed  for  these  options 
(service  companies  involved  in  communication,  web  design,  and  the  development  of  smart 
apps).  In  general,  better  information  will  lead  to  better  functioning  of  the  markets  as 
consumers will make better informed decisions. 

Option  5.2  will  offer  some  small  opportunities  for  SMEs  involved  in  installing  new 
connections,  or  in  developing  self-supply  systems.  Option  5.2  can  be  seen  as  innovation-
friendly as alternative and possibly low-cost water supply systems would be demanded.  

6.2.4.  Macro-economic impacts 
The  value  added  of  the  whole  water  supply  sector  is  0.7  %  of  the  EU28  economy.80  Thus, 
relatively small changes in this sector are not expected to have a significant macro-economic 
impact. Most important would be the macro-economic impacts of Option 1.2, as in 2050 these 
efforts sum up to an additional EUR 3.1 billion or on average EUR 14.90 per household per 
year. A further important impact will be on the industry supplying materials and products in 
contact  with  drinking  water.  It  is  expected  that  through  Option  3  some  Member  States  will 
gain a competitive advantage as their industry complies already with the rules of the system.  

The  bottled  water  industry  may  experience  some  challenges  through the  decrease  in  bottled 
water  consumption,  incited  by  Option  4.3  and  5.2.  Moreover,  the  European  Federation  of 
Bottled Water (EFBW) highlighted always that bottled water is supplementary to tap water, 
and not in competition.  

One  aspect,  which  is  easily  overlooked,  is  that  knowledge  on  water  safety  planning  under 
Option  2  can  be  exported  to  third  countries.  This  will  mainly  be  beneficial  for  companies 
active in advisory/ implementation work and directed not only to underdeveloped, but also to 
more developed countries that already have a high level of drinking water quality. 

6.2.5. 

Impact on employment81 

79  

80 
81 

This  option  was  also  strongly  supported  by  various  industries  that  pressed  in  general  for  a 
harmonisation of the market, i.e. "PlasticsEurope recommends that Article 10 of the DWD empowers 
the Commission to enact binding provisions on the safety of materials in contact with drinking water. 
These legally binding measures would have the effect to ensure that all European citizens benefit from 
the same level of human health protection. Also, they would progressively lead to the development of a 
EU-wide harmonized list of substances allowed in the production of materials and products in contact 
with drinking water." (PlasticsEurope via Feedback mechanism); 
Eurostat, 2012. 
Ecorys  (2016),  based  on  Eurostat  (2010)  Note  that  the  employment  impact  has  been  calculated  as 
impact on water providers, although they should be seen as employment effects in the sum of all sectors 
as  an  increase  in  total  cost  for  water  will  increase  the  employment  for  all  sectors  active  in  the  water 
supply industry. 

30 

 
 
 
                                                 
the  effects  of 

Each  option  will  impact  employment  in  the 
water  sector  to  a  different  extent.  Figure  9 
shows 
the  options  on 
employment, compared to the 2050 baseline. 
The employment impacts displayed in Figure 
9  show  that  mainly  option  1.2  will  boost 
employment.  The  figures  differ  strongly  per 
Member  State.  Each  option  will  impact 
employment in the water sector to a different 
extent.  The  figures  differ  strongly  per 
Member  State.  Options  that  incite  a  move 
from bottled water consumption to tap water 
are  heavily  based  on  assumptions  regarding 
behaviour. 
changes 
Consequently,  a  quantification  of  impacts  on  individual  industries,  including  whether  a 
tangible  change  in  consumer  behaviour  might  cause  negative  impacts  on  e.g.  the  consumer 
packaged goods industry, was perceived as  highly  hypothetical and therefore with  a limited 
added value to this Impact Assessment. 

consumer 

Figure 9: Employment changes due to options in 
2050 compared to the 2050 baseline 

in 

6.3. 

Social Impacts  

The  main  social  impacts  of  the  suggested  options  concern  information  to  consumers, 
consumers’  trust  in  drinking  water  quality,  behavioural  changes  like  shifting  from  bottled 
water  consumption  to  tap  water  consumption,  cost  and  affordability  of  drinking  water,  and 
social inclusion.  

Option 4.2 and 4.3 are the options which are providing the most significant improvements in 
terms of information provided to consumers. These options will bring a significant increase 
of information on water quality across EU28 as compared to the baseline. In some Member 
States (Belgium, France, Portugal, UK) the information level is on average already relatively 
high. The most significant increase will be in countries with the lowest level of information in 
the  baseline  scenario,  such  as  Latvia,  Lithuania,  Ireland,  Hungary,  Poland  and  Romania.82 
Although the social impact for the citizens are evident, stakeholder consultations showed that 
these options were not well received by some public and private water operators arguing that 
these options are conflicting with complex water services governance systems established by 
the  national  administrations,  for  example  in  relation  to  water  pricing.  Moreover,  some 
associations raised doubts  on the real possibilities for citizens to  participate in  water  supply 
decision-making.  

The confidence people have in tap water quality is one main driver of tap water consumption 
compared  to  bottled  water  consumption.  Studies  have  shown  that  consumer  decisions  to 
purchase bottled water are predominantly driven by sensorial information regarding taste and 
odour,  and  the  associated  health  risk  concerns.  Thus,  the  level  of  confidence  among 
consumers  is  mostly  linked  to  the  perception  on  the  water  quality  and  to  the  access  of 

82  

More details are provided in the Impact Assessment Study 

31 

 
 
 
                                                 
information on water quality. Increased awareness and enhanced transparency through options 
4.2 and 4.3 is expected to bring about higher trust in the overall quality of the drinking water 
and of drinking water services. The decrease of bottled water is expected to be proportional to 
the level of information provided. Together with the general trend in decrease of bottled water 
consumption,  option  4.3  is  expected  to  result  in  a  reduction  of  the  share  of  bottled  water 
consumption by 17 % in 2050 as compared to baseline 2015. The consumption per capita/year 
would decrease from 106 litre/ capita in the baseline scenario to 88 litres/ capita as the EU28 
average, saving on average EUR 2.90 per household83 per year. 

Options  2.1  and  2.2  in  conjunction  with  options  4.2  and  4.3  would  induce  behavioural 
changes  and  not  only  influence  consumers,  but  also  water  suppliers'  behaviour  to  improve 
water  quality.  Empowered  citizens  would  follow  and  participate  more  actively  in  the  water 
management  decisions,  creating  a  sense  of  ownership  among  the  local  community  and 
provide incentives for protecting and improving their water supply. The local community can 
then facilitate the identification, the access and the management of the risks and hazards in the 
area, and balance the importance of safe water supply against other competing needs, such as 
housing  and  education.  The  impact  would  be  more  significant  under  option  2.2  as  it  would 
include all water suppliers, not only the large ones as is the case in option 2.1. 

6.3.1.  Affordability and social inclusion 

In  general  the  impact  of  the  options  on  affordability  of  water  services  for  the  average  EU 
households are very low, and affordability figures continue to range between 0.85 - 1.1 % of 
the  disposable  household  income.  The  'expensive'  option  1.2  has  a  comparatively  strong 
impact on the consumers' disposable income as it increases household cost on EU average by 
EUR 14.90 per year.  

The social inclusion impact is mainly related to option 5.2 on the improvement of access to 
safe  drinking  water.  Expanding  the  current  objective  of  the  Directive  to  demand  from 
Member States the provision of alternative self-supply systems or access to water in publicly 
accessible  places  or  other  relevant  measures  to  improve  access  to  water  would  have 
significant  positive  social  impacts,  as  a  larger  number  of  people  would  get  access  to  safe 
drinking  water,  especially  vulnerable  and  marginalised  parts  of  the  population.  As  a 
consequence  of  better  social  inclusion  and  better  health  of  the  population,  benefits  include 
productive days gained per year for the working population and time-savings (working days 
gained). 

Option 5.2 using conservative assumptions (see section 5.5) would increase costs on average 
in the EU by EUR 2.5 per household/per year and has consequently a much lower impact on 
affordability than the discarded option 5.1 whilst still achieving a considerable improvement 
with regards to access to drinking water.  

83  

Bottled  water  purchases  were  calculated  on  the  basis  of  10  cents  per  litre  of  bottled  water  uniformly 
across Member States. Assumingly this figure might be significantly higher in some countries. 

32 

 
 
 
                                                 
Figure 10: Affordability of drinking water if Option 5.2 is implemented 

On household level it is assumed that especially option 4.3 but also option 5.2 will lead to a 
decrease in the consumption of bottled water. Option 4.3 would lead to a decrease due to an 
assumed change in behaviour which will take place based on the availability of information 
on tap water. Options 5.2 would decrease the need for buying bottled water, as citizens would 
have the possibility to drink tap water instead. Savings are assumed to be EUR 2.90 (4.3) and 
EUR 0.40 (5.2) per household per year.84 

6.4. 

Environmental impacts 

6.4.1.  Water Pollution 

The  main  environmental  impacts  from  the  suggested  options  include:  the  quality  of  water 
resources,  reduction  of  pollution  at  source  for  water  resources  abstracted,  improvement  of 
water  resources  where  waste  water  is  discharged  (following  lower  levels  of  pollutants  in 
drinking  water),  energy consumption,  environmental externalities  of  consumption  of  bottled 
water,  which  also  contribute  to  reducing  the  amount  of  riverine  and  marine  litter,  resource 
efficiency; and biodiversity.  

Drinking  water  is  influenced  by  the  quality  of  fresh  water  bodies:  simultaneously  the 
requirements for high drinking water quality are also drivers that influence the protection and 
thus  the  quality  of  fresh  water  bodies.  Due  to  these  interactions,  impacts  are  difficult  to 
attribute.  It  is  assumed  that  in  the  baseline  2050  fresh  water  bodies'  quality  will  keep  on 
improving  notably  because  of  the  effective  implementation  of  the  existing  water  related 
directives.  It  is  assumed  that  the  chemical  status  of  surface  and  ground  water  bodies  will 
improve  by  10  percentage  points  by  2050  for  all  water  bodies,  and  by  20  points  where  an 
RBA has been implemented.  

84  

These estimates are very conservative as the price for one bottle of water was set at 10 cents uniformly 
across all EU Member States.  

33 

 
 
 
 
                                                 
Options addressing objective 1 will lead to reductions of pollutants in drinking water. More 
relevant  pollutants  will  be  monitored,  which  would  allow  suitable  interventions  and  thus  to 
remove  potential  risks  for  the  environment.  Option  1.2  would  have  a  more  significant 
environmental impact than option 1.1 since it would cover also emerging substances. Option 
1.2 has thus the potential for the largest reduction in pollution loads.  

Options  addressing  objective  2  will  have  through  their  integrated  risk  reduction  a  positive 
environmental impact, as risk assessments have the influence and the possibility to improve 
water quality across  all options. It will have  in particular  a potential  to enforce  measures  at 
source. The level of contribution depends on the individual cases. It includes the prevention of 
industrial  and  pharmaceutical  pollution,  and  different  characteristics  of  the  farming  such  as 
the crop rotations, intensity of cultivation, integration or not of livestock production as well as 
type  of  livestock  production,  addressing  fertilizers,  tillage,  irrigation,  green  manuring  and 
liming, reducing monoculture. All these characteristics have a bearing on the quality of water 
bodies  in  the  area,  and  changes  in  these  characteristics  due  to  options  2.1  and  2.2  might 
therefore significantly reduce the level of harmful environmental impact.  

The  positive  effect  of  implementing  measures  addressing  option  3  will  lead  to  less 
'toxic/harmful' contact materials itself, both for metallic and plastic materials, and also reduce 
the leaching  of  contaminants  into  the  water  cycle.  Also,  options  addressing  objective  4  will 
have a small but positive environmental impact, as consumers will have better information on 
water quality, and might require further stricter and precautionary measures to limit risks to a 
minimum.  With  regard  to  option  5.2,  it  will  open  up  additional  catchments  and  require 
additional measures at source, which might have positive local impacts on fresh water quality 
through  reduced  pollution  loads.  The  biggest  impacts  would  be  in  areas  with  currently  low 
connection rates to PWS. The most affected countries are Romania, Lithuania and Latvia. 

Reducing  the  amounts  of  pollutants  in  drinking  water  by  unlisted  and  emerging  substances 
would  have  a  positive  environmental  impact  on  water  bodies,  water  ecosystems  and 
organisms. The benefits on the status of aquatic ecosystems and related ecosystems will thus 
also have a positive effect on biodiversity, as well as on the recreational value of ecosystems. 
The increased measures at source following options 2.1 and 2.2 will to a large extent include 
changing agricultural practices that have a significant impact on water bodies, soil quality as 
well as biodiversity. When farmers are adapting their practices to reduce pollution at source, 
this can have positive impacts on biodiversity/ landscape in the areas where changes in farm 
practices take place. 

6.4.2.  Resource efficiency 

Option  4.3  provides  consumers  and  suppliers  with  strong  incentives  to  improve  water  and 
resource  efficiency.  Smart  information  will  empower  the  consumers  to  hold  suppliers 
accountable  for  managing  leakage rates  at  acceptable levels.  This  will lead  to  early  leakage 
detection, fixing and decreased water use, and will contribute to reduce leakages from water 

34 

 
 
 
supply networks, that currently remain on EU average at 23 %85. Measures addressing leakage 
problems in distribution systems would in general reduce water consumption as well as lead 
to  energy  savings.  Due  to  its  technical  complexity,  for  example  to  consider  unavoidable 
losses86,  it  was  not  possible  to  estimate  the  impacts  of  the  options  on  potential  leakage  rate 
reductions.  Regardless,  reduced  water  consumption  would  have  a  significant  environmental 
impact  on  water  ecosystem  and  related  ecosystem  services,  especially  in  already  water 
stressed areas. 

6.4.3.  Energy 

Drinking  water  supply  by  water  pipes  is  in  comparison  to  all  other  transport  modes  very 
energy-efficient. The energy needed for distribution to provide each citizen with about 50 000 
l/  year  equals  the  energy  needed  to  produce  three  litres  of  bottled  water.  The  total  energy 
consumption  relates  to  the  energy  consumed  in  the  process  for  producing  drinking  water, 
which varies greatly due to differences in the size of the water systems, pumping requirements 
between  geographic  locations,  and  raw  water  characteristics  and  quality.  The  overall 
greenhouse  gas  (GHG)  emissions  of  the  EU  drinking  water  supply  are  roughly  6  million 
tonnes CO2 eq.87. Reduced energy consumption will also bring associated reduction in GHG 
emissions. Energy consumption for treatment represents 50 % of total energy consumption for 
the  EU  drinking  water  supply,  followed  by  abstraction,  whereas  distribution  represents  on 
average only 5 %88. Thus options that reduce the need for treatment, by for instance applying 
measures  at  source,  would  result  in  energy  savings.  Options  2.1  and  2.2  will  thus  have  a 
positive energy impact. Option 1.2 that will require an increased treatment estimated by +30 
%  will thus have  a  negative energy impact. Also option 5.2 will require  more treatment for 
alternative supplies and source  measures, which will increase their energy demand  by 50 % 
(estimates).  Overall,  estimates89  show  that  30 %  energy  savings  could  be  achieved  from 
improving  water  efficiency,  to  which  in  particular  options  2.1,  2.2,  4.2  and  4.3  contribute, 
which will very likely overcompensate additional energy consumption induced by options 1.2 
and 5.2. 

6.4.4.  Bottled water 

This Impact Assessment has also analysed the bottled water consumption in EU28, as this is 
related to social but also environmental effects. Through better availability of information to 
consumers an improvement in confidence in drinking water would be achieved, which in turn 

85 

86  

87 

88 

89 

See for example CIS Guidance Document Best Practices: https://circabc.europa.eu/sd/a/1ddfba34-e1ce-
4888-b031-6c559cb28e47/Good%20Practices%20on%20Leakage%20Management%20-
%20Main%20Report_Final.pdf 
Unavoidable  losses  of  treated  water  are  those  underground  losses  that  are  rather  little  in  quantity  but 
that would cost so much to be located and to be repaired that it would be less costly to keep the leakage 
instead of fixing it (American Water Works Association). 
The water sector uses 29 kWh per year for the drinking water supply of one person. Source: dvgw Wirt 
schafts- und Verlagsgesellschaft Gas und Wasser mbH, Profile of the German Water Sector 2015. The 
energy intensity is however quite diverse across Europe, calculation with 0,395 kg CO2/kWh 
Rachel Young (2014) Watts in a Drop of Water: Savings at the Water-Energy Nexus, An ACEEE  
White Paper and European Benchmarking Cooperation (2013) Public report of the International water 
benchmark: Learning from International Best Practices. 
Rachel Young’s report, see above 

35 

 
 
 
                                                 
would  lead  to  a  reduction  of  use  of  bottled  water.  Reduced  consumption  of  bottled  water 
would result in a reduction of the associated use of resources, energy consumption, emissions 
and waste generation from the production and transport of plastic and glass bottles.90  

Options 4.2 and 4.3 would therefore lead to improvements in resource efficiency. An average 
EU  citizen  currently  consumes  106  litres  of  bottled  water per  year,  in  some  Member  States 
like Germany, Malta, Italy up to 170 l. Option 4.3 for which a reduction against the baseline 
from 100 to 88 litres per year is estimated by 205091, would already reduce GHG emissions 
by 1.2 million tonnes CO2 eq. This represents 20 % of the total energy demand of the whole 
EU  drinking  water  supply  (Calculation/  Assumptions  in  Annex  4).  Thus  options,  such  as 
option  4.3,  that  contribute  to  reduce  bottled  water  consumption  have  a  significant  positive 
energy and climate change impact.  

Stakeholders were however vocal about using the bottled water as an indicator for consumer 
confidence  in  tap  water  and  pointed  out  that  that  the  reduction  potential  of  a  few  litres  per 
consumer  and  year  is  low,  whereas  the  bottled  water  industry  is  important  for  local 
employment and for diversified choice of drinking water. 

6.5. 

Administrative Burden Reduction Impacts 

The  evaluation  did  not  identify  provisions  that  cause  high  administrative  burden.  The  tasks 
done  by  health  authorities  that  relate  mainly  to  monitoring  and  surveillance  are  marginal  in 
comparison to the work of water operators. No substantial changes to these costs are expected 
to  occur  except  for  options  2.2  and  4.1  (Annex  4).  Positive  economic  aspects  related  to 
administrative burden-reduction will mostly be achieved through adoption of option 4.1. This 
option  identified  the  simplification  -  by  very  substantially  limiting  reporting  to  the 
Commission  to  useful  information  and  data  -  and  automation  potential  of  the  reporting.  A 
reduction of reporting requirements to the most important data on exceedances and significant 
incidents is assumed to significantly reduce administrative burden for Member States and the 
Commission. The set-up cost amount to EUR 2.9 million in comparison to the baseline 2050 
and  relate  mainly  to  developing  the  software  and  linking  of  systems.  After  these  initial 
investments,  annual  savings  on  reporting  provisions  are  estimated  at  EUR  0.35  million, 
visible in the reduction of the operating costs for reporting. Whether the simplified reporting 
can be at the same time interlinked with the European electronic reporting tool under Water 
Information  System  for  Europe  (WISE),  or  a  new  reporting  tool  in  the  follow-up  of  the 
Fitness Check of Monitoring and Reporting92, remains to be seen.  

For options 2.1 and 2.2 the main challenge for administrations and national authorities will be 
the change of approach to set up risk assessment systems. This is expected to lead to set-up 

90  

91  

92 

These  assumptions  were  contested  by  stakeholders  from  the  bottled  water  industry  who  argued  that 
their industry is essential for regional/ local employments, that their water needs less treatment and that 
the industry's efforts to protect the environment are often overlooked.  
The bottled water industry argues that there is no direct link between more information and a decrease 
in the consumption of bottled water.  
http://ec.europa.eu/environment/legal/reporting/fc_overview_en.htm 

36 

 
 
 
                                                 
investment costs of EUR 6.25 million in comparison to baseline 205093. More knowledge and 
other  resources are needed for these options, as the risk-based approach requires  a different 
way of thinking and of administrative procedures than current approach via fixed monitoring 
intervals. Thus, the first years will require learning, training and guidance. This will probably 
initially be considered as a new burden by those who have to implement these changes. In the 
beginning,  difficulties  are  expected  in  monitoring  the  effectiveness.  All  this  will  be  in 
particular  an  issue  for  countries  with  a  significant  share  of  small  water  supplies  and  SMEs 
involved.  Therefore,  option  2.2  foresees  sufficient  time  to  putting  the  RBA  in  place. 
Experience  with  the  RBA  has  shown  that  over  the  years  this  new  system  will  reduce 
longer  run, 
unnecessary  administrative  burden  and  analyses  significantly.  On 
administrative burden reduction can be expected by the reduction of the number of parameters 
to be monitored and reported.  

the 

The challenges faced by Option 3 are more of a regulatory nature. It is interesting to note that 
most  of  the  administrative  costs  are  spent  on  conformity  assessment  procedures  and  testing 
(75  %)  concerning  materials  and  products  in  contact  with  drinking  water.  Smaller  cost 
components  include  the  design  of  products,  their  production  processes  (15  %)  and  the 
awareness  raising  effort  for  companies  (15  %).  The  annual  burden  reduction  potential  for 
manufacturers has been estimated at EUR 669 million, assuming that in the future materials in 
contact with drinking water are fully recognised within an internal market without obstacles.  

7. 

COMPARISON OF OPTIONS 

7.1. 

Health Protection versus Costs 

As  the  objective  of  the  DWD  is  the  protection  against  adverse  health  effects  from  drinking 
water,  the  main  question  to  be  answered  in  this  Impact  Assessment  is  how  effective  the 
different  options  contribute  hereto,  and  how  efficient  they  are.  In  terms  of  potential  health 
impacts, the best health impact, largest reduction in PPHR by 2050 is obtained with option 
1.2 (full list of parameters) followed by Option 4.3 (smart-information on water quality and 
water services performances).94  

In terms of costs, option 1.2 is the most expensive one. On the opposite side of the spectrum, 
option 3, options 2.1 and 2.2 lead to some (although limited for these two last) benefits 
(cost savings) as compared to the baseline scenario.  

Option 

1.1 

1.2 

93  

94  

Change in PPHR as 
compared to 
baseline (millions 
of inhabitants) 

-6,6 

-14,7 

Total set-up costs in 
addition to baseline 
2050 in million EUR 

Operating costs in 
addition to baseline 
2050 in million EUR 

Change in household 
costs to the consumer 

1 965 

5 895 

437 

2 842 

+ 2.60 

+ 14.90 

Estimates  in  are  based  on  recent  assumptions  from  Member  States  authorities:  one-off  administration 
time  5  hours  for  small,  20  hours  for  large  supplies.  Administrative  costs  do  not  include 
licensing/approval  costs  that  are  imposed  on  operators.  One-off  EU  costs  estimated  at  EUR  6.25 
Million. No reduction in operational costs for authorities through option 2.2 assumed. 
For a graphical overview see Figure 11 and Figure 13.  

37 

 
 
 
                                                 
2.1 

2.2 

3 

4.1 

4.2 

4.3 

5.2 

-1.2 

-1,5 

-0.9 

0 

-6,6 

-7,9 

-0,6 

22 

25 

0 

2.9 

4.2 

5.6 

1 411 

-76 

- 96 

- 669 

- 0.352 

876 

933 

60 

- 0.35 

- 0.40 

- 3.20 

+ 0.001 

+ 4.20 

+ 4.50  

+ 2.50 

Table 2: Changes in PPHR, changes in costs and costs per additional person protected for the 
different Options 

7.2. 

Ranking overall  

Table  4  provides  a  ranking  of  the  options  in  comparison.  The  assessment  of  the  ranking  is 
based on the findings and analysis described in Sections 5 and 6, as well as in Annex 4. The 
ranking is based on quantitative and qualitative factors derived from the analysis. The scale 
outlined  in  Table  3  shows  how  "+"  and  "-"  are  attributed  to  positive  and  negative  impact 
expectations. As each category in Table 4 has different indicators, Annex 4 (Section 8) can be 
consulted for an overview of ranges and cut-off points for each quantified category.  

Very large 
negative 
impact 

Large 
negative 
impact 

Medium 
negative 
impact 

Small 
negative 
impact 

No 
impact 

Small 
positive 
impact 

Medium 
positive 
impact 

Large 
positive 
impact 

Very 
large 
positive 
impact 

- - - - 

- - -  

- - 

- 

+/- 

+ 

++ 

+++ 

++++ 

Table 3: Legend for Table 5 

The "overall ranking" of each option is determined through the accumulation of "+" and "-". 
In the accumulation positive impacts for the reduction of the PPHR have twice the weight as 
other positive/negative impacts to acknowledge the Directive's overarching aim of protecting 
human  health.  As  the  aim  is  to  address  all  four/  five  areas  of  improvement  that  were 
uncovered  in  the  Evaluation  of  the  Directive,  options  are  always  chosen  in  comparison  to 
other  options in  their set.  Through this,  it will  be ensured  that all areas of improvement are 
covered through the amended Directive.  

As  the  revision  of  the  DWD  is  part  of  the  REFIT  programme,  option  4.1,  which  entails 
simplifications of reporting requirements to the Commission, is part of all combinations. As it 
does not have significant effects on many of the categories outlined in the table, it was chosen 
– also for readability purposes – to not include option 4.1 in the table.     

It  should  be  noted  that  in  the  table  below  options  addressing  the  same  objective  are  being 
compared.  Since  the  revision  of  the  Directive  aims  at  addressing  all  above  identified  and 
outlined  problems,  it  is  now  important  to  identify  from  each  set  of  options  the  best  one  to 
build an efficient policy package that address all current issues.  

38 

 
 
 
 
Option 1.1 

Option 1.2 

Option 2.1 

Option 2.2 

Option 3 

Option 4.295 

Option 4.3 

Option 5.2 

Reduction of PPHR at short/mid-term 

Reduction of PPHR at long term 

Increase/ decrease in annualised set-up 
and operating costs (€million)97 
Impact on SMEs and R&D 
Internal market impact 

Change in employment 

Change in health cost 

Change in costs per household (€/ year) 

Increase in confidence in water quality 

Improvement of water quality 
More treatment of pollution at source 
Energy savings 

Points98 

Accumulated result 

++ 
(- 33 %)  
+ 
(-3 %) 

- 
(+ 535) 
+ 
+ 
+ 
(+ 4 112) 
++ 
(- 68) 

- 
(+ 2.60) 
+ 

+ 
+ 
- 

14 +  
3 - 
11 

++++ 
(- 74 %)  
++++ 
(-15 %) 

- - - - 
(+ 3 137) 
++ 
++ 
++ 
(+ 24 353) 
++++ 
(- 152) 

- - - 
(+ 14.90) 
+ 

++ 
++ 
- - 

31 + 
9 - 
22 

HEALTH IMPACT96 
+ 
(- 6 %) 
+/- 
(0 %) 

+ 
(- 8 %)  
+ 
(-1 %) 

ECONOMIC IMPACT 
+ 
(- 74) 
+ 
+ 
+/- 
(- 674) 
+ 
(- 14) 

+ 
(- 93) 
+ 
+ 
+/- 
(- 883) 
+ 
(- 17) 

SOCIAL IMPACT 

+ 
(- 0.35) 
+ 

+ 
(- 0.40) 
++ 
ENVIRONMENTAL IMPACT 
+++ 
+++ 
+++ 

++ 
++ 
++ 
OVERALL RANKING 

14 + 
0 - 
14 

20 + 
0 - 
20 

+ 
(- 4.2 %) 
+/- 
(0 %) 

++ 
(- 669) 
+ 
+++ 
- 
(- 8 525) 
+ 
(- 14) 

- 
(- 3.20) 
+++ 

++ 
+/- 
+/- 

14 + 
2 - 
12 

++ 
(- 33 %)  
++ 
(- 5 %) 

- -  
(+ 876) 
+ 
+/- 
+ 
(+ 3 889) 
++ 
(- 80) 

- 
(+ 4.20) 
++ 

++ 
+ 
- 

17 + 
4 - 
13 

++ 
(- 39 %) 
++ 
(- 6 %) 

- - 
(+ 934) 
++ 
+/- 
+ 
(+ 2 128) 
+++ 
(- 91) 

- 
(+ 4.50) 
++++ 

++ 
+ 
- 

21 + 
4 - 
17 

+ 
(- 2.8 %)  
+/- 
(0 %) 

- 
(+ 530) 
++ 
++ 
+ 
(+ 8 926) 
+ 
(- 9) 

- 
(+ 2.5) 
+ 

++ 
+ 
- - 

12 + 
4 - 
8 

Table 4: Ranking of options 
95  

For readability purposes option 4.1 is not displayed in detail in this overview, nevertheless as pointed out previously it would have a significant impact especially on administrative 
burden. For more quantitative details on administrative burden reduction, see Section 6.5 and Annex 5. 
% change in total PPHR to baseline 2050 and % change in marginal risk population to baseline 2050 
Increase and decrease contain changes of annual operating costs and annualised set-up costs in comparison to baseline 2050.  
As the protection of human health is the main objective of the Directive, impacts on health are counted with a factor 2 in the accumulation of points to determine the ranking result. 

96 
97  
98  

39 

 
 
                                                 
 
7.3.  Who will be affected?  

The  analysed  options  of  amending  an  existing  Directive  affect  citizens, water operators and 
authorities in a rather moderate way (see Annex 3 for more details). The main impacts of the 
options for an EU citizen will be for EU citizens through the reduction of the probability of 
being  at  risk  (PPHR)  combined  with  a  reduction  of  potential  chronical  effects;  and  with 
regard to the affordability of drinking water. Water suppliers could be most affected by costs 
for monitoring and additional treatment, and through the requirements to develop and apply a 
risk-based approach even though mid-term financial benefits are expected. Manufacturers of 
products  and  materials  in  contact  with  drinking  water  will  be  affected  through  changes  in 
product standards and approvals. Public authorities will also be challenged on how to control 
the risk-based approach and apply the principles of transparency. 

7.4. 

Presentation of possible policy packages  

The  Impact  Assessment  has  identified  five  problem  areas,  defined  five  corresponding 
objectives  with  each  objective  having  a  set  of  options.  The  ranking  of  the  options  along  a 
variety of categories can be found in section 5.  

To  cover  as  effectively  and  efficiently  as  possible  all  four  identified  problem  areas  of  the 
Evaluation  of  the  Directive,  three  'feasible'  packages  of  options  have  been  developed  with 
each  package  containing  options  from  all  four  objectives.  The  packages  have,  however, 
different levels of ambition in terms of health outcomes. For these packages, and in line with 
the main objective of the Directive, the reduction of health risks has been given high priority. 
For  the  ambitious  packages  only  the  very  positive  ranked  options  1.2,  2.2,  3  and  4.3  were 
chosen from Table 4. 

In order to analyse only 'feasible' packages, options with excessive costs and limited impacts 
on health protection were not selected for the analysed policy packages.  

In summary, the three packages, combining different options were further investigated, are:  

  Package 1 (less ambitious) = 1.1 + 2.1 + 3 + 4.1 + 4.2 
  Package 2 (medium) = 1.2 + 2.2 + 3 + 4.1 + 4.3  
  Package 3 (advanced) = 1.2 + 2.2 + 3 + 4.1 + 4.3 + 5.2 

The modelling assumptions are included in Annex 4.  Figure 11 shows the health impacts of 
the remaining options plus the three combinations.  

It is assumed that the options cannot just be added up to each other, as also already noted in 
Section 2 the problems and consequently also the options addressing them interact/synergize 
and should not be seen in isolation. Synergetic effects of combinations of options are assumed 
to deliver higher health benefits whilst reducing the overall costs.  

Consequently, "packaged" options are assumed to be less expensive than individual options. 
The  synergy  effects  have  been  considered  by  including  specific  assumptions  for  the 
calculations  at  Member  State  and  EU  level  (Annex  4).  The  main  synergetic  effect  occurs 
under the simultaneous adoption of options from set 1, 2 and 4.  

40 

 
 
 
For the ambitious policy packages this means: whereas option 1.2 ensures that a vast number 
of substances is covered in general, option 2.2 allows the individual water supplier to opt out 
for  individual  parameters,  if  it  is  clear  that  these  are  not  to  be  found  in  the  supplier's 
catchment area. Consequently, the large positive health effects of 1.2 are not endangered, but 
costs can be reduced as the water supplier will only need to apply a tailored treatment to the 
specific substances found in the specific catchment area.  

Furthermore,  option  2.2's  holistic  approach  will  lead  to  more  treatment  at  source  and 
preventive  measures,  which  entails  overall  cleaner  raw  water,  which  needs  less  treatment. 
Consequently, fewer substances will be found in the water, only a shorter list of substances 
needs  to  be  monitored  and  treated  for,  and  costs  can  therefore  be  reduced.  This  positive 
interplay  is  supported  by  option  4.3  that  entails  an  enabling  framework  to  empower  the 
consumer.  An  empowered  consumer  is  expected  to  pressure  the  water  supplier  for  efficient 
management whilst maintaining highest standards of the water quality. This will also entail a 
reduction of leakages, which means that less treated water is lost – and therefore overall less 
water needs to be treated.  

As can be seen in Table 5 individual options such as 1.2 achieve significant health benefits by 
reducing the PPHR to 1.01 % - however, the option does so whilst costing more than EUR 3 
000  million.  Assuming  that  the  synergetic  effect  of  combining  option  1.2  with  2.2  and  4.3 
achieves reductions in, for instance, treatment needs by about 10 % to 15 %, policy packages 
that contain both will have significantly lower costs than only option 1.2 alone.  

Comparison individual options 
and packages 

Remaining PPHR in 2050  

under individual options 

Costs (annualised set-up and 
operating cost) in comparison to 
baseline 2050 (€/million) 

Baseline 2050 

Option 1.1 

Option 1.2 

Option 2.1 

Option 2.2 

Option 3 

Option 4.1 

Option 4.2 

Option 4.3 

Option 5.2 

3.81% 

2.56% 

1.01% 

3.59% 

3.52% 

3.65% 

3.81% 

2.56% 

2.32% 

3.71% 

41 

0 

535 

3 137 

-74 

-93 

-669 

0.23 

876 

934 

530 

 
 
PP 1 (1.1+2.1+3+4.1+4.2) 

PP 2 (1.2+2.2+3+4.1+4.3) 

PP 3 (1.2+2.2+3+4.1+4.3+5.2) 

1.60% 

0.90% 

0.79% 

Table 5: Individual options and packages in comparison 

Assessment of policy packages 

253 

1 647 

2 177 

Figure 11 shows that package 1 would reduce by 2050 the PPHR by 58 % or a reduction of 
11.6 million people at risk, package 2 by 76 % or 15.3 million and package 3 by 79 % or 15.9 
million.  The  cost  of  drinking  bottled  water  to  consumers  will  decrease  by  respectively 
EUR 336 million (package 1) and EUR 610 million (package 2 and 3).   

Figure 11: Health impacts (PPHR) for selected options and for their combination into Policy 
Packages 1, 2 and 3 

As  previously  indicated,  the  current  costs  for  supplying  drinking  water  in  the  EU  in  2015 
amount to EUR 46.3 billion (see Section 5.0) and are assumed to be 47.9 billion in baseline 
2050.  In  comparison  to  baseline  2050,  the  assessments  of  the  costs  of  the  three  policy 

42 

 
 
 
packages show that they will lead to an increase in annual costs99 of EUR 0.3 billon (PP1), 
EUR  1.6  billion  (PP2)  and  EUR 2.2  billion  (PP3)  respectively,  see  Figure  12.  For  2050  the 
pure total set-up costs in comparison to baseline 2050 would amount to EUR 2 billion (PP1), 
EUR 5.9 billion (PP2) and EUR 7.3 billion (PP3) (Table 6).  

Figure 12: Annualised set-up and operating costs of the policy packages 1, 2 and 3 (in million 
EUR) 

The  combination  of  the  PPHR  and  cost  indicators  helps  assessing  the  cost-effectiveness  of 
each  policy  package,  as  illustrated  in  the  figure  below,  which  compares  the  cost-
effectiveness ratio of the three policy packages as compared to the ratio of individual options.  

99  

"Annual costs" include annual operating costs and annualised set-up costs. 

43 

 
 
 
                                                 
Figure 13: Cost effectiveness of options and packages in comparison 

Overall,  while  package  3  delivers  the  highest  effectiveness  in  terms  of  reduction  of  the 
indicator PPHR, package 2 is more cost-effective than package 3. Package 1 involves fewer 
costs but has a more limited effect on the main objective of public health.  

With  regard  to  affordability,  policy  package  1  will  increase  the  total  cost  per  household 
(baseline:  EU28  average  2050:  EUR 228)  by  ca.  EUR 1.20  euro  per  year  (+  0.5  %).  For 
policy package 1 an increase can be observed for instance in Finland from EUR 263 per year 
in the baseline 2050 to EUR 264.80 per year. At the same time in some Member States, such 
as in Croatia the costs per household could slightly decrease from EUR 149.80 per year in the 
baseline to EUR 149.30 per year. Policy package 2 will increase the total cost per household 
on EU average by EUR 7.90 per year (+ 3.4 %).  This would mean for instance for Finland an 
increase  to  EUR  272  per  year  and  for  Croatia  to  EUR  154  per  year.  Policy  package  3  will 
increase  the  total  cost  per  household  by  EUR 10.40  per  year  (+  4.5 %),  which  would  be  an 
increase for Finland to EUR 277 per year and for Croatia to EUR 164 per year. An overview 
of the household cost changes in comparison to baseline 2050 is provided in Figure 14. As is 
visible  in  this  figure,  some  Member  States  are  assumed  to  not  be  impacted  by  option  5.2, 
which results in the economic impact of PP2 and PP3 being the same for them.  

44 

 
 
 
Figure 14: Household costs per policy package in comparison to baseline 2050 

Employment is expected to decrease by 1 233 persons as compared to the 2050 baseline for 
package  1  and  it  is  expected  to  increase  by  17  038  persons  with  package  2  and  25  964  for 
package 3. 

The  Table  6  below  compares  the  three  policy  packages  with  regard  to  effectiveness, 
efficiency, coherence, and proportionality.  

Policy 
Package 

Effectiveness 

Efficiency 

Coherence 

Proportionality 

Policy 
package  1 
(1.1+2.1+3+
4.1+4.2) 

PPHR 
Indicator 
reduced 
11,61 
by 
million  inhabitants  as 
compared  to  baseline 
by 2050 

Policy 
package  2 
(1.2+2.2+3+
4.1+4.3) 

by 

PPHR 
Indicator 
15.3 
reduced 
million  inhabitants  as 
compared  to  baseline 
by 2050 

Increased  coherence 
with WFD (as a result 
of RBA) 

EUR  25.9  /additional 
person protected from 
health risk 

of 

Increased  coherence 
with WFD (as a result 
of RBA)  
+ expected benefits in 
resource 
terms 
efficiency  of  water 
suppliers as a result of 
SMART  information 
to customers on wider 
range  of  management 
issues  

104.6 
EUR 
person 
/additional 
protected  from  health 
risk 

Total  set-up  cost  in 
2050: 2 billion 
Water  tariffs  as  %  of 
disposable  income  = 
0,73 % 
Employment: - 1 233 
Total  set-up  cost  in 
2050: EUR 5.9 billion  
Water  tariffs  as  %  of 
disposable  income  = 
0,75 % 
Employment:  
+ 17 038 
Expected 
impact 
management 
efficiency  of  water 
suppliers 
Little  positive  social 
environmental 
and 
impacts 
to 
due 
inclusion  of  2.2  and 

larger 
on 

45 

 
 
 
 
Policy 
Package  3 
(1.2+2.2+3+
4.1+4.3+5.2
) 

by 

PPHR 
Indicator 
15.9 
reduced 
million  inhabitants  as 
compared  to  baseline 
by 2050 

4.3 
Total  set-up  cost  in 
2050: EUR 7.3 billion 
Water  tariffs  as  %  of 
disposable  income  = 
0,76 % 
Employment:  
+ 25 964 
Expected 
impact 
management 
efficiency  of  water 
suppliers 
Positive  Social  and 
environmental 
impacts  significantly 
improved,  especially 
through  inclusion  of 
5.2 

larger 
on 

of 

Increased  coherence 
with WFD (as a result 
of RBA)  
+ expected benefits in 
resource 
terms 
efficiency  of  water 
suppliers as a result of 
SMART  information 
to customers on wider 
range  of  management 
issues 

138.4 
EUR 
person 
/additional 
protected  from  health 
risk 

Table 6: Summary the assessment of the three Policy Packages 

Conclusion 

On the basis of the above assessment, all policy packages are a balanced and coherent choice 
for political decision to be made. Policy packages 2 and 3 are more effective with regard to 
health  protection,  and  are,  from  the  health  and  environmental  viewpoint,  the  preferred 
packages in comparison to package 1. Both packages 2 and 3 correspond best to the general 
objective  to  contribute  in  the  most  possible  effective  and  efficient  way  to  protect  human 
health.  Improvements  can  be  expected  on  the  quality  of  the  water  distributed  by  small 
suppliers  which  will  contribute  to  the  reduction  of  human  health  risks.  The  suggested 
packages will preserve high drinking water quality in the long-term.  

The small increase of costs for both packages, as outlined above, is legitimate and outweighed 
by  the  health  benefits.  Additionally,  both  packages  2  and  3  also  contribute  to  the 
modernisation  and  simplification  the  current  legislation  -  where  this  is  feasible  and  without 
impairing the overall objective of protection of health - by moving from an 'end of pipe' to a 
more preventive and integrated approach. 

These  two  more  favourable  packages  provide  concrete  answers  to  the  ECI  'Right2Water' 
notably  through  option  4.3  (smart  information)  while  better  connecting  the  drinking  water 
approach to the concept of circular economy (for example through increased confidence in tap 
water and transparency on leakage rates).  

Package  3  provides  an  additional  answer  to  meeting  the  objectives  of  SDG  6  on  access  to 
water through the inclusion of option 5.2. It is expected that option 5.2, which entails a set of 
measures  to  improve  access  to  water,  would  substantially  improve  the  situation  for  non-
connected EU citizens.   

The related additional set-up costs (about EUR 1 411 million) is most probably overestimated 
as  -  in  absence  of  more  accurate  data  -  it  is  based  on  the  assumption  that  half  of  the  non-
connected citizens would be provided with individual treatment systems (see section 5.5).  

46 

 
 
 
Both  policy  packages  have  a  positive  impact  on  the  environment  as  bottled  water 
consumption  is  assumed  to  decrease  through  the  increase  of  consumer  confidence  in  tap 
water,  which  will  be  stimulated  by  providing  better  access  to  up-to-date  information  for  all 
consumers.  Furthermore,  the  mandatory  use  of  the  risk-based  approach  for  large  and  small 
water supplies leads to less need for treatment, which entail energy savings and a reduction of 
chemicals  released  into  the  environment.  Moreover,  it  is  expected  that  the  risk-based 
approach  improves  the  treatment  of  pollution  at  the  source  and  better  application  of  the 
polluter-pays principle.  

Taking  into  account  all findings  of  this  impact  assessment  as  well  as  the  ECI  Right2Water, 
which was one of the triggering factors for the revision of the directive, a cleverly problem-
oriented version of policy package 3 is the most favourable package. Instead of assuming that 
half the non-connected population would be provided with self-supply systems, package 3 is 
adapted to the needs of individual Member States.  This would mean a general obligation to 
improve access should be introduced, but a margin of discretion should be left to the Member 
States  to  decide  how  to  best  improve  access  to  water  taking  specific  local  situations  into 
account. A number of effective measures could be expected to work across all Member States, 
these  include:  providing  information  on  possibilities  for  connection  and  points  of  access, 
setting up street fountains, encouraging the use of drinking water in public buildings such as 
schools, and in restaurants, and, in addition, ensuring access to water for a particular category 
of  the  population  (vulnerable  and  marginalised  groups).  Implementing  such  measures  and 
leaving margin of discretion for the Member States to react to their national needs would be 
substantially less costly than the initially assumed package including self-supplies solutions.  

Finally, the implementation of option 4.1 (significantly limit reporting to the Commission) in 
combination  with  the  options  2  (risk-based  approach)  will  also  contribute  to  reduce 
administrative burden by limiting  the reporting obligations only  to  relevant information  and 
by limiting monitoring efforts only on parameters making sense.  

8. 

MONITORING AND EVALUATION 

It  is  crucial  to  monitor  the  measures  to  ensure  that  the  general  and  specific  objectives  are 
achieved in an effective and efficient manner. It needs to be ensured that the enforcement of 
the DWD can be monitored, and that in case of non-compliance the measures are enforceable.  

The current Directive had established a reporting system focusing on water quality data. This 
reporting of compliance and non-compliance information has reached its limits over the years. 
Most  compliance  data  reached  100  %,  and  as  the  data  processing  and  reporting  was  slow, 
reports  were  outdated  when  they  were  published.  Thus,  this  information  had  limited 
significance  as  an  environmental  indicator  but  also  as  an  instrument  to  measure  the 
effectiveness and efficiency of the Directive. Therefore, a different monitoring and evaluation 
system should be established. The amended  Directive should be subject to an evaluation no 
later than 12 years after transposition and its Annexes should be regularly reviewed in light of 
scientific and technical progress.  

47 

 
 
As it is difficult to measure the success of a 'safety' instrument that shall protect human health 
from the adverse effect of drinking water contamination, and as also the data collected by the 
European Centre of Disease Prevention and Control (ECDC) could not be directly linked to 
drinking  water,  a  workable  solution,  with  a  mix  of  measurable  output  indicators  combined 
with some success indicators, will be proposed. It is suggested to have a number of different 
success  indicators,  to  be  used  for  future  evaluations,  developed  in  cooperation  with  the 
European  Environmental  Agency,  taking  account  of  the  INSPIRE  Directive  and  of  the 
findings of the Fitness Check on Environmental Monitoring and Reporting (Annex 5): 

• 

• 

• 

• 

The number of 'incidents' and cases of exceedances of the limit values in the European 
Union. In the new reporting system, Member States will be asked to report on these 
incidents and on the solutions provided in a more effective manner;  

The number of Union citizens with access to water intended for human consumption; 

Long-term health impacts due to the quality of the drinking water  – this will require 
additional epidemiologic studies in conjunction with specialised organisation like the 
WHO.  

The new transparency and minimum information to be available online, for example 
the  level  of  leakages  in  the  networks,  to  allow  for  a  systematic  analysis  of 
implementation levels and achievements.  

The Commission will remain in close contact with the Member States and with the relevant 
stakeholders to monitor implementation and drinking water quality. The Drinking Water 
Expert Group represents an excellent forum for the exchange of information with the Member 
States and key stakeholders.  

48 

 
 
 
 
9. 

ANNEXES 

Annex 1 

Procedural  information  concerning  the  process  to  prepare  the  Impact 
Assessment report and related amendment  

Annex 2 

Stakeholder consultation report – Synopsis report  

Annex 3 

Who will be affected and how 

Annex 4 

Development  of  the  analytical  model  for  the  assessment  of  the  options: 
description  of  the  options,  underlying  assumptions  and  impacts  assessed 
through application of methodology  

Annex 5 

Monitoring Table 

Annex 6 

Glossary 

49 

 
 
 
 
 
 
9.1. 

Annex 1  
Impact Assessment report and related amendment  

Procedural  information  concerning  the  process  to  prepare  the 

1. Chronology 

Decide Planning: 2017/ENV/014 - Revision of the Drinking Water Directive   

2014  March 

2014 

April 

2014 

June 

2014 

September 

2014 

December 

January 

2015 
2015ff 

2015  May 
June 
2015 
December 
2015 
January 
2016 
July 
2016 
2016 
September 
2016  October 

2016 
2017 

December 
February 

2017  March 
2017   March  

Public Consultation on Drinking Water announced in the 
Commissions Reply to the ECI Right2Water 
Inter-service Steering Group set up (incl. DG SG, GROW, SANTE, 
REGIO, RTD, JRC, CLIMA) , first ISG Meeting 30/04/2014   
Public Consultation performed from 23/06/2014 until 23/09/2014 
(EUSurvey), Results published afterwards 
Stakeholder Dialogue on Transparency and Benchmarking launched, 
two dialogues performed in September 2014 and October 2015 
Inclusion of the DWD Evaluation in the Commission Work 
Programme 2015 A New Start, COM(2014) 910 final of 16/12/2014 
Annex 3 Refit 
Evaluation Study kicked off 
Inter-Service Group Meetings carried out on 08/01/2015, 
10/04/2015, 08/10/2015, 11/12/2015, 04/04/2016, 20/06/2016, 
10/10/2016, 17/05/2017 (The overall consultation strategy was 
agreed by an Inter Service Group (ISG) that met 8 times so far and 
that was kept up to date. The Commission internal ISG was also 
consulted on options, indicators, methodology and main impacts, 
options were discussed at an ISG meeting on 20/06/2016 and their 
impacts on 10/10/2016. The ISG was consulted and discussed the 
draft final Commissions' Impact Assessment on 17/05/2017. A 
summary of the minutes is provided as a separate document). 
Stakeholder Consultation Conference organised on 26/05/2015  
Drinking Water Roadmap published 
Impact Assessment Stakeholder Conference on 08/12/2015 
Seminar on Drinking Water Protection performed on 21/01/2016 
Evaluation Study finalised and published: http://www.safe2drink.eu/  
Stakeholder Consultation on Annex I Parameters 22/09/2016 
Drinking Water Revision included in Commission Work Programme 
2017, COM(2016)710 final 
Evaluation SWD (2016) 428 published on 01/12/2016 
Inception Impact Assessment Published, 4 week Feedback 
Mechanism until 28/03/2017 
Impact Assessment Study published : http://www.safe2drink.eu/ 
Expert Group Meeting 27/03/2017 

50 

 
 
 
2017 

June 

Regulatory Scrutiny Board 

The  main  information  sources  for  this  Impact  Assessment  are  the  preceding  REFIT 
Evaluation  and  external  expertise  by  a  study  supporting  the  revision  of  the  EU  Drinking 
Water Directive, published in March 2017100.  

Quality  of  the  information  collected:  The  evidence  of  information  was  high.  The  Impact 
Assessment  builds  on  recent  evaluation  that  provided  in  particular  detailed  economic  data. 
Their  comprehensiveness  and  completeness,  their  accuracy,  and  their  reliability  were 
considered good. The methodology to forecast impacts was found robust. A model validation 
and sensitivity analysis has been carried out. The indicator "PPHR" has been compared with 
causal sick cases and could be correlated to ECDC information. The modelling assumptions 
were based on expert judgments, often validated by water practitioners. The choice of options 
was  intensively  discussed  at  a  specific  stakeholder  conference,  and  adapted  accordingly. 
Information on the data collection and on the stakeholder conference is available at the project 
website  "www.safe2drink.eu".  Moreover,  information  from  a  further  external  study  on 
materials  in  contact  with  Drinking  Water101  and  interim  information  from  the  cooperation 
project with WHO102 reviewing the parameters was considered. 

Usefulness of the information collected. The information collection was valuable. The data 
collected  and  modelled  for  the  Impact  Assessment  are  a  useful  basis  for  decision  making. 
They overcome the limited relevance of compliance data collected under the current reporting 
system of the DWD. This finding that the compliance reporting was not very significant will 
be considered in the in the decision-making process of the Commission and in the amended 
Directive  to  make  it  useful  for  different  purposes:  e.g.  future  evaluations,  infringement 
proceedings against Member States; enforcement action at regional/local level. Possible new 
indicators are listed in the monitoring Annex 6. 

2. Consultation of the Regulatory Scrutiny Board 

The Regulatory Scrutiny Board of the European Commission assessed a draft version of the 
present Impact Assessment report and issued a positive opinion with reservations on the 23rd 
of June 2017. The Regulatory Scrutiny Board made the following comments: 

(1) The scope of the impact assessment is unclear. It fails to explain to what extent it 
would address a number of identified problems through a revision of the DWD or 
rather  through  other  policy  measures  (e.g.  access  to  drinking  water  for  all; 
materials  in  contact  with  drinking  water;  underinvestment  in  water  infrastructure 
in general and water leakages in particular).  

100 
101 
102 

https://circabc.europa.eu/w/browse/96b5e7a3-81c3-46ed-b9fb-0204514028e4 
https://circabc.europa.eu/w/browse/0b93e708-5e20-4c35-8fbd-8554a87e7cb5 
Folder: https://circabc.europa.eu/w/browse/b6bb0d99-8c88-4b9d-9a14-68a0f2695e6d 

51 

 
 
 
                                                 
(2) The  report  does  not  clearly  explain  the  planned  process  of  selecting  the  list  of 
parameters  and  their  limit  values,  including  the  integration  of  the  most  recent 
scientific knowledge.   

(3) Further  considerations  and  adjustment  requirements:  (1)  Clarify  the  scope  of  the 
impact  assessment  and  corresponding  policy  actions;  (2)  Selection  of  parameters 
and  risk-based  approach,  (3)  Clarify  the  cost  estimates,  (4)  Elaborate  the 
comparison of options; and (5) Clarify monitoring arrangements. 

3. Follow-up  

Following  the  Board's  recommendations  for  improvement,  the  document  has  been  further 
amended, in the present version, as follows: 

1)  Clarifications on the scope of the impact assessment 

Regarding access to water: it has been clarified that considerations on access to water have to 
respect  the  Treaty  principles  of  neutrality  and  subsidiarity,  within  the  remit  of  the  EU's 
competence. The Impact Assessment was further aligned with the Communication replying to 
the ECI initiative (COM (2014)177). The costs and affordability of both options 5.1 and 5.2 
have been analysed, and option 5.1 concerning the full connection to the PWS systems for all 
has  been  eventually  discarded  from  further  analysis in  particular  as  in  some  Member  States 
affordability would be at stake. It has been clarified in the conclusions that Policy Packages 2 
and 3 are both valid choices. It has been clarified that option 5.2 is only one way to improve 
access  to  water,  but  that  flexibility  should  be  left  to  Member  States  so  that  alternative 
measures can also be envisaged that are assumed to be significantly less costly. Imposing the 
general  obligation  on  Member  States  to  improve  access  to  water  through  a  variety  of 
alternative measures seems appropriate but was difficult to assess in detail due to limited data.  

Regarding materials in contact with drinking water: The problem of obstacles to the internal 
market and how it would evolve has been clarified. It was made clearer that the current set-up 
does not ensure a fully-functioning mutual recognition system. This is now better reflected in 
the description of the baseline. This status quo would not change significantly in the future if 
the  flexible  Article  10  would  be  kept  in  the  Directive  without  being  complemented  by  the 
adoption  of  a  harmonised  standard.  It  is  also  explained  why  some  options  proposed  in  the 
Impact Assessment study have not been taken over in this Impact Assessment. It is also better 
clarified that the DWD is not the right instrument to propose product standardisation that is 
more  suitably  addressed  under  internal  market  legislation.  Option  3  is  however  maintained 
and  it  was  clarified  that  it  concerns  the  removal  of  an  obstacle  to  the  internal  market. 
Therefore, in its impact analysis the benefits of harmonised standards have been considered.  

Regarding underinvestment in water infrastructure in general and water leakages in particular, 
the  intervention  logic  has  been  amended,  as  discussed  during  the  hearing  on  23  June  2017. 
Water leakages are addressed under option 4.3 and the role of providing information on water 
quality and water management is explained more thoroughly. 

2)  Selection of Parameters 

52 

 
 
The report clarifies further how the process to review the parameters and the development of 
the risk-based approach has been performed. As the parametric standards set in Annex I are, 
according to Recital 16 of that Directive, generally based on the World Health Organization 
(WHO)  Guidelines  for  drinking-water,  their  adaptation  to  scientific  progress  follows  the 
recommendations  of  a  cooperation  project  with  the  WHO  Regional  Office  for  Europe.  The 
objective of the project was to provide policy-relevant advice to enable science-based input to 
inform  the  revision  of  Annex  I  of  the  Directive.  The  WHO  also  promotes  the  risk-based 
approach,  thus  also  providing  evidence  for  the  option  on  the  risk-based  approach  and  for 
making it mandatory within the EU. In addition, the extended list under option 1.2 is based on 
the precautionary principle, thereby sometimes leading to stricter values than proposed by the 
WHO. The Impact Assessment report clarifies further that the risk-based approach is a cost-
effective solution that does not entail risks to human health. 

3)  Further considerations:  

The  cost  calculations  have  been  made  more  precise.  Detailed  cost  estimates  on  policy 
packages as well as individual options have been added. Costs are displayed as set-up costs, 
operating costs, and changes in household costs to consumers. Standard tables with a cost and 
benefit  assessment  of  policy  packages  according  to  the  Better  Regulation  Guidelines  have 
been added to the Annex. 

The presentation comparing the options has been improved. The main table in section 7 on the 
ranking  and  consequent  comparison  of  options  has  been  adapted  and  amended.  A  simpler 
ranking  system  now  allows  a  clear  ranking  of  the  options  and  allows  for  a  straight-forward 
deduction of the most suitable options.  

Section 8 and Annex 5 on monitoring has been revised and aligned with the Better Regulation 
Guidelines  on  future  Evaluation:  success  indicators  e.g.  on  monitoring  results  in  cases  of 
exceedances  of  the  parametric  values  and  remedial  actions  taken,  or  on  information  on 
occurrence of incidents, have been included to address the Board's concerns.  

53 

 
 
 
 
9.2. 

Annex 2  

Synopsis report on the stakeholder consultation 

1. Introduction 
For  the  revision  of  the  Drinking  Water  Directive  (Council  Directive  98/93/EC)  several 
consultation activities in accordance with the Better Regulation Guidelines103 took place. The 
start of the consultation activities was marked by an open public consultation on the quality of 
drinking water in June 2014.  

In the consultations input from a wide range of stakeholders was sought with a focus on the 
main  objective  of  the  DWD,  namely  the  provision  of  high  quality  drinking  water  to  EU 
citizens. The focus in the consultations was on (1) the scope of the Directive, (2) the actual 
content of the Directive, namely the approach to monitoring and the parameter list, (3) new 
topics such as materials and products in contact with drinking water, as well as (4) improved 
contact with consumers when it comes to drinking water e.g. through information provision. 
During  the  various  consultation  activities,  stakeholders  also  had  the  opportunity  to  submit 
their views on concrete options that were developed for the IA.  

In line with the Better Regulation Guidelines104 and under consideration of the circumstances, 
the Evaluation and the Impact Assessment of the Directive were done back to back. Through 
the  open  public  consultation  and  follow-up  consultation  activities  it  was  ensured  that  all 
stakeholders were consulted and kept informed about the revision process. In this regard the 
broad  open  public  consultation  proved  very  valuable  as  during  the  process  of  preparing, 
conducting  and  evaluating  the  survey,  the  main  stakeholder  groups  were  identified. 
Consequently,  key  associations  acting  as  multipliers  served  to  ensure  the  systemic 
information  distribution  and  the  continuous  consultation  of  all  relevant  stakeholders.  The 
input and the feedback from the various stakeholders fed into the decision-making process for 
the revision of the DWD.  

In  this  document  an  analysis  of  the  contributions  of  the  stakeholders  is  summarised.  Some 
suggestions by stakeholders were, after careful consideration, regarded as being out of scope 
for the DWD but will potentially be addressed by other means. These included for example: 
water  supply  affordability,  encouragement  of  water  safety,  better  education  etc... 
Nevertheless,  all  topics  raised  in  the  consultation  activities  were  considered  to  be  highly 
valuable for informing the revision of the DWD. 

2. Stakeholder groups consulted for the revision 
In line with the assessment of relevant stakeholders that need to be considered for the revision 
of the DWD, the following ones were consulted: 

  Water Associations 

103 

104 

Notably toolboxes 10 and 50 on the 12-week internet-based public consultation and on the complement approaches 
and tools in order to engage all relevant stakeholders and to target potential information gaps, which was done by 
subsequent targeted stakeholder consultations. 
http://ec.europa.eu/smart-regulation/guidelines/ug_chap7_en.htm 

54 

 
 
                                                 
  Member States in a targeted consultation since 2015 and regularly through the Expert 

 

Group  
Industrial  associations  from  various  sectors  that  are  related  in  their  activities  to 
drinking  water,  or  that  identify  themselves  as  being  concerned  by  a  revision  of  the 
DWD 

  Non-governmental  organizations  related  in  their  activities  to  consumer  protection, 

nature, environmental protection, human rights etc.  

  Citizens of the European Union 
 
  Other EU institutions (EEA, EFSA, EESC…)  

Interest groups such as scientists, professional and experts in the field, academics etc. 

All of the above mentioned stakeholders provided significant input that supported the revision 
activities conducted by the Commission services. Particularly relevant was also the support by 
the WHO as well as contacts with those supporting the Right2Water initiative.  

3. Approach to consultation and inclusion of other information sources 
The revision process of the DWD was triggered by the ECI Right2Water105. It considered the 
REFIT  approach  by  the  European  Commission.  A  further  important  source  was  the 
"safe2drink.eu" project that supported the Commission with the analysis of consultations.  

For  the  open  public  consultation  5908  answers  and  138  opinions  were  received  as  well 
position papers from key stakeholders.106 Roughly 88 % of the responses came from citizens 
and the remaining 12 % were submitted by stakeholders such as institutions or experts in the 
field. In addition to citizens' answers to the online survey, 80 EU citizens sent detailed emails 
in  response  to  the  consultation.  Responses  came  from  all  EU  countries;  however  some  MS 
were  over-represented  (Germany,  Austria,  Portugal,  Cyprus  and  Ireland  when  compared  to 
their respective population share). Other MS such as Poland, Denmark, the UK, Sweden and 
Estonia were underrepresented. This imbalance was corrected in the analyses of the answers.   

Apart from the open public consultation, which lasted from June 2014 until September 2014, 
several  other  consultation  activities  were  carried  out  to  ensure  that  all  relevant  stakeholders 
can contribute to the revision:  

In  September  2014  and  in  October  2015  Stakeholder  Dialogue  on  Transparency  and 
Benchmarking launched, two dialogues were performed107.  

A targeted public stakeholder consultation conference reaching a wide range of stakeholders 
including  national  and  regional  authorities,  representatives  of  industry  and  business 
associations,  as  well  as  companies  and  experts  was  organised  in  May  2015  for  the  REFIT 

105 
106 

107  

http://www.right2water.eu/node/37/view 
Consultation Report 
https://circabc.europa.eu/sd/a/0070b535-5a6c-4ee4-84ba-6f6eb1682556/Public%20Consultation%20Report.pdf 
Summary Report: https://circabc.europa.eu/w/browse/4fa04ec0-2b16-409a-b5b1-edbb6ffd6287 

55 

 
 
 
                                                 
Evaluation.  A specific internet-based Consultation page108 was created and stakeholders had 
more than three months to submit their input and feedback. Important documents were further 
publicly available in a specific folder on the Commission's data repository CIRCABC109. 

A  further  Stakeholder  Conference  on  the  review  and  on  possible  options  took  place  as  a 
public  hearing  in  December  2015  for  which  a  background  document110  was  distributed 
beforehand.  At  the  conference,  a  specific  questionnaire/  evaluation  form111  was  handed  out 
and  electronically  issued,  and  all  presentations  and  minutes  including  participants  list  were 
made publicly available.112 This conference also targeted a wide range of stakeholders. 

In the beginning of 2016, Member States were contacted digitally for their input and had time 
until May 2016113 to respond. In total 15 responses to the questionnaire and 16 position papers 
were  registered, simultaneously a seminar  on drinking water protection was held in January 
2016. 

The  Commission  co-organised  with  WHO  a  large  stakeholder  consultation  on  the  drinking 
water  parameters  on  23  September  2016  in  Brussels.  This  conference  aimed  at  collecting 
input to adapt the drinking water standards to scientific and technical progress. Draft versions 
of the report were made available before and are publicly accessible114. At the conference the 
underlying rationale and preliminary findings of the project, including possible proposals for 
the  revision  of  Annex  I  of  the  Directive,  were  presented  and  discussed.  In  addition  to  the 
feedback received during the consultation, all Member States and stakeholders were invited to 
submit written feedback on the draft background papers presented at the consultation. Updates 
were  presented  to  the  Drinking  Water  Expert  Group  in  March  2017.  All  relevant  feedback 
was  considered  during  the  preparation  of  the  WHO  report.  A  detailed  annotated  log  of  the 
feedback including comments on individual parameters is provided in Appendix 2 of the final 
WHO report. 

After  the  publication  of  the  Inception  Impact  Assessment  on  the  new  portal  on  the  Better 
Regulation Website on 28/02/2017 stakeholders had the opportunity to provide feedback until 
28/03/2017. The feedback mechanism registered 32 replies. These replies came again from a 
wide  range  of  stakeholders, 
industry 
representatives' as well environmental organisations and local authorities. 

including  citizens,  business  associations  and 

108 
109
110 

111 
112 
113 

114  

www.safe2drink.eu including a specific functional mailbox safe2drink@ecorys.com 
https://circabc.europa.eu/w/browse/3fccab4b-812d-46be-8efe-1f866cf556c5 
https://circabc.europa.eu/sd/a/ec261386-9b0c-4fd0-9037-
3db85070517b/DWD_stakeholder%20workshop_background%20document_final.pdf 
http://www.safe2drink.eu/dwd_stakeholder-workshop_evaluation-form/ 
http://www.safe2drink.eu/wp-content/uploads/2016/02/Meeting-report-8-12-2015.pdf 
https://circabc.europa.eu/sd/a/52c8b4f5-7df5-43fb-a573-
f00967a2e4f4/Item%208%20Review%20Draft%20Policy%20options%20for%20revision.pdf (see slides 15/16) 
https://circabc.europa.eu/w/browse/b6bb0d99-8c88-4b9d-9a14-68a0f2695e6d 

56 

 
 
                                                 
 
In March 2017 the Commission published the supporting Impact Assessment Study. After its 
publication stakeholders had the opportunity to provide their feedback from March until end 
of April 2017 to DG Environment.  

4. Summary results of stakeholder consultations 

In  the  following  chapter  the  analyses  of  the  stakeholder  consultations  are  summarised.  To 
present a complete picture of the input, feedback and ideas that were received, the summary is 
structured  according  to  topics115.  Divergent  opinions  from  stakeholder  groups  as  well  as 
interdependencies,  consistencies  or  contradictions  among  groups  are  pointed  out  where 
deemed necessary. Generally it can be said that the DWD is considered to be a relevant part 
of  the  EU  legislative  framework  to  ensure  the  protection  of  the  consumer.  Nevertheless, 
considering the age of the DWD, the aim of revising the DWD is in general supported by all 
relevant stakeholders.  

Firstly, some key examples from the report on the open public consultation are presented. The 
consultation  clearly  supported  the  update  and  revision  of  drinking  water  parameters.  The 
responses  highlighted  the  following  threats  of  pollution  from  agriculture,  from  industrial 
sources,  and  from  human  consumption  and  inadequate  waste  water  treatment.  Additionally, 
the consultation also asked about further aspects and possible policy options. The responses 
support harmonised materials in contact with drinking water, incentives to save water, and to 
cover the entire supply chain. A strong message from the consultation, especially mentioned 
by EU citizens, was the wish for more up-to-date online information.  

Overview of the main topics addressed by stakeholders in the consultation activities  

Quality of drinking water and current monitoring activities 

The  main  threats  to  the  quality  of  drinking  water  were  seen  in  'pollution  from  agriculture' 
(especially from MS: DE, CZ, UK-Scotland) and from 'industrial sources', a bit less but also 
perceived  as  very  threatening  is 
'pollution  through  exploitation  and  exploration  of 
hydrocarbons'. Stakeholders and experts perceive a higher threat to quality of drinking water 
than citizens as is visible from the open public consultation.  

Stakeholders agreed that the current DWD is not effective enough regarding the protection of 
human health from certain microbiological substances such as legionella. For monitoring and 
transparency  provisions  a  variety  of  approaches  were  suggested.  Some  MS  and  water 
suppliers/associations (BE, CZ, FR, NO and UK; EurEau, WHP, United Utilities, Dwr Cymru 
Welsh  Water,  CC  Water)  favour  a  risk-based  approach.  From  those  who  have  responded  to 
the  stakeholder  consultations  only  the  Baden-Württemberg  municipalities  (DE)  support  the 
current approach in scope and frequency.  

115 

As  also pointed  out in  the  analysis of  the open public consultation  survey,  many  respondents  did not 
specify their institution or sector, and therefore a structure according to topics rather than stakeholder 
groups was preferred. 

57 

 
 
 
                                                 
Furthermore,  alignment  and  consistency  among  EU  legislations  (i.e.  the  WFD,  the 
Groundwater  Directive,  and  the  Construction  Products  Regulation)  is  crucial  to  avoid 
unnecessary  administrative  burden,  also  with  regard 
to  monitoring  and  reporting 
requirements.  If  there  is  insufficient  harmonization  between  standards,  water  supply 
companies are forced to use more treatment than actually needed. 

Risk-based approach 

Risk-based  approaches,  for  example  implemented  by  water  safety  plans  are  considered  to 
deliver  key  complementary  elements  for  the  provision  of  safe  drinking  water.  Many 
stakeholders  argued  that  guidelines  on  details  of  risk  management  should  be  developed. 
Regarding  a  change  in  the  monitoring  method,  the  inclusion  of  all  stakeholders  is 
indispensable: for example also communication with consumers appears to be very important 
in the context of risk management, as consumers might otherwise perceive flexibility as less 
safety in their drinking water. When developing and implementing water safety plans, better 
cooperation with authorities working with the Water Framework Directive (WFD) and better 
interaction  with  its  implementation  will  be  a  crucial  element  for  protecting  drinking  water 
from source to tap.  

Parameters and emerging substances 

In all consultation activities the need for revising and extending the list of parameters in the 
DWD were mentioned by the entire range of stakeholders. From a Member States perspective, 
some  were  clearly  in  favour  of  an  extended  list  (e.g.  Denmark,  Malta,  Cyprus  and 
Luxembourg),  whereas  others  do  not  want  to  see  a  price  hike  arising  out  of  a  too  broad 
extension  (e.g.  GR,  ES,  HR).  Only  a  couple  of  stakeholders,  namely  Baden-Württemberg 
municipalities (DE) and Vienna Water (AT) argue that the status quo is sufficient. From those 
who have responded to the stakeholder consultations French and English farmers opposed the 
unnecessary  stringent  regulations  and  changes  to  the  DWD.  A  focus  and  support  for  closer 
monitoring  was  seen  by  a  large  majority  of  stakeholders  for  endocrine  disruptors  (87  %), 
pharmaceuticals  (85  %),  substances  used  in  consumer  products  (87  %)  and  faecal  matter, 
pathogenic  germs,  parasites  and  viruses  (81  %).  This  strongly  supportive  feedback  for  the 
revision  of  the  parameter  list  was  used  as  the  basis  for  the  establishment  of  a  cooperation 
project with the WHO.  

On  emerging  substances,  some  stakeholders  mainly  from  water  suppliers  but  as  well  from 
Member States authorities suggested that the DWD should not regulate these substances, but 
define firstly approaches on how to deal with them. However, many stakeholders also invoked 
the need for keeping the Precautionary Principle as the leading principle in this regard.  

Materials and products in contact with drinking water 

Early  on  in  the  consultation  activities  the  topic  of  materials  and  products  in  contact  with 
drinking water was raised. Generally stakeholders from business associations as well as from 
consumer associations and from authorities argued in favour of the harmonization of materials 

58 

 
 
and  products  in  contact  with  drinking  water.  From  Germany  a  proactive  campaign  for  this 
topic  was  visible  in  the  51  individually  submitted  but  content-wise  same  answers  to  the 
survey of the open public consultation. 

On materials and products in contact with drinking water a common methodology should be 
developed, as indeed the current situation prevailing appears unsatisfactory116 as was stated by 
business associations. According to the business associations this would lessen the burden on 
companies  and  strengthen consumer  and health protection. Further considerations should  be 
based  on  the  results  of  the  ongoing  assessment  within  the  study  commissioned  by  the 
Commission.   

Access to and content of information for the consumer 

About  58.5  %  of  the  EU  citizens  that  responded  to  the  open  public  consultation  see 
themselves as being generally well-informed; however, this varies strongly depending on their 
origin  MS117.  Almost  all  stakeholders  mentioned  either  via  responding  to  the  survey  or 
through  other  forms  of  feedback  (i.e.  direct  emails)  their  wish  for  more  up-to-date  online 
information on the quality of drinking water.  

Regarding the content, information on how analyses are performed and on parameter values is 
wished for in general. Stakeholders do not have a convergent view on the depth and width of 
information  they  wish  for,  but  do  agree  that  online  publication  is  an  adequate  way.  Some 
water  suppliers  and  other  business  associations  are  against  the  supply  of  too  much 
information. Generally the use of new technologies for the distribution of information seems 
to be supported by stakeholders from MS, institutions, expert backgrounds etc.  

This triggered the decision-making process of including the provision of smart information as 
a option in the Impact Assessment.  

Consumer confidence in drinking water 

All  stakeholders  agreed  that  efforts  are  required  to  boost  consumer  confidence  in  drinking 
water quality. Upon the question of a ‘water quality label’, such a label may not be compared 
with  existing  energy  consumption  labels,  as  indeed  for  drinking  water  limit  values  are 
established – making the term ‘safe drinking water’ operational in numerical values. Positive 
experience with a drinking water App has been reported from Portugal.  

116 

117 

Article  10  “Quality  assurance  of  treatment,  equipment  and  materials  Member  States  shall  take  all 
measures  necessary  to  ensure  that  no  substances  or  materials  for  new  installations  used  in  the 
preparation or distribution of water intended for human consumption or impurities associated with such 
substances  or  materials  for  new  installations  remain  in  water  intended  for  human  consumption  in 
concentrations  higher  than  is  necessary  for  the  purpose  of  their  use  and  do  not,  either  directly  or 
indirectly, reduce the protection of human health provided for in this Directive; . . . . .”   
The  range  of  satisfaction  with  the  level  of  information  about  the  drinking  water  quality  by  countries 
varies  significantly  from  18  %  Luxembourg  to  as  high  as  85  %  for  Austria  (see  Public  Consultation 
report by Ecorys, p. 29) 

59 

 
 
                                                 
Access to drinking water 

Although  most  citizens  that  replied  to  the  open  public  consultation  believe  that  they 
themselves have good access to drinking water, this is not the case for all, in particular for the 
poorer  segment  of  the  population  (‘bottom  40  %’).  Access  to  drinking  water  could  be 
addressed in an approach similar to the one already existing on waste water, i.e. an obligation 
for  Member  States  to  provide  their  citizens  with  safe  drinking  water.  With  the  idea  of 
providing access to drinking water initially brought forward by the ECI Right2Water118, also 
during the process of the consultations especially citizens stressed the importance for having 
access to water as a human right.119 The results of the open public consultation have shown 
that supporters of the ECI Right2Water submitted 186 times the same text to the survey and 
provided 41 position papers with the same text to cement their position.  

The access to water is generally seen by stakeholders across the line as important, however, 
many wish for national approaches to this, also under the consideration that some MS already 
have  legislation  in  this  regard  in  place.  In  this  context,  the  scope  of  the  DWD  was  often 
discussed. Many stakeholders, both institutions and citizens, stated that right to water issues 
should  be  considered  exclusively  under  the  human  right  approach,  that  water  should  be 
regarded  as  a  public  good,  not  as  a  commodity,  and  all  taxes  for  the  water  services  should 
work  on  the  principle  of  cost-recovery  (EPHA  (INT),  UGT  (ES)),  Unite  the  Union  (UK), 
EPSU  (INT),  United  Services  Union  (DE),  Irish  Coalition  against  Water  Charges, 
Stakeholders (SK), CA (UK), EFFAT (INT)). 

Further topics raised in the consultations 

Recurrently, in different consultation activities, the following topics were raised. These were 
also consequently explicitly or implicitly addressed or taken up in the IA: 

  Business  associations  from  the  bottled  water  industry  were  surprised  about  the  link 
between the circular economy and the DWD and stress that no discrimination against a 
healthy  product  such  as  bottled  water  should  be  attempted  and  that  further  the 
environmental impact of bottled water is scientifically unfounded. 

  Regarding  the  improvement  of  efficiency,  benchmarking  is  considered  an  important 
element of efficient water management. However such benchmarking should be done 
at  national  /  regional  level  and  not  EU-wide  (argument  mainly  made  by  Member 
States).  

  On reporting for small water supply zones no consensus among stakeholders is visible: 
whereas some do not want to impose reporting obligations, others see an urgent need 
to  do  so.  The  administrative  burden  for  small  water  supplies  has  to  be  considered: 
Small supplies should not directly report, but the data could be assembled at regional 

118 
119 

Right2Water European Citizens' Initiative with more than 1.6 million signatures. 
https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-1061434/feedback_en 

60 

 
 
                                                 
or  national  level  before  being  reported  to  the  Commission.  New  technologies  and 
approaches  would  need  to  be  used,  along  the  lines  already  established  for  bathing 
water and waste water data. 

Responses from National Parliaments  

The  French  National  Parliament  submitted  a  position  paper  in  the  time  frame  of  the  open 
public consultation. The French Parliament regretted that the questionnaire did not explicitly 
ask a question about the right to water and sanitation.  

The main comments on the Impact Assessment Study by stakeholders were: 

  Public  operators  have  questions  on  transparency  and  SMART  information  –  they 
mainly fear comparisons of costs as they could not reflect those associated with their 
public mission;  

  Bottled  water  industry  contested  that  consumption  of  bottled  water  is  used  as  an 

indicator for confidence in tap water.  

  Stakeholders  representing  the  industry  as  well  as  Member  States  call  for  the 
harmonization of materials and products in contact with drinking water (Article 10 in 
the existing legislation). The lack of harmonization is perceived as an obstacle to the 
internal market.  

  Some stakeholders have misunderstood the meaning of the theoretical health indicator 

used for modelling in the IA.  

5. Conclusion 
Stakeholders from Member States and industry showed support for the existence of the DWD 
and agreed that, although not necessarily quantifiably, the DWD supported and still supports 
the  improvement  of  the  drinking  water  quality  in  the  EU.  Most  stakeholders  from  all 
backgrounds support in general the revision of the DWD especially regarding parameters and 
new  monitoring  approaches  under  the  provision  that  costs  and  benefits  are  considered 
throughout  the  revision  process.  Stakeholders  from  agriculture  however  argued  against 
strengthening parameters related to agriculture like nitrate and pesticides.  

Closer  unity  among  stakeholders  can  be  found  on  the  topic  of  expanding  the  list  of 
parameters. Except for a few exemptions, many are in favour for including more substances in 
the list, as well as revising the thresholds provided for the already included substances. This 
clear support was taken up by the Commission services and throughout the revision phase. A 
project cooperation with the WHO ensured that the developed parameter list relies on highest 
scientific  standards  without  losing  sight  of  underlying  EU  approaches  to  risks,  such  as  the 
Precautionary Principle.  

Stakeholders  representing  the  industry  as  well  as  Member  States  have  called  for  the 
harmonization  of  materials  and  products  in  contact  with  drinking  water  (Article  10  in  the 
existing  legislation).  The  lack  of  harmonization  is  perceived  as  an  obstacle  to  the  internal 

61 

 
 
 
market.  This  topic  was  consequently  discussed  and  approached  together  with  DG  GROW 
under the Regulation for Construction Products. 

All of the topics raised by the stakeholders were considered throughout the Evaluation and the 
Impact  Assessment  and  informed  thereby  the  decision-making  process  of  the  Commission 
service. Through the manifold consultation activities that took place over the revision phase, it 
was possible to re-discuss topics with stakeholders, clarify positions and to reach consensus 
on many items. 

62 

 
 
 
 
Appendix 1 to Annex 2: Highlights of the Public Stakeholder Consultation 

Firstly, some key examples from the report on the open public consultation are presented. The 
Figures  below  give  examples  of  how  Impact  Assessment  related  questions  on  the  problem 
definition  and  on  improvement  options  were  considered  already  at  an  early  stage  of  the 
consultation  process.  Thus,  the  consultation  covered  all  elements  supporting  a  systematic 
evaluation and impact assessment in accordance with the 'better regulation' principle.  

The consultation clearly supported the update and revision of drinking water parameters, see 
figure below. This led to a further Impact Assessment option and the work is supported by a 
cooperation project with the WHO (Option 1).  

Figure 15: Results open public consultation: focus for parameters 

With  regard  to  the  problem  definition,  the  responses  highlighted  the  following  threats;  see 
figure  below.  These  problems  and  how  they  will  evolve  have  been  assessed  in  the  problem 
definition and the baseline scenario. 

Figure 16: Results open public consultation: Threats to be considered 

63 

 
 
 
 
Additionally,  the  consultation  also  asked  about  further  aspects  and  possible  policy  options; 
see figure below. The conclusions are taken up by the Commission Services. The option with 
the  highest  rate  on  materials  in  contact  with  drinking  water  is  for  example  followed  by  a 
specific  option  and  by  further  standardisation  activities  on  construction  products  by  DG 
GROW (Option 3).  

Figure 17: Results open public consultation: Suggested options120 

A strong message from the consultation, especially mentioned by EU citizens, was the wish 
for  more  up-to-date  online  information.  This  request  has  been  considered  and  further 
developed into  a  option ensuring smart  information to  drinking  water consumers, see figure 
below (Option 4). 

Figure 18: Results open public consultation: Demand for information 

120 

HAACP 

64 

 
 
 
 
                                                 
Appendix 2 to Annex 2: Synopsis report on the stakeholder consultation 

Concerns raised by stakeholders 

Who121 

Concern 

Argument 

It should be regulated at Member State level, 
Implementation can be costly (although it should be covered on EU level) 

  Access to water should not be in the scope of the DWD 
 
 
  Cannot be solved through provision of SMART information  
  Some values already too precautionary without being based on scientific evidence 
  MS already set stricter standards than the ones in the Annexes 
  Flexibility needs to be ensured for cases of emergency 
  Many want to see WHO list first before making a statement 

BDEW,  UBA,  EurEau, 
AquaPublica, 
CEEP, 
NL 

Access to 
water 

Parameter list 

Vewin,  NL,  Northern 
UBA, 
Ireland, 
National 
Farmers 
Union 

Suez, 
EurEau, 
AquaPublica,  Poland, 
NL,  VKU,  National 
Union, 
Farmers 
BDEW 

Option 4.2 and 
4.3 

  Benchmarking is out of scope of DWD 
  Details of options are unclear. Some information can be provided such as quality, frequency, 
sources, quantities of abstraction; an incident etc., but is the consumer capable of using this 
information to interfere with management decisions? 

  Oversimplified that more information leads to high management efficiency 
  4.3 generally goes too far 
  Too much information might lead to uncertainty among consumers  
 

Information should be more tailored to audience (i.e. differentiate professionals and 
consumers).  

BDEW,  Aqua-Publica, 
CEEP,  Vewin,  VKU, 

Risk-based 

  Unclear how the risk-based approach should look like 
  Unclear how RBA affects pollution at source 

121  

These tables provide just a short and distilled indicative overview of the stakeholders' various opinions. Many of the stakeholders have very detailed ideas of what is 
acceptable and what is not.  

65 

 
 
                                                 
Sweden's' 
authorities, Vivaqua 

local 

approach 

Indicator of 
bottled water 

FIEB-VIWF,  European  
&  French  Federation 
of  bottled  waters, 
Hydration 
Natural 
Council 

Aquapublica, 
NL, Vewin 

CEEP, 

PPHR 

Supportive points raised by stakeholders 

  Subsidiarity and flexibility need to be considered 
  Argument does not reflect sufficiently positive impact on environment 
  Shifts responsibility too much to local suppliers 
  Using bottled water as an indicator is inappropriate 
  Bottled water is not as bad for the environment as always said,  
  This industry provides loads of local jobs, 
  Limiting the choice of consumption for drinking water is detrimental to efforts to make people 

drink enough.  

  Underlying assumptions are arguable, at times unreliable and sometimes inaccurate  

Who 

Support 

Argument 

  Supportive because mutual recognition is important for internal market functioning 
  Wish for harmonisation of regulatory frameworks across Member States, 
  4MS approach should be taken into consideration,  
  Harmonization will lead to equal levels of consumer protection across the Member States  

Option 3: 
Harmonisation 
of materials 
and products 
in contact with 
drinking water 

BDEW,  UBA,  CCE, 
CEEP, 
Auqapublica, 
Vewin,  NL,  German 
Ministry, 
Health 
Northern 
Ireland, 
European  Consumer 
representation 
in 
standardization, 
PlasticsEurope, 
many others  

and 

ENDWARE, 
RIWA, 
UBA,  CCEE,  CEEP, 

General 
harmonization 

  Almost all stakeholders support that the amended/new DWD is to be more harmonized with the 

WFD, its daughter directives and other EU (environmental but also other) legislations 

66 

 
 
Carbon 
project, etc.  

disclosure 

with other 
legislation 

CEEP,  VKU,  Sweden, 
Health  care  without 
harm, IDEXX 

ENDWARE, 
UBA, 
EurEau, CCE 

SUEZ, 
Sweden, 

Updated 
parameter list 
in line with 
scientific and 
technological 
standards 

Inclusion of 
mandatory 
risk-based 
approach 

AquaFed, 
Veolia, 
disclosure project 

Suez, 
Carbon 

Provision of 
transparency 
& information  

Individual 
CEE,  Nalco, 
Veolia 

citizens,  
SUEZ, 

Inclusion of  

access to 
water 

Suez, Danfoss, Danish 
Environment 
technology 
Association 

Addressing 
leakages 

  Precautionary Principle should be leading (also when considering WHO's list) 
  New list should include endocrine disruptors, pharmaceuticals, legionella 
  New list should be simplified (Sweden) 
  Adaptation to new scientific & technological standards is highly supported 

  Good approach, (as long as flexible enough for Member States) 
  Supports the sharing of information among different authorities that govern water, which is 

highly important 

  Works well with a good parameter list 
  Responsibilities under RBA should be clear 
  General support for more transparency and information to consumers,  
  Support for the use of IT tools for the distribution of SMART information to consumers 

  Access to water should be embedded in DWD 
  For the poorest, ad-hoc solutions such as social tariffs should be found 
 
It is a human right and the EU should stand up to its commitments.  
  5.2 is acceptable as long as MS have flexibility of how to do it 
  Sustainable management of drinking water should be more targeted (could be done via 4.3) 
  Support a recital on link between protection of drinking water resource and potential to reduce 

water leakage 

67 

 
 
 
 
9.3. 

Annex 3   Who will be affected by the preferred policy packages and how?  

The  following  annex  presents  the  main  impacts  for  citizens/consumers,  supplier/water 
industry/operators, and public authorities. Impacts  on SMEs have  been analysed in detail in 
chapter  5.2.5. The preferred Policy Packages 2 and 3 will  have  an impact on all considered 
stakeholders. 

Citizens/consumers 

The main impacts of the preferred policy combination for an EU citizen will be the reduction 
of the chance of being at risk (PPHR); this and additional costs and benefits concerning the 
average EU citizen are pointed out below: 

– 

– 

– 

– 

– 

– 

Health  benefits/ (costs)  associated with  that:  In  total  it is  expected that  through the 
ambitious packages the population at health risk would be reduced by 15.3 (PP2) or 
even 15.9 (PP3) million inhabitants by 2050 (reducing the risk for 76 % (PP2) or 79 
%  (PP3)  of  the  EU  population);  Most  positively  affected  from  PP2/3  regarding  the 
health benefits are Bulgaria, Luxembourg, Malta, Greece and Spain.  

Increase  of  household  cost  and  affordability  of  water  services:  The  total  cost  per 
household will increase for PP2 by EUR 7.90 or for PP3 by EUR 10.40 per year. For 
the individual and average EU citizen drinking water will constitute 0.75 % (PP2) or 
0.76 % (PP3) of the disposable income. For the lowest income group drinking water 
will constitute 1.05 % (PP2) and 1.06 % (PP3) of the disposable income. 

Employment will increase by 17 038 persons through the impacts of PP2 and by 25 
964 for PP3, mainly to be seen in the UK, France and Germany.  

Through the access to better information, an increase in confidence in drinking water 
is  expected,  leading  to  a  decrease  in  purchases  of  bottled  water.  With  the 
implementation  of  PP2/3,  (costs)/  savings  from  bottled  water  purchase  will  be 
achieved as consumers will develop more confidence in drinking water. The overall 
decrease in costs for bottled water is expected to be EUR 610 million.  

EU citizens will benefit in the long-term from resource efficiency/ use of water, an 
impact that is arises through the application of Option 1.2 and Option 2.2 in PP2/3. 

PP3 would positively impact non-connected citizens through providing some of them 
with access to drinking water.  

Suppliers/operators 

Water  suppliers  will  be  most  affected  by  costs  for  monitoring  and  additional  treatment 
(Option  1.2  as  contained  in  PP2/3).  Overall  it  is  expected  that  PP2  leads  to  set-up  costs  of 
EUR 5 923 million and PP3 to EUR 7 337 million. Total annual treatment costs increase for 
PP2 by EUR 1 651 million and for PP3 by EUR 1 660 million. However, the application of 
the  RBA  (Option  2)  and  the  hazard  assessment  of  abstraction  areas  will  in  the  longer  term 

68 

 
 
avoid  unnecessary  monitoring  and  treatment.  These  changes  in  monitoring  and  treatment 
activities  are  assumed  to  lead  to  the  need  of  finding  new  ways  of  management  in  water 
companies  as  well  as  the  need  for  more  training.  As  option  4.3  requires  the  suppliers  to 
provide substantially more information to the consumers, water suppliers have to improve the 
way  they  use  modern  technology  and  work  on  the  establishment  of  a  clear  communication 
channels  with  their  customers.  PP2/3  is  also  anticipated  to  have  a  positive  impact  on 
innovation (new monitoring, new data management).  

Especially  option  3  will  have  a  positive  impact  for  suppliers  of  materials  and  products  in 
contact with drinking water as tendering will become significantly easier and cross-MS trade 
will increase. However, certification and testing institutes in the same Member States can be 
expected to lose business as new materials would have to be tested only once to be accepted 
throughout the EU, which can then also be done in other Member States. 

Public authorities 

From the perspective of authorities, an important challenge will be  the shift to the RBA for 
health authorities. The introduction of the risk-based approach will require additional time and 
effort  for  setting-up  the  new  approach,  as  the  assessment  of  hazards  can  be  demanding  and 
requires a different skill set than the existent one. This also entails that more human resources 
will be needed to follow up on the new approach and on compliance. Another impact relates 
to the reduction of administrative burden through simplified reporting (Option 4.3). However, 
there  will  also  be  a  need  to  widen  existent  expertise  on  health  and  water  to  support  the 
implementation of ption 4.3 and to monitor the effects.  

Figure 19: Scheme of the drinking water system 
69 

 
 
Also  public  authorities  will  feel  the  impact  of  option  3  as  it  will  be  easier  to  implement  as 
there no longer the need for separate standardization procedures to be established by each MS.  

Figure 19 above provides further background on the drinking water scheme, who is involved, 
and who is affected. 

70 

 
 
Cost – benefit assessment of policy packages 

Title: Proposal for a Directive of the European Parliament and of the Council amending Council 
Directive 98/83/EC on the quality of water intended for human consumption (IA) 

PP2/PP3 

PP3 

SUMMARY OF COSTS AND BENEFITS 

I. Overview of Regulatory Costs – Preferred Option(s)122 

Consumers 

Businesses=Water operators123 

Administrations 

Set-up costs 

Recurrent 

(increase/decrease 
in  baseline  2050 
household costs) 

Set-up costs 

Annual 
costs 

operating 

Set-up costs 

Annual 
costs124 

operating 

122  

123  

124  

Costs of preferred option(s) as compared to the baseline. The baseline 2050 assumes yearly operating costs of EUR 47.9 bn and annualised set-up costs of EUR 1.9 
million. All figures provided in the table are additional costs or savings compared to the Baseline 2050. 
Businesses in this case are Water Operators. They can be public or private or a mixture of both. It is assumed that all costs that are incurred by water operators will be 
borne by the consumers through transfers to the water tariffs or taxes. Therefore, column 1 and 2 of this table look at the same costs but from two sides: consumers 
(cost displayed as costs per household) and water operators (costs for all EU operators).  
The tasks done by the administrations (mostly health authorities) relate mainly to surveillance and monitoring controls. The costs are marginal in comparison to the 
work of water operators. Annual recurrent costs are estimated at EUR 42.6 million per year (40h per large supply, 8h per small supply). No substantial changes to 
these costs are expected to occur through any of the proposed options except for options 2.2 and 4.1. 

71 

 
 
 
 
 
                                                 
1.2 Extended 
Parameter List 

Direct 
costs125 

Indirect 
costs  

EUR + 14.90/year 

EUR 5 895 million  

EUR 2 842 million 

Direct costs  No set-up costs 

EUR - 0.40/year 

EUR 25 million  

EUR -96 million 

EUR 6.25 million126 

2.2 RBA 
Mandatory for all 
water suppliers 

Indirect 
costs 

3 Harmonisation 
of materials; 
standards  

Direct costs   No set-up costs 

EUR – 3.20/year 

set-up 

No 
expected 

costs 

EUR  –  669  million 
Costs  reduction  for 
product 
manufacturers 
passed 
on 
consumers127.  

to 

125  
126  

127  

For details on cost components please see the attached glossary.  
Additional administrative costs for the RBA introduction were not quantified in the draft IA. Estimate in this table based on recent assumptions from Member States 
authorities: one-off administration time 5 hours for small, 20 hours for large supplies. Administrative costs do not include licensing/approval costs that are imposed 
on operators. One off EU costs estimated to 6.25 Million. No reduction in operational costs for authorities through option 2.2 assumed. 
Businesses in this field are in contrast to the other fields manufacturers of products/materials in contact with drinking water such as water pipes, taps, seals, etc. A 
specific  study related  to Option  3 on  the  testing  and  approval  of products in  contact  with  drinking water  looked into  internal  and external  costs.  It  estimates  that 
industry  has  around  60  Million  per  year  external  costs  for  approvals  procedures  which  could  be  saved  through  harmonization.  The  overall  and  internal  costs  are 
however much higher, as these includes savings related to product design and pre-testing etc. In the IA the overall annual savings was estimated at EUR 669 Million 
per year   

72 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
                                                 
 
Indirect 
costs 

4.1 Automatic 
reporting 

Direct costs 

EUR 2.9 million  

EUR - 0.352 million 

EUR  933 million   

The  decrease  of 
water 
bottled 
is   
consumption 
the 
in 
included 
costs. 
household 
The 
in 
water 
bottled 
will 
consumption 
nevertheless  remain 
minor  compared  to 
the market.  

changes 

packaging 
The 
industry  will  not  be 
significantly 
negatively  affected 
by  better  tap  water 
quality.    

4.3 Advanced 
access to 
information 

Direct costs 

No set-up costs 

EUR + 4.50/year  

through 
Savings 
less  purchases  of 
bottled water: 

EUR – 2.90/year 

EUR  5.6  million  (in 
to 
comparison 
baseline 2050) 

Indirect 
costs  

73 

 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                                                                                                           
 
PP2 (combined 
for measures 1.2, 
2.2, 3& 4.3)128 

5.2 Alternative 
self-supply 
systems and 
access in public 
places  

PP3 (combined 
for measures 1.2, 
2.2, 3, 4.3 & 5.2) 

Direct costs  No set-up costs 

EUR + 7.90/year 

EUR - 0.352 million  

EUR 1 349 million  (operating costs) 

EUR 5 925 million  

EUR 1 411 million  

EUR 60 million 

EUR + 2.50/year 

through 
Savings 
less  purchases  of 
bottled water: 

EUR – 0.40/year 

Direct costs   No set-up costs 

Indirect 
costs  

Direct costs 

 No set-up costs 

EUR + 10.40/year 

EUR 1 408 million (operating costs) 

EUR - 0.352 million 

EUR 7 354 million   

II. Overview of Benefits (total for all provisions) – Preferred Option (between PP2 and PP3) 

Description 

Amount 

Comments 

Direct benefits 

128  

Synergies are expected from  combinations of the individual options  

74 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
                                                 
Administrative cost reduction 

EUR 669M/year in costs savings due to reduction of administrative burden. 
Additional  marginal  savings  could  be  expected  from 
the  proposed 
simplification of reporting obligation for Member States  

Compliance cost reduction   

EUR 96M/year in cost savings compared to the baseline – due to a decrease 
in the number of tests. The annualised cost saving includes the amortised set 
up costs.  

Differentiation of set-up costs and operating costs: see glossary 

Compliance cost reduction 

EUR 0.40/year per household in cost savings due to overall decrease in water 
supply costs being passed on to consumers (due to option 2.2) 

FTE increase  

Overall  6,4  %  increase  in  employment  from  all options  under  PP3 (4,2  % 
under PP2) 

Costs  for  employment  were  included  in  the  costs 
figures and is therefore represented in all figures. 

N/A 

N/A 

N/A 

Unquantified (but small) benefit to IT providers of option 4.3  

Unquantified  benefit  for  companies  involved  in  the  creation  of  additional 
PWS (due to measure 5.2)  

Significant increase in water quality (PP2) and access (PP3) 

The  reduction of  bottled  water  purchases  is included 
in the assessment of the household costs. Under both 
preferred policy packages a decrease of purchases of 
bottled water  is  assumed  and  this  is  also reflected  in 
the household costs. 

Indirect benefits 

75 

 
 
 
 
 
 
 
 
 
  
 
 
 
  
Avoided health impacts 

EUR  285M/year  in  cost  savings  from  reduced  healthcare  costs  due  to  a 
decrease of illnesses related to contaminated water  

FTE increase   

Increase in employment of between 500-1000 FTEs due to innovation driven 
by option 1.2 

Description 

Amount 

Comments 

REFIT Cost Savings – Preferred Option(s) 

Administrative cost reduction 

EUR 669M/year in costs savings due to reduction of administrative burden 

Compliance cost reduction   

EUR 96M/year in cost savings compared to the baseline – due to a decrease 
in the number of tests. The annualised cost saving includes the amortised set 
up costs.  

In operating costs a saving of EUR 96 million is assumed 

Glossary to cost benefit table 

Item 

Set-up costs 

Component (depending on option) 

Life-span/ time frame of costs 

Risk-based approach implementation 

10 years 

Equipment for non-equipped citizens 

3 years 

76 

 
 
 
 
  
 
 
  
 
Automatic reporting development 

SMART information provision system 
development 

5 years 

5 years 

Distribution network extension 

30 years 

New monitoring and treatment equipment 

20 years 

Operating costs 

Monitoring or analysis 

Annual costs borne by water operators (and 
then transferred to consumer) 

RBA audit 

Treatment 

Distribution 

Additional preventative actions 

Information provision 

Reporting 

Other operating costs 

77 

 
 
Household costs (1 household equals 2.4 
persons) 

Operating costs 

Annualised set-up costs 

Yearly costs borne by consumers 

Only counting population connected to the 
public water supply system 

78 

 
 
9.4  

 Development  of  the  analytical  model  for  the  assessment  of  the 
Annex 4  
options,  underlying  assumptions  of  the  options  and  impacts  assessed  through 
application 

This Annex describes the methodology that was developed and used to assess the status quo 
and the different options. Among experts, it was agreed upon that there is a need to develop a 
new  indicator,  the  so-called  'People  at  Potential  Health  Risk'  (PPHR)  indicator.  The  PPHR 
was  developed  together  with  a  consortium  of  consultancies  led  by  Acteon.  Throughout  the 
stakeholder  consultation  activities,  the  indicator  has  been  presented  to,  and  was  discussed 
with  experts  in  the  field,  and  feedback  has  been  included  whenever  possible.  The 
development  of  this  indicator,  the  baseline  for  its  comparison  to  natural  developments  until 
2030 and 2050 and how the indicator was consequently used for the assessment of the options 
is explained in the subsequent sections.  

1. The need for a new indicator 

There  is  general  recognition  regarding  the  importance  of  safe  drinking  water  for  human 
health. At EU level no data is available regarding how many people turn sick after drinking 
contaminated  water,  but  outbreaks  occur  frequently.  Several  cases  collected  for  the 
Evaluation129  confirm  that  people  have  to  be  treated  for  diarrhoea,  vomiting  or  fevers  after 
drinking  tap  water.  A  recent  WHO 
the  pan-European 
assessment 
region130  estimates 
that  diarrhoeal 
diseases  still  cause  14  deaths  per  day 
due to inadequate water, sanitation and 
hygiene.  Renewed  momentum 
is 
therefore  needed 
these 
challenges (Figure 20). 

to  address 

for 

As no data is available to directly link 
EU  drinking  water  quality  with  EU 
human health effects, a specific health 
indicator  'Population  Potentially  at 
Health  Risk'  (or  PPHR)  has  been 
the  overall 
to  estimate 
developed 
impacts 
population 
today’s 
on 
potentially at health risk. According to 
this  methodology,  it  is  estimated  that 
22.7  million  inhabitants  (or  4  %  of 

Figure 20: Infographic WHO - 14 deaths per day 
due to inadequate water, sanitation and hygiene 

129 
See  Annex  C  Evaluation 
32ca8bfafe55/DWD-evaluation-report-2-Annexes.pdf 
130 

Study: 

The WHO pan-European Region comprises 53 countries including less developed countries from  
Albania  to  Uzbekistan;  therefore  the  figures  in  the  infographic  are  disproportionate  and  cannot  be 
transferred to the EU. 

https://circabc.europa.eu/sd/a/14e7ac5a-df84-42b8-9b6c-

79 

 
 
                                                 
the  EU28  population)  are  potentially  at  health  risk  today  because  of  potential 
contamination in water resources and drinking water. This theoretical health indicator is 
used  as  a  benchmark  to  assess  health  impacts  next  to  economic,  environmental  and  social 
impacts, and to assess whether there are possible options to tackle this EU health issue.  

1.2. The PPHR indicator 

The PPHR indicator (combining the low, medium and high risk categories) and the population 
marginally  at  health  risk  were  estimated  on  the  basis  of  assumptions  for  the  shares  of  the 
population exposed to different risk factors among which: being connected to a PWS or not, 
drinking  bottled-water  or  not,  being  supplied  by  a  water  operator  applying  RBA  or  not, 
having  access  to  water  potentially  contaminated  by  different  types  of  pollutants,  etc.. 
Depending on their exposure to different risk factors, the percentage of the population under 
each risk category (marginal, low, medium and high) was estimated as summarized in Figure 
21.  

Figure 21: Underlying scheme for the development of the PPHR 

To develop the PPHR, available data on population, connection rates to public water supplies, 
assumptions on the type and level of contaminants in water resources were used, as well as 
data  of  reported  illness  cases  that  could  be  due  to  the  consumption  of  drinking  tap  water 
collected by the European Centre for Disease Prevention and Control (ECDC). Through this 
the  health  indicator  'Population  Potentially  at  Health  Risk'  (or  PPHR)  was  defined  to 
capture  the  part  of  the  population  that  has  access  to  drinking  water  that  might  contain 
substances that can potentially cause health problems. The indicator PPHR was developed to 

80 

 
 
 
aggregate the overall impact of these different elements on today’s population potentially at 
health risk. The information refers to Annex 2 of the IA Study131. 

The above introduced PPHR analytical model explained how to best estimate the number of 
EU  citizens  currently  at  risk.  To  complement  that  model  and  make  a  link  between  the 
population  at  risk  and  societal  cost  related  to  being  sick  (or  not  sick,  thus  leading  to  health 
benefits) is needed.132  

1.3 Assumptions on today’s situation with regards to basic parameters used to estimate PPHR 

The following data points were used to constitute the basis for PPHR analytical model: 

  508 223 624 inhabitants (EU 28) 
  With 95 % connected to PWS 
  Each inhabitant drinks on average 106 litres of bottled water per person and per year – 

with 3 845 litres of tap water being used per person and per year 
 
It is assumed that 47 % of (large) PWS are applying already a RBA. 
 
It is assumed that current tap water quality is affected by contamination as follows: 
  7 % contaminated by substances listed in the current DWD Annex, with concentration 
above  the  WHO  parametric  values,  i.e.  not  complying  with  the  current  DWD 
standards 

  11  %  contaminated  by  substances  listed  in  the  current  DWD  Annex,  with 
concentration  below  the  WHO  parametric  values  but,  above  “precautionary”  limit 
values 

  4 % contaminated by substances from the new list under option 1.1 (see Annex 5, 2.1)  
among water distributed by water suppliers who apply an RBA; and 8 % among water 
distributed by water suppliers who do not apply a RBA 

  7  %  contaminated  by  supplementary  substances  from  the  new  list  under  option  1.2 

 

(Table 11, Annex 5) 
It  is  assumed  that  raw  water  (used  for  self-water  supply  in  particular)  is  affected  by 
contamination as follows: 

  9 % contaminated by substances listed in the current DWD Annex, with concentration 
above the WHO parametric values, i.e. not compliant with the current DWD standards 
  11 % contaminated by substances listed in the current DWD Annex,  substances with 
concentration  below  the  WHO  parametric  values  but  above  “precautionary”  limit 
values 

  10 % contaminated by substances from the new list under option 1.1  
  11  %  contaminated  by  supplementary  substances  from  the  new  list  under  option  1.2 

(Table 11, Annex 5). 

131 
132 

In: https://circabc.europa.eu/w/browse/52c9bdf7-9fbb-46da-aefe-1deea6311508 
Even though there is strong monitoring and control some EU citizens will still get sick when consuming 
drinking water. Being sick has both direct and indirect cost for society. 

81 

 
 
                                                 
1.4. Cost estimation related to cases of illness due to consumption of drinking tap water 

To  analyse  the  societal  cost  of  cases  of  illness  related  to  the  consumption  of  drinking  tap 
water we follow the four-step methodology depicted below: 

Number of 
drinking water 
related illness 
cases  

•Reported cases 

(ECDC) 

•Unreported cases 

Number of 
drinking water 
related illness 
cases  

•Reported cases 

(ECDC) 

•Unreported cases 

Attributability of 
drinking water to 
type of illness 

Attributability of 
drinking water to 
type of illness 

Number of days 
ill  

•Reported no. of 

cases 

•Unreported no. of 

cases 

Number of days 
ill  

•Reported no. of 

cases 

•Unreported no. of 

cases 

Societal impact 
of being ill 

• Cost of being ill per 
person/ MS/ type of 
illness 

• Total cost 

Societal impact 
of being ill 

• Cost of being ill per 
person/ MS/ type of 
illness 

• Total cost 

Figure 22: Four step methodology 

The European Centre for Disease Prevention and Control (ECDC) collects information from 
each MS regarding the yearly number of reported illness cases. This information is taken up 
for the years 2008-2012 in the Evaluation of the EU Drinking Water Directive study (Annex 
C). From this table one can observe that there are, on average, 17.000 reported cases of illness 
per MS that could be due to the consumption of drinking tap water. Furthermore, 86 % of all 
cases are related to a case of Campylobacteriosis and most of the reported cases stem from the 
UK (32 %).133 However, generally not all cases of illness are reported. An ill person does not 
always report to a general practitioner (in most cases since there is no need of urgency as he/ 
she is only ill for a short(er) period of time). As such, there is a need to estimate and include 
the  number  of  unreported  cases  of  illness.134  The  well  documented  case  of  an  outbreak  of 
Giardiosis  in  Norway  has  been  used  to  roughly  estimate  the  number  of  unreported  cases 
versus the number of reported cases (COWI, 2009). From this specific Giardiosis outbreak we 
are able to determine that on average there are 2.5 cases of  unreported illness (who are also 
much less longer sick) for each reported case. In this study this result is used as a proxy for 
the six main types of water related illnesses. 

Not all cases of illness taken up in the ECDC are due to consumption of drinking tap water. 
The ECDC reports the sickness of a person, but (logically) no information is known as to the 
cause  of  falling  ill  and  as  such  not  reported  on.  Based  on  an  extensive  literature  study, 
combined  with  expert  judgement  (in  case  literature  is  not  conclusive),  the  causal  attributed 
share of becoming ill due to drinking tap water is estimated.  

133 

134 

From discussion with experts we found that the UK scores very well when it comes to reporting this 
type of information to the ECDC. The 32% of reported cases might as such be an overestimation – or an 
underestimation for other MS; 
Note  that  we  do  not  take  underreporting  in  MS  into  account  the  numbers  from  the  ECDC  should  be 
seen as minimum number of actual cases of illness; 

82 

 
 
 
 
                                                 
The third step in our approach is to include the number of days a person falls ill in the case he/ 
she obtained a parasite/ virus/ other through the consumption of drinking tap water. This step 
is closely related to step two.135 The final step in assessing the current societal cost related to 
the  consumption  of  drinking  tap  water  is  related  to  the  (financial)  societal  impact  of  being 
sick, mainly related to  a combination  of healthcare cost (on average EUR 203 per day) and 
loss  of  productivity  cost  (on  average  EUR  93  per  day  (if  you  are  part  of  the  working 
population)).  

1.5. Causal attributable share and duration of cases of illness related to tap water 

1.5.1. Cryptosporidium and drinking tap water 

An infection of Cryptospridium has an incubation period of 7 to 10 days and the symptoms 
are in general diarrhoea. Infected people who have a well-functioning immunity system are on 
average  sick  for  2  to  3  weeks  (it  ranges  from  4  days  to  over  4  weeks).  In  case  an  infected 
person does not have a well-functioning immunity system (aids-, transplant-, cancer patients 
etc.) the infection can last up to months, become a chronic disease and even be fatal. Mortality 
is in general very low (<0.01 %), in case an infected person does not have a well-functioning 
immunity  system  chances  are  up  to  50  %.  Small  children  are  also  a  group  that  is  more 
affected by this type of waterborne infection. 

One  can  be  infected  by  Cryptosporidium  through  various  ways.  When  infected  the  cause  is 
often unclear. As such it is very difficult to show the contribution of drinking tap water to the 
reported  number  of  Crypto  cases.  One  can  however  make  estimations  using  the  QMRA 
approach. Sources of infection, related to drinking water consumption, are recreational water 
bodies,  swimming  pools,  drinking  water  sources  (river-  and  groundwater)  after  flooding, 
intense rainfall, meltwater and food. Small (private) water supplies can also be a source of the 
infection. 

There are several studies that use the QMRA method to empirically show the chance of being 
infected with crypto through drinking water: A Chinese  study estimated that the chance per 
100.000  people  is  8.31  x  10-6  (range  0.34-30.93  x  10-6)  DALY  per  person  per  year.  The 
findings of this study are higher than what is reported by the WHO and lower than the risk 
according  to  the  US  EPA.136  In  the  UK,  a  country  that  has  a  strong  focus  on  monitoring 
crypto, the risk of being infected is estimated at 50 % from swimming pools and 20 % from 
tap  water.  On  the  other  end  of  the  spectrum,  the  Netherlands,  no  cases  of  crypto  infection 
related  to  consumption  of  drinking  water  are  known,  meaning  that  the  method  of  water 
treatment  and/  or  quality  of  intake  are  important  factors  and  determine  the  number  of 
infections. For the EU 20% as upper limit is used.  

135 

136 

See  the  analysis  below,  where  for  all  six  drinking  water  related  sickness  the  approach  findings  are 
shown. 
The  burden  of  drinking  water  associated  cryptosporidiosis  in  China;  the  large  contribution  of  the 
immuno  -deficient  population  identified  by  quantitative  microbial  risk  assessment  QMRA.  Water 
Research volume 46 issue 13 September 2013 Shumin Xiao et. al. 

83 

 
 
                                                 
1.5.2. Campylobacteriosis and drinking tap water 

Campylobacteriosis  is  known  to  be  caused  by:  private  water  sources  and  rivers  (especially 
after  floods)  and  in  many  cases  it  is  carried  by  animals.  Other  contaminants  are  food, 
especially beef, chicken, various birds and shellfish, but also raw milk and vegetables.  

The  incubation  period  is  somewhere  between  1  to  7  days,  3  on  average.  When  infected  the 
patient will have diarrhoea for up to 7 days, and in 15 % of the cases the sickness lasts even 
longer.  The  chance  of  infection  through  drinking  water  is  roughly  5-10  %  and  is  mainly 
related to small(er) water supplies. 

1.5.3. E.coli and drinking tap water137 

There is a common misconception regarding E.coli in drinking water, as E.coli is in itself not 
leading to any infections. E.coli  is however  an indicator parameter for a range of infections 
closely related to  the E.coli bacteria, namely shigatoxic producing E.coli (STEC),  verotoxic 
producing E. Coli (VTEC) and enterohemorrargic E.coli (EHEC). An infection of these three 
types of E.coli is almost always related to food consumption (raw vegetables such as tomato, 
cucumber, but also meat).  

An infection of a type of E.coli bacteria is in most known cases not caused directly through 
the consumption of drinking water, but to some extent indirectly through the cleaning of food. 
For this study chances of infection are estimated to be in the range of 0-5% for Europe. The 
incubation period of E.coli is between 1 and 14 days, roughly 3-4. A patient is on average 4 
days sick when infected. 

1.5.4. Giardiosis and drinking tap water 

Giardiosis is an intestine infection caused by G.Lamblia. When infected, the main symptoms 
are  weight  loss  and  diarrhoea.  Overall  the  duration  of  the  infection  is  two  to  three  weeks, 
although in some cases it is reported to be longer and even chronic. In case a person is also 
infected by aids, underfed or elderly the infection can be fatal.  

One can be infected through drinking tap water, swimming pools, spas, open water bodies and 
in some cases also through food consumption. Overall infection is caused more often by open 
water when compared to groundwater sources. According to an American study 80 % of the 
infections are caused by untreated water.138 Based on expert judgment, it is estimated that the 
chance of being infected by consumption of drinking water is between 50 and 80 %. 

1.5.5. Shigellosis and drinking tap water  

137 
138 

According to the WHO, RIVM and the LCI guidelines for shigatoxic producing E.coli; 
Robertson LJ, Forberg T, Gjerde BK. Giardia cysts in sewage influent in Bergen, Norway 15-23 months 
after  an  extensive  waterborne  outbreak  of  giardiasis. J  Appl  Microbiol.  2008  Apr.  104(4):1147-
52. [Medline].  Ryu  H,  Alum  A,  Mena  KD,  Abbaszadegan  M.  Assessment  of  the  risk  of  infection  by 
Cryptosporidium  and  Giardia  in  non-potable  reclaimed  water. Water  Sci  Technol.  2007.  55(1-2):283-
90. [Medline]; 

84 

 
 
                                                 
In general Shigellosis patients are infected through consumption of drinking water and food 
that is washed by infected water. Based on expert judgment the attributability of drinking tap 
water  to  the  number  of  Shigellosis  cases  is  between  70  and  80  %.  Patients  infected  by 
Shigellosis are having diarrhoea after an incubation period of 1-7 days and it lasts between 4-
7  days.  In  select  cases,  it  has  been  reported  that  the  duration  extends  to  several  weeks. 
Normally being infected with Shigellosis is only fatal for the young, sick and elderly. 

1.5.6. Legionella and drinking tap water 139 

There  is  one  way  for  being  infected  by  Legionella,  namely  through  inhaling  of  aerosols  (in 
water vapour). Legionella causes a lung infection. Locations of infection are the shower, hot 
tubs,  saunas,  and  air  condition  systems.  The  consumption  of  drinking  water  does  not  cause 
Legionella. Legionella becomes dangerous if it can multiply, which happens if water stands 
still  for  a  longer  period  of  time  and  reaches  a  temperature  between  25  and  55  degrees. 
Mortality  rates  are  relative  high  compared  to  other  discussed  infections,  namely  2-10  % 
(although  often  elderly people).  The  value  of  a  life  is  set at  EUR  3.4  million.  Although  the 
number of mortal Legionella cases is low, it accounts for the highest social cost. 

The incubation period of a Legionella infection is 2 to10 days and an infected patient is sick 
from  2  days  up  to  several  weeks.  Based  on  a  discussion  with  RIVM  we  estimate  the 
attributability of drinking water (water vapour, i.e. showering) to be 60 to 80 % of the reasons 
for infection. 

Case 

Min 

Max 

Days sick 

Cryptosporidiosis 
Campylobacteriosis 
E.coli 
Giardosis 
Shigellasis 
Legionella 

0% 
0% 
0% 
50% 
70% 
60% 

20% 
5% 
5% 
80% 
80% 
80% 

36 
5 
9 
14 
7 
10 

Table 7: Overview of attributability and duration of sickness 

1.6. Cost of being sick 

Additional 
sick days 

4 
2 
2 
2 
4 
2 

The societal cost of being sick consist of two main components, namely the hospital and/ or 
general  healthcare  costs  and  the  cost  due  to  loss  of  production  or  productivity.  The  cost  of 
being taken up in a hospital for an infectious disease (most similar to above causes of illness) 
has been estimated to cost EUR 2 676 for five days.140 However, not all people who fall sick 
need hospital treatment and for the analysis the assumption that half of the cases need to be 

139 
140 

www.dewatergroep.be and RIVM. 
http://www.zorgwijzer.nl/zorgverzekering-2014/wat-kost-een-verblijf-en-behandeling-in-het-
ziekenhuis;  

85 

 
 
                                                 
treated in the hospital is used. This assumption and the simplification141 for the different MS 
healthcare  systems  show  that  on  average  direct  costs  of  falling  ill  are  EUR  203.  Next  to 
healthcare costs society has cost when one falls sick if s/he is part of the working group (65 % 
of  the  population  when  taking  EU28  2015  average)142.  The  costs  of  falling  sick  consist  of 
salary for a replacement employee and loss of productivity.143 On average the costs have been 
estimated at EUR 93.144  

1.6.1. Total number of cases and societal cost of being sick  

The table below is a culmination of the approach set out in the first section of this chapter and 
provides a rough indication of the current societal cost related to drinking tap water per MS. 
In 2015 the societal cost of drinking tap water in Europe is equal to EUR 220 million or EUR 
0.43 per EU citizen and EUR 9.6 per person at risk.145 These figures are a rough estimation of 
the current societal cost of consuming tap water; this value should be interpreted as the lower 
boundary. In this analysis possible (unknown) long term health impacts of water consumption 
are not taken into account.  

Member 
State 

 Austria 

 Belgium 

 Bulgaria 

 Croatia* 

 Cyprus 

 Czech R. 

 Denmark 

 Estonia 

Societal  cost 
being 
for 
sick  due  to 
tap water 

Total  min  
(x mln) 

Total  max  
(x mln) 

Causal  days 
sick** 

Cost 
PPHR *** 

per 

€ 386 

 € 2,4  

 € 3,3  

 3.055  

 € 6,9  

€ 353 

 € 5,3  

 € 7,3  

 23.681  

 € 8,6  

€ 139 

 € 3,5  

 € 4,5  

 34.468  

 € 5,8  

€ 139 

 € 2,1  

 € 2,1  

 20.681  

 € 11,5  

€ 244 

 € 0,2  

 € 0,3  

 107  

 € 5,5  

€ 252 

 € 3,0  

 € 4,5  

 8.758  

 € 7,8  

€ 372 

 € 1,6  

 € 2,3  

 2.301  

 € 11,4  

€ 227 

 € 0,6  

 € 0,8  

 3.706  

 € 17,5  

141 

142 

143 
144 

145 

Simplification  entailed  that  for  the  calculation  the  cost  of  different  MS  healthcare  systems  were 
assumed on the basis of income per capita differences; 
http://ec.europa.eu/eurostat/statistics-
explained/index.php/File:Population_age_structure_by_major_age_groups,_2005_and_2015_(%25_of_
the_total_population)_YB16.png. 
http://www.mkbservicedesk.nl/10218/zieke-werknemer-kost-200-tot-400-euro.htm;  
We excluded cost of salary to the person who is sick, because this is rather a transfer. Values are EU 
weighted averages; 
The societal cost, in the short-run, is ranging between €160 and €239 million. 

86 

 
 
                                                 
Member 
State 

 Finland 

 France 

 Germany 

 Greece 

 Hungary 

 Ireland 

 Italy 

 Latvia 

 Lithuania 

 Luxembourg 

 Malta 

 Netherlands 

 Poland 

 Portugal 

 Romania 

 Slovakia 

 Slovenia 

 Spain 

 Sweden 

 UK 

EU total 

Societal  cost 
for 
being 
sick  due  to 
tap water 

Total  min  
(x mln) 

Total  max  
(x mln) 

Causal  days 
sick** 

Cost 
PPHR *** 

per 

€ 330 

 € 1,6  

 € 2,2  

 2.875  

 € 7,4  

€ 319 

 € 17,7  

 € 23,4  

 12.584  

 € 10,3  

€ 375 

 € 27,4  

 € 39,7  

 82.822  

 € 14,5  

€ 216 

 € 2,7  

 € 3,6  

 772  

 € 4,8  

€ 202 

 € 2,5  

 € 3,5  

 3.655  

 € 7,1  

€ 400 

 € 1,4  

 € 2,2  

 4.086  

 € 17,1  

€ 287 

 € 14,9  

 € 19,8  

 1.549  

 € 5,8  

€ 190 

 € 0,5  

 € 0,7  

 720  

 € 7,0  

€ 224 

 € 0,8  

 € 1,1  

 1.083  

 € 5,3  

€ 406 

 € 0,2  

 € 0,3  

 377  

 € 10,5  

€ 257 

 € 0,1  

 € 0,2  

 131  

 € 9,4  

€ 390 

 € 5,4  

 € 7,1  

 8.097  

 € 11,1  

€ 202 

 € 11,1  

 € 14,7  

 28.085  

 € 18,8  

€ 233 

 € 2,5  

 € 3,4  

 251  

 € 4,6  

€ 165 

 € 5,4  

 € 7,0  

 8.096  

 € 3,8  

€ 229 

 € 2,1  

 € 2,8  

 8.856  

 € 8,5  

€ 246 

 € 0,6  

 € 0,8  

 1.009  

 € 8,5  

€ 272 

 € 12,3  

 € 16,5  

 13.583  

 € 5,0  

€ 367 

 € 5,3  

 € 7,3  

 25.139  

 € 15,0  

€ 325 

 € 24,6  

 € 36,6  

 107.380  

 € 41,2  

 € 157,9  

 € 218,5  

 407.906  

87 

 
 
 
 
Member 
State 

EU average 

Societal  cost 
for 
being 
sick  due  to 
tap water 

Total  min  
(x mln) 

Total  max  
(x mln) 

Causal  days 
sick** 

Cost 
PPHR *** 

per 

€ 298 

 € 5,6  

 € 7,8  

 14.568  

 € 9,6  

Table 8: Societal cost of being sick (short-term) 

* The EDCD database did not include information on Croatia. Croatia has been set at 60 % of 
Bulgaria to best assess total EU28 sick costs (due to differences in population). The societal 
cost per sick case is set equal for Bulgaria. 

** 0.08 % of the EU will on a yearly basis become 1 day sick due to drinking tap water. 
For these figures the average of column 2 and 3 in Table 8 has been taken. 

*** The difference per MS corrects for the difference in actual sick cases (ECDC) and PPHR. 

1.7. Linking PPHR and causal attributed reported sick cases 

The PPHR approach calculated the number of people at risk for the baseline (2015, 2030 and 
2050)  and for each of the options. Similar to  the number  of drinking  water related sickness 
cases  (based  on  the  ECDC  reported  cases  database)  we  found  that  there  are  considerable 
differences across MS for both the PPHR and number of sick cases. These section analyses to 
what extent a link exists between the PPHR approach and number of causal attributable sick 
cases at MS level.  

On  average  23  million  people  are  annually  at  risk  per  MS,  or  roughly  5  %  of  the  EU 
population. A consumer is most at risk in Bulgaria (>10 %) and least at risk in the UK (<2 %), 
(Figure 23).  

Figure 23: Population potentially at risk of being sick by MS, % annually 

In  order  to compare  the PPHR and  number of causal  sick cases  we first took  the chance of 
being at risk and chance of falling sick per MS and secondly calculated the share compared to 
the  EU  total  chance  of  being  at  risk  and  causal  sick  chance  summed  over  all  MS.  To 
graphically best depict what MS have a good correlation versus MS where the correlation is 
weaker we took the difference of the scaled result. 

88 

 
 
 
One should interpret the below figure in the following manner: 

- If all MS have a value close to 2.8 %  there is a very strong correlation between the PPHR 
approach and the actual number of reported sick cases. 

- If many MS are far away from the average of 2.8 %  there is a weak correlation and the 
PPHR approach or the ECDC information do not report the actual number of people at risk.146 

Figure 24: Linkage between being at risk and getting sick 

The above figure shows that there is a relative strong link between both approaches for most 
MS.  It  also  shows  that  the  approach  is  relatively  unreliable  for  Cyprus,  Germany,  Greece, 
Poland,  Portugal,  Romania  and  the  United  Kingdom.  The  expected  main  reason  for 
inconsistencies in correlation between both approaches is related to the level of reporting on 
number  of  sick  cases  to  the  ECDC  database  by  MS.  Experts  who  often  work  with  this 
database have  informed  us that the UK is  very actively monitoring  and reporting sick cases 
compared to some other MS. In light of this qualitative background we can conclude that for 
some  MS  the  PPHR  might  be  an  underestimation  and  for  others  an  overestimation.  We 
conclude that it would be best to fall back to calculating PPHR costs at EU level compared to 
an approach where we link PPHR results to the number of reported sick cases for that MS. 

2. Underlying assumptions for analytical model and options 

2.1. Assumptions made for the quantification of impacts 

This Annex serves as an explanatory guide regarding the assumptions and quantifications that 
were made for the Impact Assessments of the different options. All assumptions were based 
on  the  same  baseline  scenario  which  is  presented  in  tabular  form  below  (Table  9).  These 
assumptions were used for the consequent assessment of the options. Cost figures build on the 
cost estimations in the Evaluation and its underlying study. An EU 'household' corresponds on 
Eurostat figures to 2.4 persons. 

146 

We note that we are aware that not all MS report equally to the ECDC database and we assume that 
option 1 (all MS near the 2,8% average) is an unlikely outcome of the analysis. This section is therefore 
more of a check and results are not impacting the overall analysis. 

89 

 
 
 
                                                 
Monitoring  costs,  in  the  baseline  scenario,  are expected to  decrease  from  2015  to  2030  and 
2050 as a result of the voluntary application of the risk-based approach. Treatments costs are 
expected to decrease by 2030 and then to increase again by 2050 because of the combination 
of  two  trends:  firstly,  reduced  unitary  treatment  costs  through  the  risk-based  approach  and 
preventive measures that secondly, do not compensate for the increase in population. 

Current situation (2015) 

Projections (2050) 

Characteristics of 
demography and 
pressures on water 
resources 

Demography  

508.2 millions of 
inhabitants (Eurostat)  

Distribution of 
population between 
urban / rural areas  

43 % in urban areas; 35 
% in intermediate areas; 
22 % in rural areas 
(Eurostat)  

525.5 millions of inhabitants, - 
decreasing in some MS 
(Eurostat) 

47 % in urban areas; 38 % in 
intermediate areas; 15 % in 
rural areas (UN trends) 

Population above 65  

19 % (Eurostat)  

28 % (Eurostat)  

Pharmaceuticals 
products consumption 
expenditure  

9 030 PPS (Eurostat)  

14 204 PPS (increase 
proportional to the number of 
inhabitants above 65)  

N losses to surface and 
ground water  

13.9 kg N/ha (Eurostat)  

18.1 kg N/ha (Wolf et al., 
2015)  

Surface water bodies 
subject to point source 
pollution  

37.5 % (Waterbase, EEA) 
- with large disparities 
between MS  

37.5 % (stable, as decoupling 
of industrial emissions and 
economic growth)  

Percentage of PWS 
water coming from 
groundwater sources  

58 % (Eurostat)  

58 % (stable)  

Average consumption 
of drinking water per 
person (tap + bottles)  

3 950 litres per year and 
per person (Eurostat, 
Unesda)  

3 950 l/y/p (stable)  

Large water suppliers 
(among population 
connected to PWS) 

80 % of the EU28 
population (Eurostat)  

86 % of the EU28 population 
(increase proportional to the 
population in urban and 

90 

 
 
intermediate areas)  

Risk-based approach 
% of the MS population 

Small supplies 0 %, 
Large supplies 0->90 % 

Small supplies 25-75 % 
Large supplies 50-90 % 

Table 9: Assumptions for the baseline scenario 

Member state  Population 

Population 
connected to 
PWS 

Population 
connected 
or covered 
by specific 
regulation 

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 

8.551.081 
11.336.943 
7.199.931 
4.244.995 
873003 

95,10% 
100,00% 
99,16% 
85,50% 
100,00% 

10.536.043 

93,28% 

5.649.584 
1.311.505 
5.478.486 
66.175.754 
80.709.056 
10.977.945 
9.863.193 
4.602.854 
60.944.960 
1.985.887 
2.901.039 
562.848 
426.144 
16.876.904 
38.499.953 
10.367.550 
19.909.323 
5.416.851 
2.066.511 
46.390.269 
9.721.642 
64.643.370 

97,00% 
81,44% 
91,50% 
99,00% 
99,30% 
94,00% 
100,00% 
85,00% 
99,00% 
76,00% 
76,00% 
99,90% 
100,00% 
100,00% 
87,64% 
96,90% 
57,16% 
86,84% 
85,50% 
100,00% 
86,00% 
100,00% 

91 

95,1% 
100,0% 
99,2% 
85,5% 
100,0% 

93,3% 

97,0% 
81,4% 
91,5% 
99,0% 
99,3% 
94,0% 
100,0% 
85,0% 
99,0% 
76,0% 
76,0% 
99,9% 
100,0% 
100,0% 
87,6% 
96,9% 
57,2% 
86,8% 
85,5% 
100,0% 
86,0% 
100,0% 

average 
consumption 
of tap water 
per person 
(drinking 
water in 
l/cap/day) 
137 
100 
191 
182 
105 

90 

99 
70 
117 
128 
122 
177 
92 
150 
243 
77 
61 
115 
50 
128 
98 
132 
74 
83 
122 
130 
148 
150 

LEAKAGE 

PWS 

14% 
50% 
57% 
44% 
8% 

23% 

14% 
17% 
22% 
30% 
12% 
26% 
25% 
44% 
39% 
28% 
19% 
19% 
26% 
12% 
24% 
23% 
17% 
28% 
29% 
30% 
19% 
14% 

 
 
 
Kingdom 
EU total 
EU average 

508.223.624 
18.150.844 

95% 
95% 

3.371 
120 

23% 

Table 10: Population, Connection, Consumption Data, Leakage Rates 

2.2. Social-economic baseline impacts - water costs in a household-spending 

The baseline scenario starting with 2015 income levels has made predictions on income levels 
in 2050. This analysis shows that, in the baseline, the cost of water for households decreases 
from  EUR  229  to  EUR  228  in  the  2050  forecast  with  no  visible  change  with  regards  to 
affordability. This is a result of a cost reduction expected in the baseline and of the disposable 
income estimation increasing faster than the estimated increase in cost of water from drinking 
water  providers.  However,  due  to  the  large  uncertainties  in  these  predictions  for  2050,  it  is 
unlikely  that  drinking  water  becomes  dramatically  more  affordable  towards  2050  in  the 
baseline. Figure 25 below shows the comparison of water costs with household incomes per 
Member State. 

Figure 25: Comparison of water costs with household incomes (2015 and 2050 baseline) 

3. Detailed description of the options  

The  following  section  describes  the  different  options  that  were  discussed  to  address  the 
problems and the objectives pointed out in this Impact Assessment. First each option and the 
underlying  assumptions  are  explained  in  detail.  These  assumptions  are  based  on  expert 
discussions. Second, in tabular form an initial screening of all options across a wide range of 
categories is provided. Third, the in-depth assessment of the health and economic impacts of 
the options is described. For the in-depth assessment the above outlined PPHR indicator was 
used as well as the baseline assumptions.    

92 

 
 
 
 
 
 
In  the  following  sub-section  the  five  overarching  objectives  are  explained  in  detail  and  the 
underlying assumptions are provided.  

3.1. Objective 1: Updated list of parameters   

The DWD defines minimum requirements for the quality of drinking water by regulating 48 
microbiological and chemical parameters in its Annex I. The parameters have to be reviewed 
based on technical progress every five years, but the reviews have not led to a revision in the 
set of parameters so far. The ex-post Evaluation and the stakeholder consultations identified 
the need to amend the list of parameters of Annex I in line with latest scientific and technical 
developments and evidence. There were in particular suggestions from the public consultation 
that  substances  used  in  consumer  products,  pharmaceuticals  and  endocrine  disrupting 
substances should be included. A number of European projects from Framework programmes 
(such as HEALTHY Water –FP6, RAMADA – FP6, ECHAIN-FP6, ChemFree Water – FP6, 
BIOTREAT-FP7,  MAQUA-FP7,  AQUAVALENS-FP7,  HI-WATE-  FP6,  ARSENIC 
reduction – FP6, and others) shows the need to address this challenge. For a detailed review, a 
cooperation project is conducted by the WHO to update the parameters and the limit values in 
the  DWD,  as  the  DWD  standards  should  be  generally  based  on  the  WHO  Guidelines.  The 
project suggests a list of substances to remove and to add to the DWD list. This project will 
provide for each parameter a fact sheet that justifies the proposed changes.147  

Table  11  below  shows  the  extended  parameter  list  (resulting  from  the  WHO  cooperation 
project as well as reliance on precautionary principle) with new parameters displayed in bold, 
which have been used to back up the assumptions of option 1.2. 

Parameter 

Parametric value 

Unit 

Clostridium perfringens spores 

Coliform bacteria 

Enterococci 

Escherichia coli (E. coli) 

0 

0 

0 

0 

Heterotrophic plate counts (HPC)  
22o 

No abnormal change 

Somatic coliphages 

Legionella 

Turbidity 

0 

<1000 

<1 

Number/100 ml 

Number/100 ml 

Number/100 ml 

Number/100 ml 

Number/100 ml 

Number/l 

NTU   

147 

Folder WHO Project: https://circabc.europa.eu/w/browse/b6bb0d99-8c88-4b9d-9a14-68a0f2695e6d 

93 

 
 
 
                                                 
 
Acrylamide 

Antimony 

Arsenic 

Benzene 

Benzo(a)pyrene 

Beta Estradiol (50-28-2)  

Bisphenol A  

Boron 

Bromate 

Cadmium 

Chlorate 

Chlorite 

Chromium 

Copper 

Cyanide 

1,2-dichloroethane 

Epichlorohydrin 

Fluoride 

Haloacetic acids (HAAs) 

Lead 

Mercury 

Microcystin-LR  

Nickel 

Nitrate 

Nitrite 

0,10 

5,0 

10 

1,0 

0,010 

0,001 

0,01 

1,0 

10 

5,0 

0,35 

0.35 

50/25  

2,0 

50 

3,0 

0,10 

1,5 

80 

10/5  

1,0 

1,0 

20 

50 

0,50 

94 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l  

μg/l  

mg/l 

μg/l 

μg/l 

mg/l  

mg/l  

μg/l 

mg/l 

μg/l 

μg/l 

μg/l 

mg/l 

μg/l  

μg/l 

μg/l 

μg/l 

μg/l 

mg/l 

mg/l 

 
 
Nonyl phenol  

Pesticides 

Pesticides — Total 

PFAS  

PFASs - Total  

0,3  

0,10 

0,50 

0,10 

0,50 

Polycyclic aromatic hydrocarbons 

0,10 

Selenium 

Tetrachloroethene and 
Trichloroethene 

Trihalomethanes — Total 

Uranium 

Vinyl chloride 

Table 11: Parameter list 

10 

10 

100 

30 

0,50 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l 

μg/l  

μg/l 

Objective  1  of  updating  the  list  of  parameters  is  addressed  by  three  options  with  different 
levels of ambition.  

3.1.1 Option 1.1: Updated list of parameters  

to  scientific  progress  and  following 

This  Option  would  solve  the  problem  raised  above  by  amending  Annex  I  of  the  Directive. 
the 
Annex  I  would  be  updated  according 
recommendations  of  the  WHO.  This  update  would  lead  to  the  removal  of  some  substances 
that  are  outdated  (i.e.  that  do  not  represent  a  source  of  contamination  with  potential  health 
effects  anymore),  and  the  addition  of  some  newly  identified  priority  substances.  Parametric 
values for those new substances would be set according to the WHO guidelines. It has to be 
noted  that  several  global  WHO  standards  are  slightly  less  strict  than  the  current  DWD 
standards. Hence, a few EU-specific standards based on a different risk assessment or on the 
precautionary  principle  (for  instance  for  pesticides)  would  stay  unchanged.  The  aim  is  to 
maintain  both  the  level  of  health  protection  and  ambition  as  well  as  to  keep  the  number  of 
substances to be monitored stable.  

3.1.1.1 Assumptions for option 1.1 

• 
Parameters:  around  48  parameters  to  monitor  and  to  comply  with  in  drinking  water, 
defined  as  an  update  of  the  current  list  in  Annex  I  according  to  scientific  and  technical 
progress.  

95 

 
 
This option would require some investments to equip monitoring labs and treatments 
• 
facilities  for  making  water  potable,  with  new  technologies  machines  in  order  to  be  able  to 
monitor and treat the new substances added to Annex I list.  

This  option  would  require  the  application  of  more  treatments  on  water  during  the 

• 
potabilization process as compared to baseline (+5 % in annual treatment costs).  

It would lead to a change in the drinking water quality as some more parameters will 

• 
be monitored and taken into consideration:  

- 
We  assumed  that  contamination  by  substances  in  this  new  list  above  defined 
parametric values would be reduced as compared to baseline because those substances would 
now  be  regulatory  monitored  and  treated.  The  contamination  rates  would  be  equal  to  those 
under  the  current  DWD  list  non-compliance  rates  during  the  previous  period.  We  also 
assumed that water suppliers which apply a RBA would even more reduce this contamination, 
consistently  with  the  assumptions  in  baseline  (i.e.  that  contamination  rates  are  twice  lower 
would be reduced by the factor 2 for water suppliers which apply RBA as compared to those 
which do not apply RBA. 

We  assumed  that  contamination  of  raw  water  used  for  individual  supply  would  be 

- 
similar as in baseline. 

3.1.2. Option 1.2: Extended list of parameters 

This  option  will  consist  of  an  update  of  the  parameters  in  Annex  I  following  scientific  and 
technical progress, plus the addition of relevant potentially harmful substances on the basis of 
the  precautionary  principle,  i.e.  in  particular  through  additional  microbiological  reference 
parameters, perfluorinated compounds or  endocrine disrupting compounds  (EDCs). This  list 
would  therefore  be  broader  than  the  list  under  option  1.1.  Parametric  values  would  be  set 
either by reference to  the  WHO guidelines, or  by keeping the same value as  in  the existing 
DWD if that one is already stricter that the WHO value, or by setting a stricter value for the 
most  harmful  contaminants  with  regard  to  the  precautionary  principle.  As  this  list  of 
parameters includes a wider spectrum of potentially harmful substances that could be found in 
drinking water, the need for a precautionary treatment by far-reaching adsorption and filtering 
technologies, i.e. by activated carbon has been assumed. 

3.1.3. Assumptions for option 1.2 

• 
Parameters:  more  than  48  parameters  to  monitor  and  to  comply  with  in  for  drinking 
water, defined as the whole list of substances representing a potential harm for human health 
and with parametric values settled according to the precautionary principle.  

• 
This  option  would  require  some  investments  to  equip  monitoring  labs  and 
potabilization plants with new technologies modern machines in order to be able to monitor 
and treat the new substances added to Annex I list. Investments needed are considered to be 
33 times higher than in Option 1.1. 

96 

 
 
This  sub-option  would  require  an  increased  monitoring  effort  during  the  drinking 

• 
water production process as compared to baseline (+15 % in annual monitoring costs). 

This  option  would  require  the  application  of  more  treatments  on  water  during  the 

• 
potabilization process as compared to baseline (+30 % in annual treatment costs).  

It would lead to a change in the drinking water quality as some more parameters will 

• 
be monitored and taken into consideration:  

- 
We assumed that contamination by these substances would be on average at a lower 
concentration  in  drinking  water  as  compared  to  the  baseline.  Overall,  the  compliance  rates 
with  current  DWD  parametric  values  would  remain  similar  to  the  baseline:  as  a  result, 
contamination  rates  above  precautionary  limit  values  are  assumed  to  be  equal  to  the  non-
compliance rates assessing assessed during the previous DWD reporting period. 

We assumed that the contamination by substances from the list under option 1.1 above 
- 
defined  parametric  values  would  be  reduced  as  compared  to  baseline  as  these  substances 
would  be  regulatory  monitored  and  treated.  The  new  contamination  rates  would  be  equal 
previous compliance rates. We also assumed that water suppliers which apply a RBA would 
even  more  further  reduce  this  contamination,  consistently  in  line  with  the  assumptions  in 
baseline  (i.e.  that  contamination  rates  are  twice  lower  by  a  factor  of  2  for  water  suppliers 
which apply RBA as compared to those which do not apply RBA. 

- 
We  assumed  that  the  contamination  of  drinking  water  by  the  supplementary 
substances  that  are  above  defined  parametric  values  would  be  reduced  as  compared  to 
baseline  and  to  option  1.1.  Contamination  rates  are  assumed  to  be  equal  to  ¾  of 
contaminations  rates  in  baseline  for  both,  water  suppliers  applying  RBA  and  those  not 
applying RBA.  

We  assumed  that  contamination  of  raw  water  used  for  individual  supply  would  be 

• 
similar as in baseline. 

3.1.4. Option 1.3: Reduced list of parameters 

This Option is designed with the main aim of simplifying the requirements in terms of quality 
standards for drinking water. The list of parameters would contain only the most potentially 
harmful parameters. In conjunction with option 2 (risk-based approach) and the principle of 
subsidiarity, Member States will be responsible to set regulations, if any, for other substances. 
A first screening has shown that this sub-option leads to a worse situation than the baseline in 
terms of achieving the health objective. As noted previously, this option will not be analysed 
and not be considered in the overall assessment.  

3.1.5. Assumptions Option 1.3 

Parameters:  less  than  48  parameters  to  monitor  and  to  comply  with  in  for  drinking 
• 
water,  corresponding  to  the  current  list  in  Annex  I  with  only  the  most  potentially  harmful 
substances kept.  

97 

 
 
This  option  would  lead  to  a  reduced  monitoring  effort  during  the  drinking  water 

• 
production process as compared to baseline (-15 % in annual monitoring costs). 

This  option  would  lead  to  the  application  of  less  treatments  on  water  during  the 

• 
potabilization process as compared to baseline (-10 % in annual treatment costs).  

It would lead to a change in the drinking water quality as only a few parameters will 

• 
be monitored and taken into consideration:  

- 
We assumed that contamination substances from the current Directive remains stable 
as compared to 2015, which means it, would be higher than in baseline where for which an 
improvement has been assumed. 

We  assumed  that  contamination  of  raw  water  used  for  individual  supply  would  be 

• 
similar as in baseline. 

This  Option  has  been  excluded  from  further  analysis  in  the  IA,  as  it  obviously  leads  to  a 
worse situation than today in terms of achieving the set health objective. 

3.2. Objective 2: Risk-Based Approach  

As  identified  in  the  problem  definition  (Section  1.2.1.2),  the  current  DWD  method  is  not 
sufficiently  comprehensive.  Preventive  safety  planning  and  risk-based  elements,  concepts 
introduced  in  2004  by  the  WHO,  are  so  far  only  under-considered.  This  option  therefore 
covers the introduction of a risk-based approach (RBA) offering opportunities to concentrate 
time  and  resources  on  risks  that  matter  and  on  cost-effective  source  measures,  and  to  avoid 
analyses  and  efforts  on  non-relevant  issues.148  It  should  be  underlined  that  considerable 
progress at the European level have been shown as an outcome of several European scientific 
projects  (e.g.  in  particular  TECHNAU-FP6)  where  decision  support  framework  for  the 
integration  of  risk  management  in  drinking  water  supply  successfully  advanced  comprising 
risk tolerability in drinking water as a basis for decisions on risk reduction measures. 

The  RBA  presents  an  opportunity  to  move  from  an  end-of-pipe  approach  to  a  holistic  and 
modern management of water supply, from abstraction area to distribution. Under the RBA, 
Member  States  and/or  water  suppliers  are  required  to  conduct  preventive  risk  assessments, 
based  on  minimum  requirements  set  at  EU  level,  encompassing  a  hazard  assessment  of  the 
abstraction  area,  a  supply  risk  assessment,  and  also  a  risk  assessment  of  the  domestic 
distribution  system.  The  hazard  assessment  should  identify  hazards  that  might  threaten  the 
safety  of  a  water  supply  and  the  quality  or  acceptability  of  drinking  water.  It  should  take 
existing monitoring data collected under the Groundwater Directive 2006/118/EC, the Priority 
Substances  Directive  2008/105/EC,  or  the  Water  Framework  Directive  2000/60/EC  into 
account, but also be flexible to identify emerging hazards, e.g. microplastics.The RBA needs 
to be transposed and integrated in Member States' national legislations, whilst leaving some 
degree of flexibility on how the RBA is implemented and who is responsible to conduct it.  It 

148 

See WHO Publication on the Water Safety Plan/Risk-Based Approach: 
http://www.euro.who.int/en/health-topics/environment-and-health/water-and-sanitation/publications 

98 

 
 
                                                 
  
has to be noted that the baseline already considers a voluntary take-up of risk assessment. As 
outlined above, this Option is therefore not counteracting a negative development, but rather 
supporting and accelerating a positive one. The difference between the baseline and Option 2 
is the mandatory and uniform character of the risk based approach across all Member States. 

The RBA triggers changes on several levels as depicted in Table 12: 

Changes that can be triggered through adoption of RBA149 

Level 

Expected changes 

Institutional 
changes 

Operational 
changes 

Financial 
changes 

 
 

 

Increased communication and collaboration among stakeholders 
Increased knowledge and understanding of the water supply system among 
water supplier’s staff and other stakeholders 
Increased training (increased knowledge, discipline and ownership among staff 
for their specific roles). 
Improved system infrastructure (through system infrastructure assessments, 
water quality assessment and monitoring plans) 
 
Implementation of improved procedures for operations and monitoring. 
  Cost savings through identification and implementation of more efficient 

 

procedures 

  Cost recovery: higher willingness to pay because of increased consumer 

 

satisfaction 
Increased donor support and investment (better foundation for more efficient 
and targeted investment in drinking water systems). 

Table 12: Change triggered through RBA – holistic approach 

3.2.1. Option: 2.1: compulsory RBA for large water suppliers 

The  current  DWD  provides  the  possibility  to  exclude  very  small  supplies150  from  its  scope 
and  distinguishes  between  large  and  small  water  supplies151  in  terms  of  reporting 
requirements. Option 2.1 would apply in a proportionate way to large water suppliers having 
the  obligation  to  apply  a  RBA  as  described  above.  This  option  will  enable  large  water 
companies and communities to learn more about sources of pollution of their drinking water 
sources, monitor the right parameters and target measures to reduce pollution at source.  

3.2.2.. Main assumptions for option 2.1 

• 
RBA application: We assumed that 98 % of large water suppliers would indeed apply 
a  RBA  and  have  implemented  it  by  2050.  Concerning  small  water  suppliers,  voluntary 
application of RBA would  be similar as  in  baseline. In  total,  it  would result in  86 %  of the 

149  

Identified by CDC, A conceptual framework to evaluate the Impacts of water safety plans. Centers for 
disease 
2011. 
http://www.cdc.gov/nceh/ehs/gwash/Publications/WSP_Evaluation_Framework.pdf; 
Very small supplies with less than 10 cubic meters per day or serving less than 50 people are exempted 

prevention, 

Atlanta. 

control 

and 

150 
from the Directive, Article 3.2 (b). 
151 
% of the population. For further details, see Evaluation SWD.  

EU: Around 11 000 large supplies and 85 000 small supplies serving respectively around 80 % and 20 

99 

 
 
                                                 
population connected to PWS concerned by a RBA in  2050 (vs. 74 %  in baseline).  Cost of 
mandatory RBA implementation (per person supplied and per year) is assumed to be higher 
(by 10 %) than for the 'voluntary' RBA considered in baseline as the regulation would impose 
a stricter process of development, implementation, updating of the risk assessments performed 

• 
Parameters:  As  currently  and  as  in  baseline,  a  list  of  parameters  to  monitor  and  to 
comply with will be annexed to the DWD - and with (as currently) the possibility for water 
suppliers which apply a RBA (so in theory all large water suppliers at least) to deviate from 
this  list  in  terms  of  monitoring  and/or  treatment.  For  this  option,  as  more  water  suppliers 
would  apply  an  RBA  as  compared  to  baseline,  we  can  assume  that  more  water  suppliers 
would monitor less (and sometimes more) parameters. 

• 
Monitoring  and  treatment  efforts  (and  thus  unitary  costs)  are  impacted  by  the 
application  of  an  RBA.  Assumptions  on  those  impacts  are  common  with  baseline  and  are 
described  in  details  in  the  regarding  section.  It  is  important  to  stress  that  monitoring 
obligations  shift  from  a  pure  monitoring  of  the  quality  of  drinking  water  supplied  to 
consumers  to  monitoring  the  wider  water  resources,  including  the  quality  of  raw  water  in 
catchments. 

• 
The obligation to apply RBA would have consequences on the drinking water quality. 
Although the impacts of an RBA application on supplied drinking water’s contamination by 
all categories of substances considered are similar than in baseline regarding to contamination 
percentages, more water (and more persons) would be concerned by the lower rates defined 
for  water  suppliers  applying  RBA.  As  a  result,  drinking  water  quality  would  be  globally 
improved (those concerned by a difference in contamination if an RBA is applied). 

• 
The  obligation  to  apply  RBA  would  also  have  consequences  on  the  quality  of  raw 
water  used  for  individual  supply  by  the  persons  not  connected  to  PWS.  Indeed,  a  higher 
number  of  water  suppliers  applying  RBA  would  lead  to  more  actions  addressing 
contamination  at  source  implemented  –  with  ancillary  benefits  for  those  persons  with  self-
supplies/self-abstractions in water bodies benefiting from these actions.  

3.2.3. Option 2.2: compulsory RBA for large and small water suppliers 

In this option, in addition to the option 2.1, smaller water suppliers would also be obliged to 
develop and implement the RBA. The RBA would need to be proportionate to the size of the 
water  supply  and  to  possible  hazards  that  could  deteriorate  water  quality,  following  WHO 
processes  and  guidelines,  including  a  simplified  process  for  small  communes/communities 
managing their own water supplies. In practice, this means that smaller water suppliers may 
benefit from more time to apply the RBA. 

3.2.4. Main assumptions for option 2.2 

RBA application: We assumed that 98 % of large water suppliers would indeed apply 
• 
an RBA and have implemented a WSP by 2050, and 95 % of small water suppliers. In total, it 
would result in 95 % of the population that is connected to PWS to benefit those concerned by 
an RBA in 2050 (vs. 74 % in baseline). Cost of mandatory RBA implementation (per person 

100 

 
 
supplied  and  per  year)  is  assumed  to  be  higher  (by  10  %)  than  for  the  'voluntary'  RBA 
considered  in  baseline  as  the  regulation  would  impose  a  stricter  process  of  implementation 
and of WSP writing. 

Parameters:  As  currently  and  as  in  baseline,  a  list  of  parameters  to  monitor  and  to 
• 
comply with will be annexed to the DWD - and with (as currently) the possibility for water 
suppliers  which  apply  an  RBA  to  derogate  from  this  list  in  terms  of  monitoring  and/  or 
treatment.  In  this  option  as  more  water  suppliers  would  apply  an  RBA  as  compared  to 
baseline, we can assume that more water suppliers would monitor less (and sometimes more) 
parameters. 

Monitoring  and  treatment  efforts  (and  thus  unitary  costs)  are  impacted  by  the 
• 
application  of  an  RBA.  Assumptions  on  those  impacts  are  common  with  baseline  and  are 
described in detail in the corresponding section.  

• 
The obligation to apply RBA would have consequences on the drinking water quality. 
Although the impacts of an RBA application on supplied drinking water’s contamination by 
all  categories  of  substances  considered  are  similar  than  in  baseline  regarding  to  the 
contamination percentage, more water (and more persons) would be concerned by the lower 
rates defined for water suppliers applying an RBA. As a result, drinking water quality would 
be  globally  improved  (those  concerned  by  a  difference  in  contamination  if  an  RBA  is 
applied). 

• 
The obligation to apply an RBA would also have consequences on the quality of raw 
water  used  for  individual  supply  by  the  persons  not  connected  to  PWS.  Indeed,  a  higher 
number  of  water  suppliers  applying  RBA  would  lead  to  a  higher  implementation  of  more 
actions addressing contamination at source implemented.  

3.3. Objective 3: Materials and products in contact with drinking water  - harmonisation of the 

system 

This option emerges from the evaluation, as described under the problem definition section152. 
The effectiveness analysis concluded that Article 10 on materials and products in contact with 
drinking  water  leaves  too  much  room  for  Member  States  to  determine  what  'necessary 
measures' for such materials are, which made the provision ineffective. The ambiguity of the 
Article tolerated national approval systems for materials and products in contact with drinking 
water,  which  do  not  recognise  test  and  approval  results  from  other  Member  States.  The 
nationally  required  multiple  testing  and  approval  can  be  seen  as  an  obstacle  to  the  internal 
market. Thus, Article 10 represents a long-term challenge to the provision of clean and safe 
drinking water in the EU, and options need to assess how best to replace this Article.  

Most materials and products in contact with drinking water are construction products that can 
be  harmonised  under  the  Construction  Products  Regulation,  but  standardisation  efforts, 
already going on for quite some time, were so far not successful.  

152 

See Section 2.1.3 

101 

 
 
                                                 
This  option  foresees  the  development  of  product  requirements  and  standards  to  overcome 
non-functioning mutual recognition and the stagnant standardisation work so far in area. This 
would  be  done  by  replacing  Article  10  in  the  DWD  by  concrete  provisions  related  to  the 
wider  domestic  distribution  risk  assessment,  and  the  development  of  product  requirements 
and  standards  would  be  done  under  internal  market  legislation,  namely  the  Construction 
Products Regulation.  

3.3.1.  Option  3:  Removal  of  an  obstacle  to  the  internal  market  and  harmonisation  of 
standards on materials and products in contact with drinking water 

Under this option, it is assumed that  product requirements and standards will be developed, 
and  that  materials  and  products  which  come  in  contact  with  drinking  water  will  have  to 
comply  with  them.  The  main  efforts  needed  are  non-legislative  measures.  Standardisation 
mandates are issued by the Commission. Thus, there is a gap in product standardisation that 
needs to be filled, as these standards on what and how to test cannot include the test results 
required. Such results, quality requirements or transitional measures need to be fixed within 
the DWD.  The DWD  will then trigger a more speedy development of  product  standards, to 
ensure that in the longer-term product standards and the Directive act in concert. This option 
foresees  that  standardisation  work  would  require  input  on  environmental  and  health-related 
aspects  of  standards,  and  therefore,  this  option's  potential  will  be  assessed  in  this  Impact 
Assessment,  and  not  under  the  Construction  Product  Regulation,  while  ensuring  full 
consistency with the CPR legislation and that entire policy area. 

3.3.2. Main assumptions: option 3 

The  harmonisation  of  standards  on  materials  and  products  in  contact  with  drinking 

• 
water would have consequences on drinking water quality: 

We assumed that contamination by substances from the list proposed under option 1.2 
- 
(Table 11 above) would be reduced as compared to baseline as those pollutants partly come 
from  materials  and  products  used  during  the  drinking  water  production  process  -  this 
reduction is assumed to be of 5 % as compared to contamination in baseline.  

- 
We  assumed  that  contamination  of  drinking  water  by  substances  from  the  current 
DWD  list  is  similar  as  in  baseline  as  those  pollutants  are  assumed  to  not  be  coming  from 
materials and products in contact with drinking water. 

• 
This  option  would  also  lead  to  an  improvement  of  organoleptic  characteristics  of 
drinking  water  (such  as  odour  and  taste  of  water).  Thus,  we  assumed  that  those  among 
population supplied by PWS but drinking bottled- water would partly switch to tap water for 
their consumption. This reduction of bottled water consumption is assumed to 10 % (vs. 4 % 
in baseline). 

3.4. Objective 4: Information on drinking water to consumers 

This objective is derived from the evaluation of the open public consultation which shows that 
the overwhelming majority of citizens wishes more up-to-date information on drinking water 

102 

 
 
and that their level of confidence in safety of water supply is relatively low. Currently, there is 
a very heterogeneous level of active and passive information to consumers. This is mainly due 
to the imprecise DWD wording, which provides that "Member States shall take the measures 
necessary to ensure that adequate and up-to-date information […] is available". This lack of 
information can cause late responses to incidents and lead to citizens consuming contaminated 
or not wholesome water.  

Therefore, the options addressing this objective look into smarter reporting and ways to better 
inform  consumers  by  tapping  the  potential  of  modern  information  technology  and  data 
management. This objective is supported by water-information technology clusters153. 

In  broader  terms  this  option  also  relates  to  the  public  perception  of  tap  water  and  lack  of 
confidence  in  tap  water.  The  confidence  in  tap  water  is  rather  low:  only  19  %  of  the 
respondents  of  the  public  consultation154  agreed  that  the  water  quality  is  acceptable  at  EU 
level.  Many  customers  do  not  trust  tap  water  and  rely  partially  or  exclusively  on  more 
expensive bottled water for drinking. This Impact Assessment uses therefore the consumption 
of  bottled  water  as  an  indicator  to  estimate  the  confidence  or  non-confidence.  The  2015 
average  is  106  l/  capita/  year  of  bottled  water  purchased  in  the  EU,  up  to  170  to  180 
l/capita/year for Member States like such as Germany, Italy and Malta. 

This  option  aims  at  increasing  the  consumers'  confidence  in  tap  water  via  the  best 
technological and organisational/managerial solutions already suggested by some of European 
innovations of water-information technology nexus groups and clusters155   

3.4.1. Option 4.1 simplified automatic electronic reporting to the Commission 

Option 4.1 entails simplified automatic electronic reporting, combined with a very substantial 
reduction of the data to be reported to the Commission. This option identifies simplification 
possibilities,  in  line  with  the  REFIT  principles,  and  the  results  of  the  Fitness  Check  of 
Monitoring  and  Reporting156.  As  shown  in  the  REFIT  evaluation  the  compliance  level  for 
most parameters is already very high which questions the added value of reporting on all data. 
Today Member  States are reporting on all parameters every 3 years to the Commission and 
the Commission then publishes synthesis reports, which are often outdated. Under this option 
Member  States  would  no  longer  be  required  to  provide  complete  national  reports  on  all 
substances every three years, but will rather only report on zones where exceedances of the 
limit values have happened as well as on critical water supply zones. In other terms, Member 
States  would  only  report  useful  information  to  the  Commission  based  on  a  risk-based 

153  
154 

155  

156 

ICT4water cluster - http://www.ict4water.eu/  
See  Figure  12  of  the  Consultation  Report:  https://circabc.europa.eu/sd/a/0070b535-5a6c-4ee4-84ba-
6f6eb1682556/Public%20Consultation%20Report.pdf 
ICT4water  cluster  -  http://www.ict4water.eu/  provides  a  solid  background  of  innovative  solutions  in 
addressing information about drinking water. This cluster has been created as a follow up of a number 
of European projects, such as FREEWAT, INCOVER, KINDRA, DAIAD, POWER (H2020), Proteus, 
Smart-Plant(H2020), etc. 
European Commission (2017) Monitoring and reporting of environment legislation: 
http://ec.europa.eu/environment/legal/reporting/fc_overview_en.htm 

103 

 
 
                                                 
approach,  to  limiting  reporting  obligations  to  information  with  a  real  added  value,  and  all 
routine  information  showing  regular  and  high  level  of  compliance  for  several  parameters 
would not be reported to the Commission anymore.  

In addition, it assumes that automatic reporting will allow a reduction of the reporting costs 
per Member State. It will replace the current three-yearly reporting to the Commission by a 
system ensuring that the information can be used by Member States to control water supplies, 
but  can  also  be  accessible  to  the  European  Environmental  Agency  and  the  European 
Commission. Results of the fitness check on environmental monitoring and reporting and its 
follow-up  will  allow  identifying  concrete  actions  towards  a  streamlined,  low-burden,  high-
effects monitoring and reporting in the context of environmental legislation157, but examples 
of  such  systems  already  exist  (SIIF  under  the  Urban  Waste  Water  Treatment  Directive, 
Eionet, etc.).  

The data thereby available would not only be used for compliance checking purposes but also 
as  indicators  for  any  future  evaluations  of  the  Directive,  in  accordance  with  the  Better 
Regulation guidelines.  

It is important to note that this option in itself does not address the problem of heterogeneous 
information  to  consumers  and  does  not  respond  to  the  objective  of  improving  information 
provided to consumers. This is why in the different policy packages it has been included in 
addition to options 4.2 or 4.3. 

3.4.2. Main assumptions: option 4.1  

The implementation of an automatized reporting process would need the development 
• 
of national informatics systems gathering information from water suppliers on drinking water 
quality and water services characteristics. This represents a small  investment corresponding 
to some time of work of some dedicated persons across MS.  

• 
Once  the  automatized  reporting  system  implemented,  the  process  dedicated  to  the 
production of the report that needs to be sent to EC each year would be simplify - and thus the 
corresponding annual costs would be reduced (by 15 % as an assumption)158. Note that these 
tasks could be supported by the EEA.  

• 
The  accessible  information  used  for  this  reporting  will  be  limited  to  relevant 
information  for  policy  monitoring  and  to  risk  based  approach  monitoring,  but  not  on 
compliance data with all parametric values.  

As the overall cost of the reporting of a few million Euro a factor 1000 lower that the costs of 
all other options, the costs of this option cannot be displayed in most of the figures comparing 
options.   

3.4.3. Option 4.2 Basic online information to consumers  

157 
158 

http://ec.europa.eu/environment/legal/reporting/fc_overview_en.htm 
This  assumption  was  based  on  an  estimate  by  the  authors  of  this  report,  which  relies  on  a  collective 
expertise. 

104 

 
 
                                                 
Option  4.2  requires  basic  online  information  on  water  quality  to  consumers.  In  order  to 
improve  information  diffusion  and  quality  provided  to  citizens,  this  option  proposes  to  set 
specific requirements for water suppliers to actively provide and updated, timely, transparent, 
understandable,  local  and  useful  information  to  consumers  using  electronic/web  systems. 
Under  this  option,  Member  States  would  need  to  ensure  that  all  water  suppliers  provide 
updated information (whose details would need to be defined in an Annex to the DWD), and 
facilitate its electronic access via Internet servers, phone applications or portals. The content 
of the information and frequency of updates will be gradual and proportionate to the size of 
suppliers to avoid excessive burden on small suppliers. 

The  information  that  shall  be  provided  will  address  in  particular:  water  sources  used, 
monitoring (frequency, location), and results of monitoring in terms of drinking water quality. 
The  quality  information  includes  the  concentrations  of  most  relevant  microbiological, 
chemical  and  indicator  parameters,  minerals,  anions/cations,  water  hardness  information  on 
odour,  taste,  with  an  explanation  of  implications  for  human  health,  remedial  actions  taken, 
incidents and interruption of services (and how long they last) and measures taken to restore 
the  service,  timeliness  and  adequacy  of  responses  to  problems.  Updated  information  would 
have to be available online on water services website and/or water authorities' websites as a 
means to limit administrative cost increases.  

3.4.4. Main assumptions: option 4.2 

Same  investment  and  same  cost  reduction  for  reporting  are  assumed  for  in  this  sub-

• 
option as in for option 4.1, as a consequence of an automatized reporting process. 

Even if the smart information on water quality would theoretically be provided to all 
• 
persons connected to PWS, we assumed that in fact only 95 % of them would have access to 
this smart- information.  

• 
The  implementation  of  a  system  that  allows  the  collection  of  data  from  water 
suppliers,  the  organization  of  a  national  database  and  the  development  of  websites  and 
applications would require an initial investment corresponding to sometime of work by some 
persons dedicated to this task in each MS and in the European Commission / EEA. Once this 
system  is  developed,  the  provision  of  smart-  information  would  be  more  costly  than  the 
current  annual  cost  of  providing  information  and  supported  by  water  suppliers  (assumingly 
4.75 times higher than the current unitary cost per person connected to PWS and per year) .  

• 
As  a  consequence  of  the  possibility  of  consumers  to  give  feedback  on  water  quality 
and  to  participate  to  in  consultations  on  water  quality  and  water  services  decisions,  the 
population would have the “power” to influence drinking water suppliers so they will improve 
drinking  water  quality  by  applying  more  treatments.  We  assumed  that  treatments  would  be 
increased by 10 % as compared to baseline.  

• 

As more treatments would be applied, drinking water quality would be improved: 

- 
We assumed that contamination substances currently regulated, would be on average 
at lower concentrations in drinking water. Globally compliance rates with current parametric 

105 

 
 
values would remain similar as in baseline, but more drinking water will contain substances at 
concentration  below  precautionary  limit  values  -  and  as  a  result  contamination  rates  above 
precautionary limit values would be reduced by 10 % as compared to baseline.  

We assumed that contamination of raw water used for individual supply would be of 

- 
similar quality than in baseline. 

• 
This option would also lead to an improvement of trust in drinking water quality and 
thus  we  assumed  that  those  among  population  supplied  by  PWS  but  drinking  bottled-water 
would  partly  switch  to  tap  water  for  their  consumption.  This  reduction  of  bottled  water 
consumption is assumed to 10 % by 2050 (vs. 4 % in baseline). 

3.4.5. Option 4.3. Advanced access to a wider range of information  

Option  4.3  requires  advanced  online  (and/or  via  water  invoices)  access  to  a  wider  range  of 
information  like  on  sources  used,  water  quantity,  water  price,  waste  water  treatment  and 
components  of  water  pricing,  overall  performance  of  the  system  in  terms  of  efficiency, 
leakage rates, energy use, or additional advice.159 Transparency of water prices contributes to 
the implementation of the principle of cost recovery (Article 9 WFD), and gives consideration 
to  the  right  of  the  individual  to  obtain  adequate  information.  Option  4.3  assumes  that  an 
informed population would have some “power” to influence locally water policies and water 
suppliers'  decisions.  Water  suppliers  in  turn  would  then  apply  more  advanced  treatments, 
more  measures  addressing  pollution  at  source  and  more  measures  to  ensure  effective 
management  and  proper  governance.  Therefore,  it  is  assumed  that  drinking  water  quality 
improves as well as the management of the water supply. Sharing this information is expected 
to lead to a change in consumer behaviour that will in turn make the water companies more 
efficient. 

This option will require water service operators to provide information on the management of 
the  drinking  water  systems  in  terms  of:  water  sources  used,  water  quantity,  water  price  and 
components of water pricing, types of treatment, overall performance of the system in terms 
of  efficiency,  leakage  rates,  energy  use,  etc.,  impacts  of  measures  previously  taken  for 
improving  performance,  measures  and  actions  proposed  for  improving  performance  (e.g. 
proposed  investments  for  leakage  rate  reductions),  additional  tips  and  advice  on  how  to 
reduce consumption can be provided depending on local conditions. The information  would 
have to be accessible in a timely manner (and regularly updated) via innovative information 
systems to all drinking water consumers. Some of this information may also be available on 
water invoices for instance, following the model in Annex II of the Proposal for a Directive of 

159 

Further  details  on  the  information  are  included  in  Annex  4,  description  option  4.  Taking  into 
consideration national and regional distinctions, the methodology on pricing, on performance criteria, 
and  on  public  participation  in  decision  making  cannot  be  set  at  EU  level,  but  should  be  up  to  the 
Member States to allow for appropriate solutions close to the consumers and comparisons at national or 
regional level. Also details whether information should be provided on the water bill, and/or together 
with information on sewerage, will be left to Member States.  

106 

 
 
                                                 
the  European  Parliament  and  of  the  Council  on  common  rules  for  the  internal  market  in 
electricity160. 

Access to this information will help consumers to influence water suppliers to become more 
efficient  in  terms  of  water  and  energy  savings  technologies,  leakage  reductions,  to  apply 
modern and online monitoring which can lead to better water quality, and to adopt more cost-
effective  measures  to  address  pollution  at  source  instead  of  treating  polluted  water. 
Information requirements on leakages would trigger specific actions in case of high levels of 
drinking water losses in the network. Information on quality and price would support citizens 
to possibly change their behaviour (bottled water consumption). 

Information systems including online monitoring systems would allow for timely information 
on exceeding parameters or identifying outbreaks, which would permit suitable interventions 
and therefore removing potential risks for the environment. 

To consider national and  regional distinctions, the  methodology on pricing, on  performance 
criteria, and on public participation in decision making cannot be set at EU level, but should 
be  up  to  the  Member  States  to  allow  appropriate  solutions  close  to  the  consumers  and 
comparisons at national or regional level. 

3.4.6. Main assumptions: option 4.3 

Same  investment  and  same  cost  reduction  for  reporting  would  happen  in  this  sub-

• 
option as in Option 4.1 as a consequence of an automatized reporting process. 

• 
Even if the smart- information on water quality would theoretically be provided to all 
persons connected to PWS, we assumed that in fact only 95 % of them would have access to 
this smart-information.  

• 
The  implementation  of  a  system  that  allows  the  collection  of  data  from  water 
suppliers,  the  organization  of  a  national  database  and  the  development  of  websites  and 
applications would require an initial investment (higher than for option 4.2) corresponding to 
sometime  of  work  by  some  persons  dedicated  to  this  task  in  each  MS  and  in  the  European 
Commission / EEA. Once this system developed, the provision of smart-information would be 
more  costly  than  the  current  annual  cost  of  providing  information  and  supported  by  water 
suppliers (9.5 times higher than the current unitary cost per person connected to PWS and per 
year).  

• 
As  a  consequence  of  the  possibility  of  consumers  to  give  their  feedback  on  water 
quality  and  to  participate  to  public  consultations  on  water  quality  and  water  services 
decisions,  population would have  the “power” to  influence drinking  water suppliers so they 
will improve drinking water quality by applying more treatments. We assumed that treatments 
would be increased by 10 % as compared to baseline (as in option 4.2).  

160 COM(2016) 864 final 

107 

 
 
                                                 
And as more treatments would be applied, drinking water quality would be improved 

• 
as in option 4.2: 

- 
We assumed that contamination substances currently regulated would be on average at 
lower  concentrations  in  drinking  water.  Globally  compliance  rates  with  current  parametric 
values would remain similar as in baseline, but more drinking water will contain substances at 
concentration  below  precautionary  limit  values  -  and  as  a  result  contamination  rates  above 
precautionary limit values would be reduced by 10 % as compared to baseline.  

We assumed that contamination by new substances would be reduced as compared to 

- 
baseline (by 15 %). 

We  assumed  that  contamination  of  drinking  water  by  supplementary  substances  is 

- 
similar as in baseline. 

In  addition  to  more  treatments,  citizens  would  also  have  the  “power”  to  make  water 
• 
suppliers implement  more measures addressing pollution  at source instead of treatment. We 
assumed that additional 5 % additional percent of treatments would be replaced by measures 
at source as compared to baseline. 

And  as  a  consequence,  we  assumed  that  contamination  of  raw  water  used  for 

• 
individual supply would be improved as compared to baseline:  

We  assumed  that  contamination  current  and  new  substances  would  be  reduced  as 

- 
compared to baseline (by 10 %).  

We assumed that contamination by new substances would be reduced as compared to 

- 
baseline (by 15 %). 

We  assumed  that  contamination  of  drinking  water  by  supplementary  substances  is 

- 
similar as in baseline. 

• 
This option would also lead to an improvement of trust in drinking water quality and 
thus  we  assumed  that  those  among  population  supplied  by  PWS  but  drinking  bottled-water 
would  partly  switch  to  tap  water  for  their  consumption.  This  reduction  of  bottled  water 
consumption is assumed to 15 % by 2050 (vs. 4 % in baseline). 

Further assumptions on bottled water: 

• 
Life-cycle  assessments  (LCA)  where  the  environmental  impact  of  a  product  is 
assessed in stages from cradle to grave have shown that the environmental impact of bottled 
water is 90 to more than 1000 times higher than that of tap water, depending mainly on how 
far the water is transported. An average EU citizen currently consumes 106 litres of bottled 
water per year. On average, it takes 7 litres of water and 162g of oil to make the plastic for 
each one litre plastic bottle, generating 100g of CO2. The results from different analyses vary 
from 173 to 250g of CO2 eq per litre of water bottled in a plastic bottle, which is up to 6 000 
times more than the ecological footprint of a litre of tap water.  

108 

 
 
Option 4.3 which estimates a reduction against the baseline from 100 to 88 litres per 
• 
year  would  already  reduce  GHG  emissions  by  1.2  million  tonnes  CO2  eq,  which  represents 
20 % of the total energy demand of the whole EU drinking water supply.  

3.5. Objective 5: Access to safe drinking water for all 

The current DWD is focused only on the quality of the drinking water, but has no provisions 
on the supply or access to water. Any decision on supply of and access to water is currently 
fully left to the Member States. It can however be noted that a similar approach requiring the 
provision of waste water collecting systems exists in EU water legislation. The Urban Waste 
Water  Treatment  Directive  91/271/EEC  imposes  all  agglomerations  are  provided  with 
collection  systems  and  treatment  in  settlement  areas  with  more  than  2  000  or  population 
equivalent.  With  regard  to  access  to  drinking  water,  some  Member  States  such  as  Belgium, 
France, Ireland, Italy, Spain and the UK established regulations proposing specific measures 
in the water sector in favour of specific vulnerable and marginalised groups such as travellers, 
Roma and others, minorities (indigenous peoples, first peoples, etc.), illegal immigrants, and 
the  homeless161,  or  that  Slovenia  has  amended  in  2016  its  constitution  to  make  access  to 
drinkable water a fundamental right for all citizens, but effects of such provisions could not be 
could not be quantitatively considered.  

This option concerns the quantitative access to drinking water despite the differing objectives 
of this option compared  to  other options, no details are available whether  those  who do not 
have  access  to  water  as  consequence  suffer  from  health  impacts.  Nevertheless,  it  has  been 
assessed, for consistency purpose, in the same way as the other options.  

This option has been developed as a follow-up to the ECI Right2Water and in line with the 
implementation of the UN Sustainable Development Goals (in particular SDG 6).  

As  clear  criteria  regarding  what  "access"  to  safe  and  clean  drinking  water  supply  exactly 
means are not available, this Impact Assessment has analysed how many EU inhabitants are 
not connected to Public Water Supply (PWS) systems, for example because they live in very 
remote areas or for other reasons (e.g. homeless, migrants, nomadic communities). Based on 
Eurostat  data  it  was  estimated  that  currently  23  million  people  or  4.5 %  of  the  total  EU 
population are not connected to PWS systems.162  

This option aims at exploring two solutions that would ensure access to drinking water to all 
EU28 citizens: extending PWS everywhere (which is a rather theoretical option as technical 

161 

162 

A study by the European Union Agency for Fundamental Rights found that "every third Roma lives in  
housing  without  tap  water"  (FRA,  2016,  p.  9).  The  need  to  provide  Roma  and  other  nomadic 
communities with access to water has been stressed by the European Commission's Communication on 
the EU Framework for National Roma Integration Strategies urging the Member States to change the 
status quo (COM(2011)173 final). The European Council has also issued a recommendation demanding 
"Access  to  housing:  (d)  ensuring  access  to  public  utilities  (such  as  water,  electricity  and  gas)  and 
infrastructure  for  housing  in  compliance  with  national  legal  requirements"  for  Roma  (Council 
Recommendation on effective Roma integration measures in the member states, 2013, p. 7).  
See also Problem Definition, Section 2.2 

109 

 
 
                                                 
impossibilities would exist), or providing individual supply systems to citizens not connected 
to PWS and that are not equipped yet, ensuring the monitoring and treatment of this raw water 
used for self-supply, plus access to drinking water in publicly accessible places like schools or 
restaurants. 

3.5.1. Option 5.1 – Full connection to Public Water Supply systems 

This option would address the issues described above by amending the current DWD with the 
obligation  to  provide  drinking  water  through  PWS  networks  to  all  citizens.  This  would 
expand  the  scope  of  the  DWD,  requiring  water  supply,  in  addition  to  compliance  with 
drinking water quality standards, in all small communities and for any person living in the EU 
(including  Roma  populations  and  migrants).  This  option  guarantees  safe  drinking  water 
quality for all. 

3.5.2. Main assumptions: Option 5.1 

• 
We assumed that 100 % of the population in all MS would be connected to PWS by 
2030  - even though  this assumption is  purely theoretical due to technical infeasibilities (see 
sensitivity analysis). Investments would be necessary to extend the drinking water networks 
(abstraction points, pipes, treatment plants, etc.), and the unitary cost to connect one person 
has been assumed higher for rural population than for urban population, and even higher for 
rural population beyond a connection rate of 95 % than for other rural population . 

• 
As a consequence of the increase  of the population connected to  PWS,  all  operating 
costs of water services would be proportionally higher as compared to baseline (monitoring, 
treatments, measures at source, information, reporting…). 

• 
Those people that do not have access to wholesome drinking water today and so drink 
bottled-water would get suitable tap water instead; the average consumption of bottled-water 
would  decrease.  This  decrease  would  be  marginal  as  compared  to  baseline  at  EU28  scale 
because of the already high average rate of connection to PWS (99 l/ pers/ year vs. 100 l/ pers/ 
year in baseline). 

3.5.3.  Option  5.2  –  Providing  people  not  connected  to  Public  Water  Supply  systems  with 
alternative self-supply systems and/or alternative measures for access to water 

Option 5.2 concerns a set of various measures to improve access to water including, (a) the 
provision of access to water to non-connected citizens with self-supply systems or alternative 
solutions,  (b)  other  appropriate  measures  to  provide  access  to  more  specific  groups  such  as 
remote, vulnerable or marginalised groups, (c) promotional measures to encourage the use of 
tap water, and (d), other measures to promote access to water for instance in public places. 

To  guarantee  access  to  safe  drinking  water  in  this  way,  the  DWD  would  include  a  new 
obligation  that  would  have  to  be  swiftly  transposed  in  national  laws  and  then  fully 
implemented in EU28 by 2030. Such obligation can be fulfilled through a variety of different 
technical,  informational,  and  promotional  approaches.  The  technical  solutions  can  comprise 
improved  wells,  local  disinfection  plants,  better  pumping,  storing  and  local  distribution 
systems, filtering devices, etc. that allow small communities or households to have drinking 

110 

 
 
water provisions close to their premises. Concrete arrangements and implementation would be 
left  to  the  Member  States.  Such  an  option  should  be  supplemented  by  guidance,  regional 
programmes, funding, subsidies etc... This option distinguishes two groups for domestic and 
public places:  

All those that are not connected and not equipped with self-supply systems and would need to 
install systems for the first time. 

Those who are already equipped with some kind of self-supply systems (wells or cisterns for 
example), would require controls and upgrades (e.g. by implementing measures at source to 
improve fresh water quality or by distributing UV treatment devices, etc.) to ensure a quality 
of water close to PWS drinking water quality.  

3.5.4. Main assumptions: option 5.2163 

We  assumed  that  50  %  of  the  population  not  connected  to  PWS  network  would  be 
• 
equipped with individual supply systems, as compared to only 50 % today and in baseline  - 
even though this assumption is theoretical. This would require some investments that would 
be supported either by population concerned either by water suppliers or MS, either both. 

- 
Monitoring:  We  assumed  that  raw  water  used  for  self-supply  will  have  its  quality 
analysed  once  a  year  (taking  water  samples  from  wells  or  from  cisterns)  -  with  costs 
supported by population concerned and/or water suppliers and MS. 

• 
Treatments and measures at source: When raw water used by people not connected to 
PWS is unsuitable for human consumption (according to the parameters of the current Annex 
I  that  would  remain  unchanged),  additional  treatments  (e.g.  with  UV  treatment  devices  for 
cisterns)  and  measures  for  addressing  pollution  at  source  will  have  to  be  implemented.  The 
share  between  treatments  and  measures  at  source  is  assumed  to  be  half-half  for  each  -  with 
corresponding unitary costs taken into consideration. 

- 
As  a  consequence  of  treatments  and  measures  at  source  applied  on  fresh  water  used 
for self-supply, raw water quality will change. We assumed that contamination of raw water 
would  be  reduced  (but  only  in  areas  where  water  is  used  for  self-supply)  -  until  reaching 
approximately the same rate of compliance with current annex I standards than drinking water 
from PWS in 2015. 

- 

Drinking water in PWS networks will remain with a similar quality as in baseline. 

- 
Those people that do not have access to wholesome drinking water today and so drink 
bottled-water would get suitable tap water instead, the average consumption of bottled-water 
would  decrease.  This  decrease  would  be  marginal  as  compared  to  baseline  at  EU28  scale 
because of the already high average rate of connection to PWS (98 l/ pers/ year vs. 100 l/ pers/ 
year in baseline). 

163  

These  assumptions  were  used  for  modelling  the  impacts  of  fully  equipping  half  of  all  non-connected 
people.  

111 

 
 
                                                 
4. Initial screening of the impact of the options 

This table provides an overview of the assumed impact of the various options across a wide 
range of categories covering social, economic and environmental aspects.  

Impact category 

Justification 

Further 
assessment  
(yes/no) 

Economic 
Growth 
investment 

and 

No 

Sectorial 
competitiveness 

Yes 

Facilitating  SMEs 
growth 

Yes 

Achievement 
the Single Market 

of 

Yes 

Increased 
innovation 
research 

Yes 

and 

Technological 
development  and 
digital economy 
Increased 
international trade 
and investment  

Yes 

No 

The options will hardly affect the economic growth and investment in MS. Only two 
options  (providing  SMART  information  to  consumers  and  “harmonisation  of 
materials”)  will  contribute  to  relatively  small  improvement  in the  conditions  for 
investment  and  the  proper functioning  of  markets. These  will  be  discussed  in  the 
context of SMEs.  

Given  that  some  options  will  have  an  effect  on  the  cost  of  production  (primarily 
water companies but also enterprises using drinking water as input), and others will 
lead  to  (technical)  innovations,  impacts  are  further  investigated,  although  the 
effects will apply quite similarly across the EU. With regard to option 3, companies 
and  in  particular  SMEs  involved  in  supplying  materials  and  products  based  in 
Member States that have an approval system will have a competitive advantage, as 
they are used to the rules of the system, while SMEs in other Member States will 
have  to  update  their  processes.  On  the  other  hand,  certification  and  testing 
institutes  in  the  same  Member  States  can  be  expected  to  lose  business  as  new 
materials  would  have  to  be  tested  only  once  to  be  accepted  throughout  the  EU, 
which can then also be done in other Member States. 
This  impact  category  is  linked  to  the  previous  one  and  consequences  for  SME 
growth  as  a  result  of  (new)  products  to  be  developed  or  better  quality  inputs 
(drinking water) available, also justifies further analysis. 

One option (harmonisation of materials) is expected to have a positive impact on 
the  free  movement  of  goods  (materials  and  products  in  contact  with  drinking 
water). This can also lead to an increase in consumer choice (and reduced prices) as 
enterprises producing for this market do not need to obtain approval for exporting 
to individual MS.  
The options which involve new technologies to detect and treat (new) substances 
will have a positive impact on innovation and research. The innovation friendliness 
of  the DWD  revision  was  confirmed  by  an  DG  RTD  Initiative  on  Integration  of  the 
Innovation  Principle  into  New  EU  Policy  Initiatives:  Application  of  R&I  Tool  for 
Better Regulation, analysed at Workshop on "Drinking Water Directive revision and 
Research and Innovation" on23 June 2017. 

Some  impact  is  to  be  expected  from  options  to  provide  ‘SMART’  information  to 
consumers. 

Although an impact on the international trade of ‘materials and products in contact 
with drinking water’ can be expected from the option ‘harmonisation of materials’, 
this  impact  will  be  very  small,  and  difficult  to  quantify  as  trade  statistics  are  not 
available at this level of detail. 

112 

 
 
 
 
 
Competition 

No 

Energy 
independence 

Deeper  and  fairer 
economic 
monetary union 

No 

No 

Social  
Employment 

Working 
conditions 

Income 
distribution 
social inclusion 

and 

Yes 

No 

Yes 

Health and safety 

Yes 

Social protection 

Education 

Security 
Governance 
good 
administration 

and 

the 
Preserving 
cultural  heritage/ 
multi-linguism 
Crime.  Terrorism 
and security 

Social  protection, 
health 
and 
education systems 

No  

No 
No 

No 

No 

No 

As none of the following questions in the ‘competition checklist’ is answered in the 
affirmative,  further  analysis  is  not  needed  for  this  impact  category.  Do  proposed 
options have any of the following effects: i) Limit the number or range of suppliers; 
ii) Limit the ability of suppliers to compete; iii) Reduce the incentive of suppliers to 
compete; and iv) Limit the choices and information available to customers?  

As impact of the options on energy use will be negligible, this category will not be 
further assessed. 

There will be no effect on the monetary union: therefore this category will not be 
further assessed. 

Each option will lead to an increase or decrease of employment in the sector and/ 
or suppliers to the sector. This category will be assessed further. 

Option ‘Access to safe drinking water for all’ would have a positive effect on social 
inclusion  for  vulnerable  groups  such  as  populations  in  rural,  peri-urban  areas  or 
temporary settlements which currently have intermittent drinking water provision 
and quality.  
As the objective of the Directive is directly related to the likelihood of health risk, 
this category will be further investigated. Not only to grasp the quantitative result 
of  the  options  in  terms  of  the  number  of  people  affected  or  the  probability  of 
health risk, but also the financial and economic consequences of these impacts. 

No impact identified 

No impact identified 
No impact identified 

No impact identified 

No impact identified 

No impact identified 

Cultural heritage 

No 

No impact identified 

Environmental 
Fighting 
change 

climate 

Yes (minor) 

A  number  of  options  can  have  a  minor  indirect  impact  on  climate  change.  This  is 
mainly  seen  through  a  marginal  effect  on  energy  consumption  and  the  expected 
decrease  in  the  production  of  bottled  water.  This  is  further  investigated  in  the 
environmental and social impact sections. 

113 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
the 
Fostering 
efficient  use  of 
resources 

Yes 

Yes 

Preserving 
the 
quality  of  natural 
resources/  fighting 
pollution 

Yes 

Protecting 
biodiversity,  flora, 
and 
fauna 
landscapes 

Reducing 
managing waste 

and 

No 

Minimizing 
environmental 
risks 

Yes 

Protecting  animal 
welfare 

No 

Other  

Economic 
social cohesion  

and 

No 

on 

No 

Impact 
developing 
countries 

Sustainable 
development 

Fundamental 
rights 

Yes 

Territorial Impacts  No 

In  the  option  SMART  information  to  consumers,  consumers  and  suppliers  will  be 
provided with incentives for implementing voluntary measures resource efficiency. 
Resource efficiency is in this context mainly related to water efficiency and related 
to energy savings as a result of more efficient water management, and an expected 
decrease in the production of bottled water 

Positive  impacts  will  derive  from  several  options  through  the  improvement  of 
water  resources  where  waste  water  is  discharged  (following  lower  levels  of 
pollutants in drinking water), and reducing pollution at source for water resources 
abstracted,  and  will  lead  to  better  environmental  status  in  water  bodies.  This  is 
mainly a result of option ‘Updated list of parameters’ and ‘Risk Based Assessment’.  
Decrease  in  littering  and  plastic  pollution  of  water  and  marine  environment 
through reduced use of plastic bottles. 
Reducing  the  amounts  of  pollutants  in  drinking  water  and  introducing  more 
treatment  at  source  to  reduce  pollution  will  have  a  positive  impact.  It  is  mainly 
addressed in option ‘Risk Based Assessment’. 

Some  options  might  have  a  marginal  impact  on  reducing  waste,  in  the  case  of 
reduced levels of bottled water consumption. This is however not further explored 
in the report. 

Several  of  the  options  will  lead  to  reducing  the  amounts  of  pollutants  in  drinking 
water  by  unlisted  and  emerging  substances  and  reducing  pollution  at  source  for 
water resources abstracted which will lead to reduced environmental risks. This is 
mainly  addressed 
list  of  parameters’ 
‘harmonisation of materials’ and ‘Risk Based Assessment’. 

through  policy  option 

‘Updated 

No impact identified 

Option ‘Access to safe drinking water for all’ would have a positive effect on social 
inclusion  for  vulnerable  groups  such  as  populations  in  rural,  peri-urban  areas  or 
temporary  settlement  which  currently  have  intermittent  drinking  water  provision 
and quality. 
No impact identified 

All suggested options will bring certain environmental benefits that are aligned with 
sustainable  development.  Options  4.3  and  in  particular  5.2  would  have  positive 
impact  on  implementation  of  SDG  6  Impacts  such  as  limiting  the  amounts  of 
pollutants  in  drinking  water,  suppressing  pollution  at  source  and  improving 
resource  efficiency  will  all  contribute  to  the  improvement  of  the  status  of  water 
bodies, biodiversity, and support the achievement of the objectives of the WFD.  

The option ‘Access to safe drinking water for all’ would expand DWD to include a 
right to safe drinking water and sanitation to all citizens, which is recognized by the 
UN as a human right.  

After discussions within the Commission, it was decided not to conduct a Territorial 
Impact  Assessment  using  one  of  the  methodologies  provided  in  the  Better 

114 

 
 
 
 
 
 
 
 
Regulation toolbox. 
The Evaluation and the reporting results show a very good and even water quality 
in  all  Member  States.  There  are  no  indications  that  specific  regions  have  specific 
differences, and therefore the initial screening suggested that no specific screening 
tool on regional or territorial impact needs to be applied. It can be noted that here 
are  significant  differences  in  raw  water  depending  on  the  origin,  sources,  on 
hardness,  etc.,  but  no  significant  differences  after treatment.  The  latest  Synthesis 
report164, Table 1 Compliance rates at national level in the  Member States (2011-
2013), shows for all compliance rates above 99% and thus no territorial differences. 
The  following  analysis  has  been  carried  out  related  to  Policy  Objective  5  This 
objective  comes  up  against  some  regional  differences,  as  access  to  water  is  a 
problem  in  some  remote  and  rural  areas.  However,  it  can  by  identified  in  which 
Member  States  they  are  by  the  assessment  of  connection  rates,  which  are  with 
over  95  5  %  of  the  overall  EU  population  very  high,  but  low  for  example  in  of 
Romania.  As  to  tackle  this  problem,  option  5.2  foresees  rather  an  enabling 
framework  and  no  stringent  legal  requirements;  the  territorial  impacts  will  be 
limited. It has to be noted that cohesion policy funding exactly in these regions is 
also  intended  to  contribute  to  a  solution  to  this  problem.  Due  to  these 
considerations,  and  that  overall  territorial  differences  are  very  low,  no  specific 
territorial impact assessment has been performed.  

Table 13: Initial screening of the impact of the options 

5.  Health benefits of options compared to the baseline 

The above sections described the approach to estimate the cost of being sick due to drinking 
tap water and to what extend the result of this analysis can be linked to the PPHR outcome for 
the 2015 baseline. These sections showed that, on average, the chance of being at risk is 5 %, 
current costs to society is at least EUR 220 million and the chance of falling 1 day ill due to 
drinking tap water is 0,08 %. For the 2015 baseline there are 23 million people at risk. This 
means that the cost for every person at risk is on average EUR 9.6. 

The resulting PPHR of each option for 2030 and 2050 can be multiplied with the above cost 
to show how that option offsets the increase in societal costs. This offset should be interpreted 
as  the  minimum  health  benefits  (or  cost)  of  a  option.  The  table  below  shows  the  expected 
societal health cost of being sick due to drinking tap water for the 2030 and 2050 baseline –
and the result for each option in 2030 and 2050.165 

Theme 
Baseline (expected total cost) 

Option 1.1 

2030 

 € 194  

 € -46  

2050 

 € 188  

 € -68  

164  

165 

Report 

COM(2016) 

Synthesis 
drink/pdf/reports/EN.pdf 
The expected decrease in population at risk for 2030 and 2050, and the associated lower health cost, are 
mainly due to the autonomous increase of implementing RBA and thus an increase in water quality. 

http://ec.europa.eu/environment/water/water-

final, 

666 

115 

 
 
                                                 
Theme 
Option 1.2 

Option 1.3 

Option 2.1 

Option 2.2 

Option 3 

Option 4.1 

Option 4.2 

Option 4.3 

Option 5.1 

Option 5.2 

2030 

 € -117  

 € 56  

 € -13  

 € -17  

 € -7  

 € -    

 € -64  

 € -73  

 € -19  

 € 0  

2050 

 € -152  

 € 81  

 € -14  

 € -17  

 € -14  

 € -5  

 € -80  

 € -91  

 € -27  

 € -9  

Table 14: Comparison of costs of being sick between baseline and options 

*  Negative  values  indicate  that  there  are  positive  health  benefits  compared  to  the  2030  or 
respective  2050  baseline.  From  this  overview  it  becomes  apparent  that  option  1.2  has  the 
largest short-term positive impact on society (due to less hospitalization cost and less loss of 
production capacity). 

6. Economic impacts per individual option in comparison to baseline 

In this sub-section first the direct economic impacts of the options on the (operations of) the 
drinking  water  providers  will  first  be  analysed.  They  will  be  distinguished  into  setting-up 
costs  and  (annual)  operational  costs.  The  outcome  of  this  assessment  will  be  used  to  assess 
further effects in terms of costs (of inputs, capital, labour, impact on the annual household bill 
and other), and to quantify other indirect effects. 

6.1. Baseline Scenario:  

Specific assessments were made for estimating the specific costs linked to the drinking water 
sector, and thus to the DWD. It is important to remark that operating costs of water services 
are only very marginally impacted by the DWD.166 

Costs (M€) 

Costs 2015  Costs 2030  Costs 2050 

Cost of monitoring (M€/yr) 

1 574 

1 560 

1 481 

166 

See also efficiency analysis in the Evaluation SWD. 

116 

 
 
                                                 
Cost of treatments (M€/yr) 
Cost of measures at source (M€/yr) 
Cost  of  information  and  reporting 
(M€/yr) 
Other costs impacted (M€/yr) 
Total operating costs (M€/yr) 
Setting-up costs (M€) 
Setting-up costs (M€/yr) 
Cost  of  bottled  water  purchase 
(M€/yr) 

8 327 
0167 
4 

0 
46 261 
0,0 
0,0 
5 371 

8 103 
46 
5 

0 
47 085 
5,6 
0,6 
5 345 

8 190 
54 
5 

0 
47 892 
19,6 
2,0 
5 254 

Table 15: Expected trends over time of the implementation costs of the current DWD (2015, 
2030 and 2050), in million EUR 

In this sub-section the cost figures and the resulting direct economic impact compared to the 
baseline scenario for each option and sub-option are presented. For the expected impacts on 
annualized operation cost for each Member State, we refer to the Impact Assessment Study.  

6.2. Individual assessment of the economic impacts per option 

In the following the economic impacts of each option are summarised, including assessments 
of the impacts of individual options.  

6.2.1. For Objective 1 new sampling systems, associated equipment, and additional treatment, 
especially  where  it  concerns  pharmaceutical  or  emerging  substances  are  required.  In  the 
baseline  the  annual  treatment  costs  are  about  EUR 8.3  billion  in  2015.  They  decrease  to 
EUR 8.1 billion in 2030 (mainly caused by the take-up of RBA) and increase slightly towards 
2050. 

For  option  1.1,  the  setting-up  cost  for  monitoring  and  treatment  are  estimated  at  EUR 2 
billion,  and  annual  costs168  at  EUR 535  million.  This  corresponds  to  an  annual  change  per 
household of an addition EUR 2.60.  

For  option  1.2,  the  setting-up  cost  for  monitoring  and  treatment  are  estimated  at  EUR 6 
billion, and the annual costs at EUR 3 137 million. This corresponds to an annual change per 
household of an addition EUR 14.90.  

6.2.2.  Objective  2  relates  to  development  and  implementation  of  a  risk-based  approach  and 
Water  Safety  Plans,  assumed  with  six-monthly/biannual  audits  and  triannual  updates.  For 
large  water  suppliers,  the  costs  of  implementation,  auditing,  updating  is  estimated  at 
respectively  EUR  0.028,  EUR 0.001  and  EUR  0.003  per  persons  served  and  savings  on 

167 

168  

Measures at source are considered to be ‘0’ in 2015 because no data was available. This has  
insignificant effect on our analysis, as the costs in the impacts assessment will focus on the difference 
with baseline 2050 and not 2015. 
"Annual costs" include annual operating costs and annualised set-up costs. 

117 

 
 
                                                 
monitoring costs are expected to be 5 %. For small water supply companies, the costs will be 
about half of this, and no saving in monitoring costs are expected (WHO, 2008). 

For  option  2.1,  the  setting-up  costs  of  RBA  for  large  suppliers  are  estimated  at  EUR 22 
million, and annual savings at - EUR 74 million. This corresponds to an annual reduction per 
household of EUR 0.35.  

For  option  2.2,  the  setting-up  costs  of  RBA  for  large  and  small  suppliers  are  estimated  at 
EUR 25  million,  and  annual  savings  at  -  EUR  93  million.  This  corresponds  to  an  annual 
reduction per household of EUR 0.40.  

In  summary,  options  2.1  and  2.2  are  expected  to  result  in  significant  (mainly  treatment 
related) savings. 

6.2.3.  Objective  3  concerns  the  harmonisation  of  standards  for  materials  in  contact  with 
drinking water. A Panteia study (2016) estimated the current cost to approve/certify products 
and  materials  in  contact  with  drinking  water  at  EUR 1.208  million  per  year  (2.8 %  of  the 
turnover  for  Article  10  products).  In  addition,  the  study  estimated  the  yearly  cost  savings 
through  harmonisation  at  EUR 669  million.  This  available  figure  is  considered  in  the 
calculations,  although  the  approval  costs  and  therefore  the  saving  potential  may  be  slightly 
overestimated.169 Due to limited information, the impacts of option 3 are only assessed at EU 
level. Nevertheless, it is assumed that on household level savings of EUR 3.2 can be expected.  

6.2.4. Objective 4 is related to information requirements. The main economic impact of option 
4 is the following: 

For option 4.1, setting-up costs of a reporting system are estimated at EUR 2.9 million, and 
annual costs at EUR 0.23 million. Costs per household are negligible. 

For option 4.2, the setting-up of simple quality information systems are estimated at EUR 4.2 
million,  and  annual  costs  at  EUR 876  million.  This  corresponds  to  an  annual  change  per 
household of an additional EUR 4.20.   

For  option  4.3,  the  advanced  access  setting-up  costs  are  estimated  at  EUR 5.6  million,  and 
annual costs of EUR 934 million. This corresponds to an annual change per household of an 
additional EUR 4.50.   

Options 4.2 and 4.3 might further create awareness on the quality of tap water and affect the 
level  of  bottled  drinking  water  consumption.  A  reduction  in  bottled  water  consumption  is 
assumed by option 4.2 to be 3 % by 2030 and 10 % by 2050, leading to savings of EUR 336 
million.  Taking  into  account  savings  through  the  reduction  of  bottled  water  consumption, 
option  4.2  will  lead  to  an  increase  in  costs  of  EUR 540  million  by  2050.  A  reduction  in 
bottled water consumption is  assumed by option 4.3 to  be  5 %  by 2030 and 15 %  by 2050, 

169 

See  page  64 
8554a87e7cb5 

'Materials  Study':  https://circabc.europa.eu/w/browse/0b93e708-5e20-4c35-8fbd-

118 

 
 
                                                 
leading to savings of EUR 610 million. Overall option 4.3 will lead to an increase in cost of 
EUR 325 million by 2050. 

6.2.5. Option 5: option 5.1 aims at connecting 100 % of all households in all Member States 
to  a  PWS  system.  Setting-up  costs  are  estimated  at  EUR 82  billion,  and  annual  costs 
compared  to  the  baseline  at  EUR 4  678  million.  This  corresponds  to  an  annual  change  per 
household  of  an  additional  EUR 21.40.  This  EU  average  cost  ranges  for  different  Member 
States  between  EUR 0  to  EUR 93  per  household,  making  this  option  by  far  the  most 
expensive one. For details on the cost distribution, see the Maps below. 

Option 5.2 aims at connecting all citizens to at least a minimum level of water quality through 
alternative  supplies.  For  option  5.2,  setting-up  costs  for  such  self-supplies  are  estimated  at 
EUR 1  411  million,  and  annual  costs  compared  to  the  baseline  at  EUR 530  million.  This 
corresponds to an annual change per household of an additional EUR 2.50.  

Map:  Annual  costs  distribution  by  Member  States  in  Options  5.1  and  5.2  in  comparison  to 
baseline 

7. Assumptions made for the assessment of the synergies of the options 

The following section provides a comprehensive overview of the synergies of the options and 
how the combinations lead to different assumptions.  

The main underlying assumptions regarding synergies are first of all that the inclusion of one 
option firstly brings all costs and benefits that it would have as a stand-alone option into the 
calculation. This can entail consequently higher costs, but also the strong reduction pollution 
in  surface  water  or  very  high  confidence  in  tap  water  for  consumers  within  the  package. 
Additionally to this accumulation of positive and negative quantifications, it was assessed that 
some of the options interact (see Figure 29 to 29 below). For instance, when water suppliers 
have to implement the risk-based approach it is assumed that higher costs arise for measures 
at  the  source  but  simultaneously  treatment  can  be  reduced  by  10  to  15  %.  This  reduces 
therefore  high  treatment  cost  that  arise  primarily  from  option  1.2  that  alone  increases 
treatment by 30 %. Additionally, it is assumed that highly informed consumers (option 4.3) 

119 

Policy option 5.1Annual cost compared to 2050 baseline, x 1.000€  per 10.000 inhabitants0 to 2525 to 50400+-25 to 050 to 100100 to 400-50 to -25Policy option 5.2Annual cost compared to 2050 baseline, x 1.000€  per 10.000 inhabitants0 to 2525 to 50400+-25 to 050 to 100100 to 400-50 to -25 
 
 
 
can  influence  water  suppliers  or  national  authorities  to  treat  water  more  effectively.  
Consequently, a reduction in treatment costs of 1 to 15 % can be expected.  

Figure 26: Assumptions for PP2 
Figure 27: Assumptions for PP2 

120 

Combination 2List A sub. In DW- > WHO guidelines- > stricter limits = BL= 5%New list B sub. In DW- without RBA- with RBA = 1.2% = 0.6%Supplementary list C sub. in DW- without RBA- with RBA = 8.4% = 8.4%List A sub. In RW- > WHO guidelines- > stricter limits = 8.3%  = 18%New list B. sub in RW = 9%Supplementary list C sub. in RW =BLCombination 2Average consumption of bottled water (liters per person and per year)88 l/p/y bcse of the increase of smart info diffusionPossibility for consumers to influence WS decisionsYes, toward more treatments and preventive measuresCombination 2Connection to PWS = BLIndividual systems =Water for all =RBA regulation and effective application (% of population connected to PWS)Mandatory for all WS (will reach 97% of population connected to PWS)Smart info (% of population)Mandatory with also info on performances (will reach 95% in all MS)ReportingAutomatized processStandards materialsHarmonized across all MSNb of par. & Limit valuesUpdate and application of the precautionary principle -> higher number of parameters-> some limit values set to stricter thesholds than WHO guidelines 
 
 
 
 
 
Figure 28: Assumptions for PP3 

121 

 
 
 
Figure 29: Cost assumptions for PP2 

122 

Combination 2Combination 2Unitary costs (expressed per person supplied by the WS)Monitoring costs (average)LWS newly applying RBA: 2.6 EUR/p/yr; Other LWS: 2.7 EUR/p/yrSWS: 8.1/p/yr-> all increased by 15% bcse more substances to monitor-> additionally costs of analysis for non connected households (PO52)RBA implementationIncreased cost for large and small WS than in BL bcse it is "mandatory" RBA (+10%)TreatmentsWS applying RBA: +10%, other WS +15% Materials and products certification /Measures at sourceWS applying RBA: 20.6 EUR/p/yr, other WS: 21.5 EUR/p/yr -> treatment increase becse new substances need to be treated (+ 30% compared to BL)Individual supply systems equipment =Self-supply systems maintenance =Smart-info and auto-reporting systems development0.01  EUR/ persRBA yearly audit -> Total higher than in BL bcse more WS apply RBAPWS extension/Smart-information diffusionHigher cost for smart-info and info on WS performances: 0.041 EUR/p/yrMonitoring and treatment machinesCost of investment in new treatment machines: 7.8 EURCost of investment in new monitoring machines: 3.9 EUR (Total: 11.7 EUR)Reporting to ECAutomatic reporting costs less: 0.004 EUR/p/yr 
 
 
 
Figure 30: Cost assumptions for PP3 

Table 16: General assumptions for the different options 

123 

Combination 3Combination 3Unitary costs (expressed per person supplied by the WS)Monitoring costs (average)LWS newly applying RBA: 2.6 EUR/p/yr; Other LWS: 2.7 EUR/p/yrSWS: 8.1/p/yr-> all increased by 15% bcse more substances to monitor-> additionally costs of analysis for non connected households (PO52)RBA implementationIncreased cost for large and small WS than in BL bcse it is "mandatory" RBA (+10%)TreatmentsWS applying RBA: +10%, other WS +15% + for half of the population costs to treat water from self-supply system (PO52)-> treatments increase bcse of consumers' influenceMaterials and products certificationMeasures at sourceWS applying RBA: 20.6 EUR/p/yr, other WS: 21.5 EUR/p/yr -> treatment increase becse new substances need to be treated (+ 30% compared to BL)-> additionally, costs to treat water from self-supply system (PO52: additionally preventive measures are applied to improve raw water quality used for self-supply 1.73 EUR/p/yr)Individual supply systems equipment130 EUR/ persSelf-supply systems maintenanceWater analysis once a year: 4.7 EUR/p/yrWater treatment systems: 17.3 EUR/p/yr-> Difference with baseline concerns new equipped households (ie 50% of not connected to PWS) Smart-info and auto-reporting systems development0.01  EUR/ persRBA yearly audit -> Total higher than in BL bcse more WS apply RBAPWS extension/Smart-information diffusionHigher cost for smart-info and info on WS performances: 0.041 EUR/p/yrMonitoring and treatment machinesCost of investment in new treatment machines: 7.8 EURCost of investment in new monitoring machines: 3.9 EUR (Total: 11.7 EUR)Reporting to ECAutomatic reporting costs less: 0.004 EUR/p/yr 
 
 
 
Table 17: Assumptions regarding the consumer for the different options 

Table 18: Assumptions regarding the hazardous substances in drinking water for the different 
options 

124 

 
 
 
 
Table 19: Cost assumptions for the different options 

Table 20: Unitary cost assumptions for the different options 

125 

 
 
 
 
8. Ranking of options – underlying ranges 

The below table provides the ranges and cut-off points used to establish Table 4 in Section 7.2 
"Ranking of the options". As Table 4 "Ranking of the options" contains a variety of 
categories, it was deemed necessary to show the various cut-off points and ranges that were 
established for each quantified category. 

Category  Very 
large 
negativ
e 
impact 

Large 
negativ
e 
impact 

Mediu
m 
negativ
e 
impact 

Small 
negativ
e 
impact 

No 
impa
ct 

Small 
positiv
e 
impac
t 

Mediu
m 
positiv
e 
impact 

Large 
positiv
e 
impac
t 

Very 
large 
positiv
e 
impac
t 

- - - - 

- - -  

- - 

- 

-/+ 

+ 

++ 

+++ 

++++ 

Reduction 
of  PPHR  at 
short/mid-
term170 

Reduction 
of  PPHR  at 
long 
term171 

Increase/ 
decrease 
in 
annualised 
costs 
(€million) 

Change 
in 
employme
nt 

/ 

/ 

/ 

/ 

/ 

/ 

HEALTH IMPACT 

/ 

0% 

-1% - -
20% 

-21% - 
-40% 

-41% - 
-60% 

< -61% 

/ 

0% 

-1% - -
4% 

-5% - -
9% 

-10% - 
-14% 

< -15% 

ECONOMIC IMPACT 

> 
+2401 

+1201 
– 
+2400 

+601 – 
+1200 

+1 – 
+600 

0 

-1 - -
600 

-601 - -
1200 

< -
2401  

-1201 
–  

-2400 

< -
60001 

-40001 
–  

-20001 
–  

-1001 
–  

-60000 

-40000 

-20000 

-
1000
>  

0 

<100
0 

1001 – 
20000 

20001 
– 
40000 

40001 
– 
60000 

> 
60001 

Change 

in 

/ 

/ 

/ 

/ 

0 

-1 - -

-41 - -

-81 - -

< -121 

170 
171 

% change in total PPHR to Baseline 
% change in marginal risk population to Baseline 

126 

 
 
 
 
 
 
 
 
 
                                                 
health cost 

in 
per 

Change 
costs 
household 
(€/ year) 

40 

80 

120 

SOCIAL IMPACT 

> 
+15.00 

+10.1 - 
+15 

+5.1 - 
+10 

+0.1 - 
+5 

0 

-0.1 – 
-5 

-5.1 – -
10 

-10.1 - 
-15 

< -
15.00 

127 

 
 
 
 
 
 
 
9.5.   Annex 5  

Monitoring  

Indicators per specific objective:  

Parameters fit for purpose 

Indicator 

Unit of 
measurement 

Parameters 
and Values 
transposed  

Number per 
Member State 

Number per 
Member State 

List with 
parameters and 
numbers per 
water supplier 
and Member 
State 

Additional 
Parameters set 
up by Member 
States  

Cases of 
exceedances 
of the 
parametric 
values set in 
Annex and 
remedial 
action taken 

Occurrence of 
incidents 
including 
causes and 
remedial 
action taken  

Long-term 
health impacts 
due to the 
quality of the 
drinking water  

Source of data 

Transposition 
Check, 
communicated 
legislation 

Transposition 
Check, 
communicated 
legislation 

Frequency of 
measurement 

Baseline 

Full 
Implementation 

Once, updates 
every 6 years  

48 

All 

Once, updates 
every 6 years 

Monitoring results 
collected and kept 
in a data set 

Every 3 years 

First results  

Exceedances 
decrease 

Number, cause, 
significance 

Data set 

Annually 

First 
submissions 

Occurrences 
decrease 

Suitable health 
indicators  

Epidemiologic 
studies in 
conjunction with 
specialised 
organisation like the 
WHO 

Evaluation related, 
every 12 years or 
occasionally  

Health impacts 
decrease 

Risk –based Approach 

Number of 
supplies with 
supply risk 
assessments 

Rate in % of 
water suppliers  

Data set 

Every 6 years 

Currently 
EU  

~96 000 
water 
supplies 

128 

 
 
 
 
 
 
Numbers 

Data set 

Every 6 years 

Lists with 
parameters and 
numbers of 
'allowances' 

Data set  

Every 6 years 

Not 
available 

Abstraction 
hazard 
assessments  

Number of 
cases and 
related 
parameters 
where 
suppliers 
could reduce 
monitoring 
according to 
the RBA  

Materials in contact with Drinking Water and distribution 

Number of EN 
standards with 
test and 
performance 
criteria 
established for 
products in 
contact with 
drinking water 

Domestic 
distribution 
risk 
assessments 

Effective 
actions to 
avoid non-
compliance 
and the risk 
from 
reoccurring 
for lead and 
legionella  

Number 

Commission or 
CEN information 

Permanent/Annual 

Number of 
control and 
management 
measures 
performed 

Number of 
effective action 
taken 

Data set 

Every 3 years 

Not 
available 

Data set 

Every 3 years 

Information to Consumers 

129 

 
 
 
 
 
 
 
 
 
 
100% 

Water supplier 
websites with 
quality 
information  

Number per 
Member State, 
%, up-to-
dateness 

Websites 

Permanent/Annual 

Price of 
drinking water 
per litre, daily 
or annual 
volume 
consumed, 
trends of 
consumption 

Overall 
performance 
including 
leakage rates 
and amount of 
investment  

Euro/litre; 
litre/day and 
person, m3/year 
and person or 
household  

Water suppliers, 
authorities, or from 
consumers that 
receive regularly 
and in the most 
appropriate form, 
websites 

Permanent/Annual 

Rate in % and 
amount in 
million Euro 
per very large 
supplier 

Very large water 
suppliers, Websites 

Permanent/Annual  

Access to Drinking Water 

Currently 
EU  

~96 000 
large water 
supplies 

Currently 
EU average 
annual cost 
per 
household 
EUR 229; 
120 l/day 
and person 

Currently 
EU leakage 
average  
~23 %  

Share of 
population 
that has access 
to drinking 
water  

Share of 
population 
connected to 
public 
drinking water 
supplies  

% per Member 
State 

Data set 

Regularly updated 
every 6 years 

All 

% per Member 
State 

Eurostat  

Regularly updated  

95.5 % 

130 

 
 
 
 
 
 
"Percentage 
of population 
using basic 
safe water" 
UN Indicator 
under 
development 
for SDG 6.1 
Access to 
clean and 
affordable 
Drinking 
Water  

% per Member 
State 

UN, Eurostat  

2030 

All 

131 

 
 
 
 
 
9.6. 

EC  

EU  

DWD    

PPHR  

MS  

PO  

PWS  

RBA    
WHO) 

SDG  

WFD    

WHO    

WSP  

Annex 6   Glossary 

European Commission 

European Union 

Drinking Water Directive 

The indicator Population Potentially at Health Risk refers to the part of 
the population that is supplied with, or has access to, a drinking water 
that  could  contain  pollutants  that  might  potentially  cause  health 
problems. In the context of the assessment of the baseline scenario and 
of  the  different  options,  the  population  supplied  with  drinking  water 
that complies with the current Drinking Water Quality Standards can be 
part  of  the  PPHR,  in  situation  where  pollutants  of  emerging  concern 
and/or compounds not currently covered by Annex II of the DWD but 
that  represent  a  health  risk,  are  present  in  the  drinking  water.  People 
supplied with such water are considered as potentially at health risk (for 
Details: see Annex 4).  

Member State of the European Union 

Policy Options 

The  Public  Water  Supply  is  the  water  supplied  by  operators  that  are 
engaged  in  collecting,  purifying  and  distributing  water  through  public 
networks  (source:  see  Eurostat172).  It  is  complemented  by  “self  and 
other water supply” in the Eurostat typology dealing with the different 
types of (drinking) water supply. 

Risk  Based  Approach/Assessment  (following  the  definition  of  the 

Sustainable Development Goals 

Water Framework Directive 

World Health Organisation 

A  Water  Safety  Plan  (see  also  dedicated  boxes  in  Chapter  6)  is, 
according  to  the  WHO  definition,  a  plan  that  ensures  the  safety  of 
drinking  water  through  the  application  of  a  comprehensive  risk 
assessment  (aimed  at  identifying  all/the  main  sources  of  pollution  or 
pollution  risk)  and  a  risk  management  approach  that  encompasses  all 
components  of  the  water  supply  system  from  water  resources  in  the 

172 

http://ec.europa.eu/eurostat/statistics-explained/index.php/Water_statistics 

132 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
WSZ  

Water Supplier  

catchment  to  the  delivery  to  the  final  consumer.  A  WSP  is  a  part  of 
Water Safety Framework, which contains of step by step activities and 
measures  prepared  by  the  distribution  network  operator  in  order  to 
permanently  and  effectively  ensure  the  wholesomeness,  compliance 
and  cleanliness  of  drinking  water.  The  WSP  is  based  on  the 
identification  of  risks  and  hazardous  occurrences,  risk  assessment, 
taking  preventive  measures  in  order  to  prevent  or  manage  these  risks, 
checking 
the  effectiveness  of  drinking  water  preparation  and 
monitoring  compliance  with  the  regulatory  requirements  relevant  to 
drinking water. 

A  Water  Supply  Zone  is  a  geographically  defined  area  within  which 
water  intended  for  human  consumption  comes  from  one  or  more 
sources  and  within  which  water  quality  may  be  considered  as  being 
approximately uniform (source: DWD). 

Large water supplies (LWS) are those supplying more than 1, 000 m³ 
drinking  water  per  day  as  an  average  or  serving  more  than  5  ,000 
persons (source: DWD) 

Small  water  supplies  (SWS)  are  those  supplying  less  than  1,  000  m³ 
drinking  water  per  day.  Small  water  supply  zones  can  be  subdivided 
into  two  categories:  category  1  supplying  less  than  100m³/day;  and 
category 2 supplying between 100m³ to 1 000m³/day. Individual supply 
providing less than 10 m³ a day as an average or serving fewer than 50 
persons, unless the water is supplied as part of a commercial or public 
activity,  are  considered  as  a  separate  category  exempted  from  the 
provisions of the DWD.  

A water supplier is a company (private or public) in charge of drinking 
water  supply  for  general  domestic  water  use  in  an  agreed  geographic 
area. This company can also be responsible for sewerage management 
and wastewater treatment. In most MS, the company operates under the 
delegation  of  a  public  authority  (municipality  in  general).  A  Water 
operator is a synonym of Water Supplier. Water supply companies/ or 
water operators are part of what is defined as the water industry. They 
can supply water via PWS to different water supply zones (see above), 
or  there  can  be  several  large  and/or  small  water  supply  companies 
supplying water to one water supply zone.   

WWAP  

World Water Assessment Program 

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