COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and Directive 2008/105/EC on environmental quality standards in the field of water policy
Date: 2022-10-26
Institutions: Directorate-General for Environment, European Commission
Subjects: environmental standard, groundwater, pollution control, quality of the environment, surface water, water policy, water pollutant, water pollution, water protection, water resources

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.10.2022  SWD(2022) 540 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council  amending Directive 2000/60/EC establishing a framework for Community action in the field of water policy, Directive 2006/118/EC on the protection of groundwater against pollution and deterioration and Directive 2008/105/EC on environmental quality standards in the field of water policy {COM(2022) 540 final} - {SEC(2022) 540 final} - {SWD(2022) 543 final}  
 
 
Contents 

1 

2 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ...................................10 

PROBLEM DEFINITION .........................................................................................13 

2.1  What are the problems? ...................................................................................14 
2.2  What are the problem drivers? .........................................................................18 
2.3  How likely is the problem to persist? ..............................................................21 
3  WHY SHOULD THE EU ACT? ...............................................................................29 

3.1  Legal basis .......................................................................................................29 
3.2  Subsidiarity: Necessity of EU action ...............................................................30 
3.3  Subsidiarity: Added value of EU action ..........................................................31 
4  OBJECTIVES: WHAT IS TO BE ACHIEVED? ......................................................32 

4.1  General objectives ............................................................................................32 
4.2  Specific objectives ...........................................................................................32 
5  WHAT ARE THE AVAILABLE POLICY OPTIONS? ...........................................32 

5.1  Methodology to select substances and set the quality standards .....................33 
5.2  Description of the policy options .....................................................................37 
5.3  Options discarded at an early stage ..................................................................42 

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS AND WHO WILL 

BE AFFECTED? .......................................................................................................42 

6.1 
Impact assessment methodology ......................................................................43 
6.2  Surface water – impacts of policy options .......................................................47 
6.3  Groundwater – impacts of policy options ........................................................57 
6.4  Monitoring, reporting and administrative streamlining – impacts of options .61 
6.5  Administrative burden .....................................................................................68 
6.6  Note on impacts for individual MS ..................................................................68 

7  HOW DO THE OPTIONS COMPARE AND WHAT ARE THE PREFERRED 

OPTIONS? .................................................................................................................69 

7.1  Surface water ...................................................................................................70 
7.2  Groundwater ....................................................................................................78 
7.3  Monitoring, reporting and administrative streamlining options ......................82 
PREFERRED POLICY PACKAGE .........................................................................84 

8 

8.1  Preferred options summary ..............................................................................84 
8.2  Overall magnitude of impacts ..........................................................................86 
8.3  One In, One Out ...............................................................................................87 
8.4  REFIT ..............................................................................................................88 
9  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ........89 

9.1 
Indicators of success ........................................................................................89 
9.2  Monitoring and evaluation under the existing EU water quality legislation ...89 

1 

 
 
 
9.3 

Joint monitoring and evaluation .......................................................................90 
ANNEX 1: PROCEDURAL INFORMATION .................................................................92 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT).....................96 

ANNEX 3:  WHO  IS AFFECTED AND  HOW? PRACTICAL  IMPLICATIONS OF 

THE INITIATIVE ...................................................................................................116 

ANNEX  4:  ANALYTICAL  METHODS  USED  IN  PREPARING  THE  IMPACT 

ASSESSMENT ........................................................................................................125 

ANNEX  5:  RELATIONS  BETWEEN  ONGOING  INITIATIVES  AND  THE 

PRESENT INITIATIVE ..........................................................................................153 

ANNEX  6:  TECHNICAL  PROCESS  FOR  THE  REVISION  OF  THE  LIST  OF 

PRIORITY SUBSTANCES AND THEIR EQS IN SURFACE WATER ..............159 

ANNEX  7:  TECHNICAL  PROCESS  FOR  THE  REVISION  OF  THE  LISTS  OF 

POLLUTANTS IN GROUNDWATER ..................................................................164 

ANNEX 8: RESULTS OF THE QUALITY STANDARD DERIVATION PROCESS 

FOR REVISION OF THE ANNEXES TO THE EQSD AND GWD .....................175 

ANNEX 9: DETAILED ASSESSMENT OF IMPACTS PER POLICY OPTION ........188 

ANNEX  10:  POTENTIAL  COSTS  OF  SELECTED  SURFACE  WATER  AND 

GROUNDWATER POLLUTION REDUCTION MEASURES ............................216 

ANNEX 11: SURFACE WATER MONITORING DATA ............................................222 

ANNEX 12: LITERATURE REFERENCES ..................................................................228 

2 

 
 
 
 
 
Abbreviations 

Term or abbreviations 

Meaning or definition 

AA 

AC 

AgNPs 

AMR 

BAT 

BPR 

BREF 

BWD 

CAS 

CIRCABC 

CIS 

CJEU 

CLP 

CMR  

DNSH 

DSD 

DSUP 

DWD 

DWS 

EBM 

EC 

ECA 

ECHA 

EDC 

EEA 

Annual Average 

Associated Countries 

Silver (Ag) nano-particles 

Antimicrobial Resistance 

Best Available Techniques 

Biocidal Products Regulation 

Best Available Techniques Reference 

Bathing Water Directive 

Chemical Abstracts Service 

Communication 
and 
Administrations, Businesses and Citizens 

Information  Resource  Centre 

for 

Common Implementation Strategy 

Court of Justice of the European Union 

EU  Regulation  on  Classification,  Labelling  and  Packaging  of 
chemical  substances  and  mixtures  to  the  Globally  Harmonised 
System.  

Carcinogenic, Mutagenic and Reprotoxic 

Do No Significant Harm 

Dangerous Substances Directive 

Directive on Sustainable Use of Pesticides 

Drinking Water Directive 

Drinking Water Standard 

Effect-Based Methods 

European Commission 

European Court of Auditors 

European Chemicals Agency 

Endocrine Disrupting Chemical 

European  Economic  Area/European  Environment  Agency  (Context 
specific) 

3 

 
 
  
Term or abbreviations 

Meaning or definition 

EINECS/EC numbers 

European  Inventory  of  Existing  Commercial  Chemical  Substances 
number/European Community number 

E-PRTR 

EPR 

EQS(D) 

EU 

FC 

FD 

FTE 

GAC 

GES 

GQA 

GWAAE 

GWD 

GWDTE 

GWQS 

GWWL 

IA 

IED 

IPCC 

IPM 

IUPAC 

JRC  

LFR 

MAC 

MS 

MSFD 

NAg 

ND 

NPV 

European Pollutants Release and Transfer Register  

Extended Producer Responsibility  

Environmental Quality Standards (Directive) 

European Union 

Fitness Check 

Floods Directive 

Full-Time Equivalent 

Granulated Activated Carbon (GAC) 

Generic Exposure Scenarios 

General Quality Assessment test for groundwater chemical status 

Groundwater Associated Aquatic Ecosystems 

Groundwater Directive 

Groundwater Dependent Terrestrial Ecosystems 

Groundwater Quality Standards 

Groundwater Watch List 

Impact Assessment 

Industrial Emissions Directive 

Intergovernmental Panel on Climate Change 

Integrated Pest Management 

International Union of Pure and Applied Chemistry 

European Commission Joint Research Centre 

List Facilitating the 6-yearly Review of GWD Annexes I and II 

Maximum Allowable Concentration 

Member State(s) 

Marine Strategy Framework Directive 

Nano-Silver (Ag) 

Nitrates Directive 

Net Present Value 

4 

 
 
Term or abbreviations 

Meaning or definition 

nrMs 

OECD 

OPC 

PACT 

PAH 

PBDE 

PBT 

PC 

PCP 

PFAS 

PFCA 

PFOA 

PFOS 

PFOSA 

PHS 

PMT 

PNEC 

PoMs 

POP 

PRO 

PS 

RBMP 

RBSP 

REACH 

RPF 

RoHS 

SCCS 

non-relevant Metabolites (pesticide degradation products) 

Organisation for Economic Cooperation and Development 

Open/Online Public Consultation 

Public Activities Coordination Tool 

Polyaromatic Hydrocarbon 

Polybrominated Diphenyl Ethers 

Persistent, Bioaccumulative and Toxic 

Participating Countries 

Personal Care Products 

Perfluoroalkyl and Polyfluoroalkyl Substances 

Perfluorinated Carboxylic Acids 

Perfluorooctanoic Acid 

Perfluorooctane Sulfonate 

Perfluorooctanesulfonamide 

Priority Hazardous Substance 

Persistent, Mobile and Toxic 

Predicted No Effect Concentration 

Programmes of Measures 

Persistent Organic Pollutant 

Producer Responsibility Organisations 

Priority Substance 

River Basin Management Plan 

River Basin Specific Pollutant 

Registration, Evaluation, Authorisation and Restriction of Chemicals 

Relative Potency Factor 

Restriction of Hazardous Substances 

Scientific Committee on Consumer Safety 

5 

 
 
Term or abbreviations 

Meaning or definition 

SCHEER 

Scientific Committee on Health, Environmental and Emerging Risks 

SDG 

SSD 

SUPD 

SVHC 

SWD 

TFEU 

ToR 

TV 

TWI 

vPvM 

Sustainable Development Goals 

Sewage Sludge Directive 

Single-Use Plastics Directive 

Substance of Very High Concern 

Staff Working Document  

Treaty on the Functioning of the European Union 

Terms of Reference 

Threshold Value 

Tolerable Weekly Intake 

Very Persistent and Very Mobile 

UWWTD 

Urban Waste Water Treatment Directive 

WB 

WFD 

WG 

WG GW 

WL 

WWTP 

ZPAP 

Glossary 

Water Body 

Water Framework Directive 

Working Group 

Working Group for Groundwater  

Watch List 

Wastewater Treatment Plant 

Zero Pollution Action Plan 

Term or acronym 

Meaning or definition 

Antimicrobial Resistance (AMR) 

AMR occurs  when microbes (e.g. fungi and bacteria) transform over 
time and no longer respond to antimicrobial substances, in particular 
pharmaceuticals  but  also  biocidal  products  and  certain  metals  (e.g. 
silver).  The  main  drivers  of  the  development  of  drug-resistant 
pathogens  are  misuse  and  overuse  of  anti-microbials  e.g.  antibiotics, 
antivirals,  antifungals  and  antiparasitics.  AMR  has  been  declared  as 
one of the top 10 global public health threats facing humanity by the 
World Health Organization. (1) 

Contaminants of emerging concern  According  to  the  Organisation  for  Economic  Co-operation  and 
Development  (OECD)  “Contaminants  of  emerging  concern”  (CECs) 
comprise  a  vast  array  of  contaminants  that  have  only  recently 
appeared  in  water,  or  that  are  of  recent  concern  because  they  have 

6 

 
 
 
Term or acronym 

Meaning or definition 

been detected at concentrations significantly higher than expected, or 
their  risk  to  human  and  environmental  health  may  not  be  fully 
industrial  and 
understood.  Examples 
pesticides, 
chemicals, 
household 
manufactured nanomaterials, and their transformation products’. (2) 

include  pharmaceuticals, 

products, 

personal 

care 

Do No Significant Harm (DNSH) 

Effect-Based Methods (EBM) 

Fitness Check of EU Water Law 

Groundwater 

Microplastics 

Micro-pollutants 

Nanoplastics 

Pesticides 

PFAS 

In the area of this initiative an activity is considered to be in line with 
the  ‘do  no  significant  harm’  to  the  sustainable  use  and  protection  of 
water  and  marine  resources  if  it  contributes  to  achieving  and 
maintaining the good status or the good ecological potential of bodies 
of  water,  including  surface  water  and  groundwater,  or  to  the  good 
environmental status of marine waters. 

EBM are methods for detecting the presence of substances indirectly, 
i.e.  without  conducting  conventional  chemical  analysis.  They  use 
biological  test  systems,  which  can  be  inside  or  outside  a  laboratory, 
and  capture  the  presence  of  chemicals  having  the  same  biological 
effect, for example estrogenic activity or inhibition of photosynthesis. 

Evaluation  of  WFD,  Environmental  Quality  Standards  Directive, 
Groundwater  Directive  and  Floods  Directive,  published  on  10 
December 2019 (SWD(2019)439 final). 

Water which is below the surface of the ground in the saturation zone 
and in direct contact with the ground or subsoil. 

Generally, microplastics are referred to as plastic fragments having at 
least  one  of  their  dimensions  between  0.1  μm−5  mm  in  size.  Note: 
according  to  the  European  Chemicals  Agency  (ECHA),  ‘the  term 
“micro-plastic” is not consistently defined, but is typically considered 
to  refer  to  small,  usually  microscopic,  solid  particles  consisting  of  a 
synthetic polymer. They are associated with long-term persistence in 
the  environment, 
to 
(bio)degradation.’  The  smallest  particle  size  fractions  are  usually 
referred to as nanoplastics (3) 

they  are  very  resistant 

if  released,  as 

Micro-pollutants  are  defined  as  synthetic  or  natural  compounds 
released from point and nonpoint resources and  which end up in the 
aquatic  environments  at  low  concentration  (4),  i.e.  pollutants,  which 
exist  in  very  small  traces  in  water  (5).  Most  micro-pollutants  are 
considered as “Contaminants of emerging concern” (see above). 

Generally,  nanoplastics  are  referred  to  as  plastic  fragments  with  at 
least one of their dimensions from 1 to 100 nm. Nanoplastic particles 
often  present  a  colloidal  behavior  and  are  often  unintentionally 
produced (i.e. from. the wear-and-tear, abrasion, degradation and the 
manufacturing of the plastic objects). 

Pesticides  can  be  described  (with  certain  minor  exceptions)  as  any 
substances  or  mixtures  of  substances  intended  for  preventing, 
destroying,  repelling,  or  mitigating  any  pest;  any  substances  or 
mixtures of substances intended for use as a plant regulator, defoliant, 
or desiccant; any nitrogen stabilizers. (6) 

Per-  and  polyfluoroalkyl  substances  (PFAS)  are  a  family  of  at  least 
4730  compounds  containing  carbon-fluorine  bonds.  Their  lack  of  a 
chemically active group makes them very inert and highly resistant to 
degradation, both during their use andin the environment. Most PFAS 
are also easily transported in the environment covering long distances 

7 

 
 
Term or acronym 

Meaning or definition 

Pharmaceuticals 

Precautionary principle 

Population Equivalent (p.e.) 

Priority 
(P(H)S) 

(Hazardous) 

Substance 

away from their releasing point. PFAS have been frequently observed 
to  contaminate  groundwater,  surface  water  and  soil.  Cleaning  up 
polluted sites is technically difficult and costly. These substances are 
accumulating in the environment, drinking water and food. (7) 

Pharmaceuticals  (medicines,  medications,  drugs)  are  chemical 
substances used in the prevention, diagnosis or treatment of disease. 

The  precautionary  principle  is  designed  to  assist  with  decision-
making under uncertainty and is a core principle of EU environmental 
law, enshrined in  Article 191(2) of the Treaty on the  Functioning of 
the  EU.  The  classic  definition  of  ‘a  precautionary  approach’  comes 
from  the  1992  Rio  Declaration  on  Environment  and  Development, 
stating  that:  "Where  there  are  threats  of  serious  or  irreversible 
damage, lack of full scientific certainty shall not be used as a reason 
for  postponing  cost-effective  measures  to  prevent  environmental 
degradation"  (UNEP  1992)’.  In  cases  where  the  precautionary 
principle  was invoked this  was done under the following conditions: 
1)  an  established  identification  of  potentially  adverse  effects;  2) 
evaluation  of 
the  scientific  data  available;  3)  a  (qualitative) 
assessment of the extent of scientific uncertainty. 

1  p.e.  describes  the  average  water  pollution  load  released  by  one 
person in one day  
The  UWWTD  definition:  ‘1  p.e.  (population  equivalent)’  means  the 
organic  biodegradable  load  having  a  five-day  biochemical  oxygen 
demand (BOD5) of 60 g of oxygen per day.’ In the UWWTD IA, one 
p.e.  includes  on  average  11.18  g/day  for  total  Nitrogen,  and  1.68 
g/day for Phosphorus. 

Surface  water  pollutant  listed  in  Annex  X  of  the  WFD  (later 
superseded by Annex I to the EQSD) and for which measures have to 
be taken to reduce emissions. 
Among these, there are ‘priority hazardous substances’ which means 
substances identified as PBT or of equivalent concern and for which 
measures have to be taken to phase-out emissions completely. 

River  Basin  Management  Plan 
(RBMP) 

River Basin Management Plans are the key tools for implementing the 
Water  Framework  Directive  (WFD).  They  are  drawn  up  after 
extensive public consultation and are valid for a six-year period. (8) 

Surface water 

TFEU 

Inland water, except groundwater, and transitional and coastal waters, 
as well as, with respect to chemical status, territorial waters. 

Treaty on the Functioning of the European Union  
Article  191(2)  of  the  TFEU  states  that  the  “Union  policy  on  the 
environment  shall  aim  at  a  high  level  of  protection  taking  into 
account the diversity of situations in the various regions of the Union. 
It shall be based on the precautionary principle and on the principles 
that  preventive  action  should  be  taken,  that  environmental  damage 
should as a priority be rectified at source and that the polluter should 
pay”. 

8 

 
 
Term or acronym 

Meaning or definition 

Watch List (WL) 

For  surface  waters:  Mandatory  mechanism,  established  by  the  2013 
revision  of  the  Environmental  Quality  Standards  Directive  (EQSD), 
to collect data from MS on surface water pollutants of potential EU-
wide concern. 
For  groundwaters:  Voluntary  mechanism,  established  in  the  CIS,  to 
collect data from MS on groundwater pollutants of potential EU-wide 
concern.  

9 

 
 
 
 
1 

1  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

The European Green Deal (EGD) is Europe’s growth strategy ensuring that by 2050 the EU 
is  transformed  into  a  climate  neutral,  clean  and  circular  economy,  optimising  resource 
management  while  minimising  pollution.  Water  is  an  essential  resource  and  therefore  an 
integral part of the EGD ambition and initiatives, building upon the EU’s comprehensive and 
mature water law. Since the 1990s, significant progress has been achieved in improving water 
quality  through  the  implementation  of  many  EU  laws  regulating  pollution  sources1.  By 
reducing pollution at source and by treating water before release into the environment, many 
past pollution problems were tackled successfully. However, the EU’s water bodies are still 
at risk from certain hazardous substances, which can affect ecosystems  and threaten human 
health. And new pollutants of concern are emerging. 

This initiative is part of the Commission Work Programme 2022 and a key action in the Zero 
Pollution Action Plan (ZPAP)2. This initiative, like all EGD-initiatives, aims at ensuring that 
objectives are achieved in the most effective and least burdensome way, and comply with the 
‘do no significant harm’ (DNSH) principle (see glossary for the water related details). It fine-
tunes,  updates  and  adapts  existing  legislation  in  the  context  of  the  EGD.  Its  focus  is  on 
defining the zero pollution ambition for water pollutants and thereby the level of protection 
for  human  health  and  natural  ecosystems.  The  measures  necessary  to  achieve  this  level  of 
protection  are  addressed  by  several  other,  closely  related,  initiatives  under  the  European 
Green Deal, e.g.3: 

  The  Biodiversity  and  Farm  to  Fork  Strategies,  which  aim  to  reduce  pesticide  use, 
nutrient losses, and sales of antimicrobials (by 50%), as well as fertilizer use (by 20%) 
by 2030. Much of it is to be achieved by the ongoing revision of the Directive on the 
Sustainable  Use  of  Pesticides.  The  upcoming  review  of  Regulation  (EC)  No. 
1107/20094 concerning the placing of plant protection products (PPPs) on the market 
in the European Union could also play a role. 

  The EU Plastics Strategy and the upcoming EU microplastics initiative, which aim to 
deliver  on  the  ZPAP  target  to  reduce  waste,  plastic  litter  at  sea  (by  50%)  and 
microplastics released into the environment (by 30%) by 2030; 

  The Single Use Plastics Directive (SUPD) which aims  to limit the use of single-use 
plastic  products  e.g.  by  introducing  waste  management  and  clean-up  obligations  for 
producers  (incl.  Extended  Producer  Responsibility  (EPR)  schemes),  and  setting 
specific targets including; a 77% separate collection target for plastic bottles by 2025, 
increasing to 90% by 2029; as well as incorporating 25% of recycled plastic in PET 
bottles from 2025, and 30% from 2030. 

  The Circular Economy Action Plan, which announces in particular measures to reduce 
microplastics and the evaluation of the Sewage Sludge Directive (SSD), regulating the 

1 E.g. Urban Waste Water Treatment Directive, Industrial Emissions Directive and Nitrates Directive 
2 Specific commitment to ‘Revise the EQSD and the GWD’ (Action 10, Flagship 3) 
3 A comprehensive list of relevant actions also considered in the baseline assessment is available in Annex 5. 
4 A plant protection product ("pesticide") usually contains more than one component. The component that works against pests/plant diseases 
is called an "active substance". Active substances can be chemicals or micro-organisms. Active substances can only be approved for use in 
plant protection products if they fulfil the approval criteria that are laid down in Regulation (EC) No. 1107/2009. 

10 

 
 
 
                                                           
quality of sludge used in agriculture; the new Regulation on minimum requirements 
for water reuse regulates the quality of waste water if used for agricultural irrigation5. 
  The  Chemicals  Strategy  for  Sustainability,  which  recognises  that  chemicals  are 
essential for the well-being of modern society, but aims to better protect citizens and 
the environment against their possible hazardous properties;  

  The 2019 Strategic Approach to Pharmaceuticals in the Environment (flowing directly 
from  the  2013  revision  of  the  EQSD)  and  the  Pharmaceuticals  Strategy  for  Europe, 
which  both  underline  the  environmental  and  potential  health  impacts  of  pollution 
from  pharmaceutical  residues  and  list  a  range  of  actions  designed  to  tackle  these 
challenges; 

 

  The  Industrial  Emissions  Directive,  currently  under  revision,  which  regulates 
emissions from a large number of installations in the industrial and agricultural sector; 
Internationally,  treaties  such  as  the  Stockholm  Convention  on  Persistent  Organic 
Pollutants and the Minamata Convention on Mercury prohibit or restrict the use of a 
number of the substances covered by this Impact Assessment. The EU, as a Party to 
these  treaties,  constantly  ensure  that  EU  legislation  is  kept  in  conformity  with 
developments  agreed  in  that  context.  Negotiations  on  a  new  global,  legally  binding 
instrument on plastics have been set in motion in 2022. 

  This proposal is also consistent with the final report of the Conference on the Future 
of  Europe  and  the  explicit  recommendations  it  contains  from  citizens  on  zero 
pollution in general and in particular the proposals on tackling pollution. Especially, 
the following final proposals are specifically relevant in this context: 
o  Proposal  1.4  to:  ‘Significantly  reduce  the  use  of  chemical  pesticides  and 
fertilizers, in line with the existing targets, while still ensuring food security, and 
support for research to develop more sustainable and natural based alternatives’; 
o  Proposal  2.7  to:  ‘Protect  water  sources  and  combat  river  and  ocean  pollution, 

including through researching and fighting microplastic pollution’. 

It will, however, ultimately be for Member States (MS) to put together the most cost-effective 
mix  of  measures  to  achieve  the  objectives  set  out  by  this  initiative.  This  is  set  out  in  the 
WFD, the main policy framework for preserving and restoring the quality of European water 
bodies,  laying  down  a  common  framework  for  all  other  water  policies  within  an  integrated 
planning approach. It aims to ensure that all surface and groundwater bodies achieve “good 
status” by a certain deadline and that there is no further deterioration of water quality. For a 
surface  or  groundwater  water  body  (WB)  to  be  classified  in  overall  good  status,  both 
chemical  status  and  either  ecological  or  quantitative  status,  respectively,  must  be  at  least 
good. In particular, for surface waters, WFD Article 16(2) requires the establishment of a list 
of PS and priority hazardous substances (PHS) which present a significant risk to or via the 
aquatic environment. The first such list (constituting Annex X to the WFD) was established 
in 2001, and EQS were established in 2008 in the Environmental Quality Standards Directive 
(2008/105/EC  -  EQSD).  The  list  was  last  revised  in  2013  by  Directive  2013/39/EU  and 
currently contains 45 substances including industrial chemicals, pesticides, and metals.  

The  2013  revision  of  the  EQSD  (Article  8(b))  introduced  an  obligation  to  establish  a  so-
called watch list (WL) of substances for which EU-wide monitoring data are to be gathered to 
inform the review of the PS list. The first WL was established by Commission Implementing 
Decision  (EU)  2015/495  and  included  macrolide  antibiotics  (Erythromycin,  Clarithromycin 

Regulation 

5 
content/EN/TXT/?uri=CELEX%3A32020R0741 

2020/741 

(EU) 

on  minimum 

requirements 

for 

water 

reuse: 

https://eur-lex.europa.eu/legal-

11 

 
 
                                                           
and Azithromycin, used to treat infections), estrogenic hormones (17-beta-estradiol (E2), and 
17-alpha-ethinylestradiol (EE2), mainly used in contraception), neonicotinoid-pesticides (the 
insecticides  Imidacloprid,  Thiacloprid,  Thiamethoxam,  Clothianidin,  Acetamiprid)  and 
Diclofenac (an anti-inflammatory) were included in the first watch list. The list was updated 
in 2018 and 2020. 

For  groundwaters,  pollutants  of  EU-wide  concern  and  their  quality  standards  are  listed  in 
Annex I to the Groundwater Directive (2006/118/EC - GWD) whereas MS have to consider 
setting  national  threshold  values(TVs)  for  the  substances  listed  in  Annex  II.  Annex  II 
substances are found only in a limited number of MS therefore no EU-wide action is needed. 
Both  Annexes  were  last  revised  in  2014.  Annex  I  currently  includes  nitrates  and  active 
substances in pesticides, incl. their metabolites, degradation, and reaction products, whereas 
Annex II contains 12 pollutants or pollution indicators. The 2014/80/EU Directive amending 
the  GWD  expressed  the  need  to  obtain  information  on  additional  substances  posing  a 
potential risk for groundwater (Recital 4). In response to this, in the context of the Common 
Implementation  Strategy  (CIS)  supporting  the  implementation  of  the  EU  water  acquis,  a 
voluntary  watch  list  mechanism  for  pollutants  in  groundwater  was  introduced.  Under  this 
Groundwater  Watch  List  (GW  WL)  process,  MS  agreed  to  voluntarily  collect  data  on 
groundwater  pollutants  of  potential  EU-wide  concern,  to  support  the  identification  of 
(emerging) pollutants for which groundwater quality standards or threshold values should be 
set.  The  “Voluntary  Groundwater  Watch  List  Concept  &  Methodology”  (9)  describes  the 
identification process of substances to be put on the GW WL. 

WFD  Article  10  obliges  MS  to  establish  relevant  emission  limit  values  and  ensure  that  all 
point and diffuse source emissions are controlled based on best available techniques (BAT). 
In  addition,  the  EQSD  and  the  GWD  set  out  more  precisely  what  ‘good  chemical  status’ 
means by defining the level of protection per pollutant and how it is assessed and monitored. . 

Article 16(4) of the WFD requires the Commission to regularly review, at intervals of at least 
every four years, the list of PS that pose a risk to the aquatic environment, i.e. both surface 
and  groundwaters.  Specifically,  for  surface  water,  Article  8  of  the  EQSD  requires  the 
Commission to review Annex X of the WFD (the PS list), while, for groundwaters, Article 
10  of  the  GWD  requires  the  Commission  to  review  every  6  years  Annexes  I  and  II  of  the 
GWD  itself.  The  revision,  and  this  impact  assessment,  also  serve  to  report  to  the  EP  and 
Council, as referred to in Article 8 of the EQSD 

In  2019,  a  Fitness  Check  (FC)  evaluation  of  EU  water  legislation  (10)  was  completed 
covering the WFD, as well as the EQSD and the GWD. The FC concluded6 that, although the 
legislation  is  largely  fit  for  purpose,  there  is  room  for  improvement  in  relation  to  tackling 
chemical  pollution.  The  obligation  to  review  the  lists  of  pollutants  and  their  corresponding 
standards provides an opportunity to also introduce some of the improvements warranted by 
the FC. The changes considered by this initiative (see Chapter 5.4) are linked to the scope of 
the  lists  of  substances,  the  updating  process  as  well  as  related  monitoring  and  reporting 
methods,  which  are  all  aimed  at  improving  the  regulatory  response  to  emerging 
environmental and health risks. Conclusions of the FC related to the slow progress towards 
reaching  WFD,  EQSD  and  GWD  objectives  are  not  directly  addressed  by  the  proposed 
intervention and are instead being addressed, at this stage, by stepped up enforcement actions. 

6 Pages 120-121 (‘emerging challenges’) and 121-123 (‘EQSD and GWD’) 

12 

 
 
                                                           
A possible revision of the lists of pollutants will also improve marine water quality and the 
quality of bathing waters7. There is also a direct link with soil health, in particular in relation 
to  the protection of groundwaters. The proposal  therefore feeds into the preparations of the 
new Soil Health Law foreseen for 2023. In line with the “A Europe fit for the Digital Age” 
Communication, the potential benefits  of digitalisation will be further explored, as they  are 
particularly relevant in the water sector. This will help reduce administrative burden. 

Finally, the revision of the lists of pollutants directly contributes to achieving the Sustainable 
Development Goals (SDGs), specifically SDG 6 on ensuring the availability and sustainable 
management of water and sanitation for all8, SDG 3 on ensuring healthy lives and promoting 
well-being9, as well as SDG 14 on protecting life below water10. 

2 

2  PROBLEM DEFINITION  

Air,  water  and  soil  pollution  affect  human  health  and  biodiversity.  Pollution  is  transferred 
between different water compartments (from groundwater to lakes or rivers and from rivers 
to the marine environment) as well as different environmental compartments (air/water/soil). 
Tackling water pollution is therefore a cornerstone for achieving the Zero Pollution ambition. 
Water pollution is also one of the significant pressures affecting European surface and ground 
waters  (11).  This  initiative  addresses  the  identification  of  new  pollutants  of  concern  and 
adapts the existing lists of pollutants to the latest scientific and technological progress. This 
impact assessment does not address the – current – underachievement of the ‘good chemical 
status’  legal  objective  overall11,  which  forms  the  object  of  the  ongoing  assessment,  by  the 
European  Commission,  of  the  3rd  River  Basin  Management  Plans  (RBMPs),  covering  the 
crucial 2021-2027 time-period and which all MS should have submitted by March 202212.  

Box 1: Status of EU freshwater bodies as reported in 2nd River Basin Management Plans 
The 2nd RBMP reporting showed that only 38% of EU surface water bodies are in good chemical status, while 46% are not 
achieving good status and the status of 16% is unknown (12). There are substantial differences between MS, as shown in 
Figure B1.1. Some report that over 90% of their surface water bodies are in good chemical status, while others report this 
for fewer than 10%.  

7 And thereby help in the review of the Marine Strategy Framework Directive (MSFD) and of the Bathing Water Directive. 
8 Specifically target 6.3: Improve water quality by reducing pollution and minimizing the release of hazardous chemicals and materials by 
2030. 
9 Specifically target 3.9: Substantially reduce the number of deaths and illnesses from hazardous chemicals and water pollution and 
contamination by 2030. 
10 Specifically target 14.1: By 2025, prevent and significantly reduce marine pollution of all kinds, in particular from land-based activities, 
including marine debris and nutrient pollution. 
11 Under the WFD, MS had time until 2015 to ensure good chemical status for their waterbodies, or until 2027  if achieving good status is disproportionally costly. 
12 A total of 11 MS have reported their RBMPs by 5 September 2022. 

13 

 
 
                                                           
Figure B1.1: Chemical status of all surface water bodies for all priority substances per Member State (12) 

As regards groundwater, the 2nd RBMP reporting showed that 75% of EU groundwater bodies are in good chemical status, 
while  24%  are not  achieving  good  status  and  only  for  1%  the  status  is unknown  (12).  There  are  substantial  differences 
between MS, as shown in Figure B1.2. Some report that 100% of their groundwater bodies are in good chemical status, 
while others report this for 3%. 

Figure B1.2: Chemical status of all Groundwater bodies per Member State (12) 

What are the problems?  

2.1  2.1 
The problem definition rests mostly on the findings of the 2019 Fitness Check13 (FC) related 
to  chemical pollution, implementation,  administrative simplification,  and digitalisation. The 
key issue is that the current legislative scope does not sufficiently protect human health and 
ecosystems.  In  addition,  several  administrative and implementation impediments  reduce the 
effectiveness of the legislation and raise the administrative burden of the legislation. The FC 
concluded that the key area to improve and to achieve better results is on chemicals. While 
there is evidence that the WFD, EQSD and GWD have led to reduced chemical pollution of 

13 
%20SWD(2019)439%20-%20web.pdf 

https://ec.europa.eu/environment/water/fitness_check_of_the_eu_water_legislation/documents/Water%20Fitness%20Check%20-

14 

 
 
 
 
 
 
                                                           
the EU’s waters, the analysis points to three areas in which the current legislative framework 
is sub-optimal: 

 

the differences between the MS are much larger than what can be explained by national 
differences  (variability  in  lists  of  local  pollutants  (river  basin-specific  pollutants  and 
pollutants  posing  a  risk  to  groundwater  bodies)  and  the  limit  values  they  should  not 
exceed); 

  updating the list of PS (i.e. adding or removing substances and the corresponding quality 
standards)  is  a  lengthy  process,  partly  because  it  takes  time  to  gather  the  necessary 
scientific evidence and partly because of the ordinary legislative procedure; 
the  EQSD  and  GWD  evaluate  the  risk  to  people  and  the  environment  based  mainly  on 
single  substances,  not  taking  into  account  the  combined  effects  of  mixtures,  and 
inevitably cover only a tiny proportion of the substances present in the environment. 

 

Figure  2.1.1  shows  the  “intervention  logic”  which  links  problem  drivers,  problems, 
consequences  and  specific  objectives  to  the  options  under  consideration.  All  policy  options 
are expected to intervene at the driver and problem level. The intervention logic is the same 
both when single pollutants are considered and when their combination is at stake. 

Figure 2.1.1: Intervention logic 

2.1.1  2.1.1  Lack of ecosystem and human health protection from emerging risks 

Emissions of pollutants in surface and groundwater are linked to agricultural production and 
animal  farming  activities  (pesticides,  pharmaceuticals,  nutrients),  industrial  activities 
(emissions linked to production of various industrial pollutants), consumption and disposal of 

15 

 
 
 
products  containing  pollutants  (e.g.  PFAS  a.k.a.  “forever  chemicals”,  or  plasticizers),  and 
also  healthcare  (increased  consumption,  partially  due  to  ageing  population).  Numerous 
ubiquitous  and  emerging  pollutants  released  from  these  anthropogenic  sources  continue  to 
have  detrimental  effects  on  aquatic  ecosystems,  limit  the  services  they  provide  (recreation, 
drinking water, etc.) and constitute a cause for concern for public health. Significant levels of 
concern  regarding  various  surface  and  groundwater  pollutants  were  also  flagged  during  the 
consultation  activities  (see  Box  2),  indicating  that  more  needs  to  be  done  to  reduce  their 
presence in the aquatic environment. 

Box 2: Concerns regarding surface and groundwater pollutants expressed during consultation activities 

In  the  Open  Public  Consultation  (OPC)  respondents  were  asked  to  rate  their  concern  about  the  presence  of  various 
emerging pollutants in water bodies on a scale of 1 (not at all) to 5 (very much). For surface water, respondents were most 
concerned about pharmaceuticals (average score of 4.2; rated ≥4 by 72% of respondents) as well as pesticides (including 
biocides), substances released from household items (e.g. compounds from plastic products, flame retardants, detergents, 
disinfectants),  and  industrial  chemicals  (e.g.  PFAS)  (all  scored  4.1  on  average;  rated  ≥4  by  72%,  68%  and  67%  of 
respondents,  respectively).  A  slightly  lower,  although  still  high,  level  of  concern  was  expressed  regarding  metals  and 
microplastics (both scored 3.9 on average; rated ≥4 by 63% and 59% of respondents respectively).  

For  groundwater,  OPC  respondents  were  most  concerned  about  fertilisers  (4.3; 71%)  and pesticides  (4.2; 76%),  closely 
followed by industrial chemicals (incl. PFAS) (4.0; 64%), pharmaceuticals (3.9; 63%) substances released from household 
items and metals (3.8; 57%). Least concern was expressed regarding microplastics (3.5; 47%).  

These  substance  groups  were  also of  high  importance to  the  water  stakeholders  and  experts,  as  flagged  in  the  Targeted 
Expert  Consultation  (TEC).  Participants  in  the  TEC  were  most  concerned  about  individual  pharmaceutical  substances 
(61%), (micro)plastics (59%), PFAS (56%), neonicotinoid pesticides (55%) and pyrethroid pesticides (44%). 

The current legislative scope covers 53 single substances or groups of substances for surface 
water  and  14  for  groundwater,  including  pesticides  (their  relevant  metabolites,  degradation 
and  reaction  products),  various  industrial  chemicals  (e.g.  PAHs),  (heavy)  metals  and  other 
pollutants/indicators (e.g. nitrates and nitrites, ammonium, chloride) (see Annex 8 for the full 
lists).  Out  of  the  21  currently  listed  pollutants  considered  under  this  initiative  (see  section 
5.2.1), mercury, nickel,  industrial  chemicals  PBDEs, PAHs (incl.  Fluoranthene), Tributyltin 
and Nonylphenol are among the top 15 most frequently reported PS causing failure to achieve 
good chemical status in surface water bodies (12) and therefore remain highly relevant.  

It  should  be  noted  that  Member  State  a  required  to  report  they  meet  (pass)  or  do  not  meet 
(fail)  quality  standards,  not  the  actual  amount  of  pollutants,  their  geographical  or  sectoral 
sources,  therefore,  the  EU-wide  picture  is  of  actual  amounts  (Table  A11.2  in  Annex  11)  is 
incomplete.  

Most  of  the  currently  listed  pollutants  had  long  been  recognised  as  harmful  to,  or  via,  the 
aquatic  environment;  however,  they  are  only  a  small  subset  of  the  thousands  of  chemicals 
found  in  water  bodies.  The  problem  is  particularly  apparent  for  PFAS,  microplastics  and 
pharmaceuticals. PFAS have been detected at more than 70% of the groundwater measuring 
points in EU MS (13); investigations reveal that existing thresholds are clearly exceeded at a 
considerable  number  of  locations.  Reported  environmental  concentrations  and  associated 
risks  of  microplastics  are  likely  underestimated  (14)  because  most  studies  fail  to  detect  the 
smallest  particles.  Pharmaceutical  contaminants  are  widely  found  in  surface  and  ground 
waters (15) (16) (17), and several publications (18) (19) (20) (21) show that medicines, (ionic 
/nano)  silver  and  antibiotic  residues  can  have  negative  effects  on  aquatic  organisms  and/or 
contribute to antimicrobial resistance (AMR). 

16 

 
 
 
Box 3: PFAS 

A  main  source  of  PFAS  to  humans  and  the  environment  is  their  production  and  use  in  industrial  and  professional 
installations, e.g. as production of fluoropolymers, use of fire-fighting foams, use in the production of textiles, paints and 
printing inks and food contact materials. Another source is the release from consumer products, such as textiles, polishing 
and  cleaning  products,  cosmetics  and  food  contact  materials,  during  their  use  and  at  the  end  of  their  life.  Analysis  of 
sampled products showed that the most commonly detected PFASs in the samples collected in 2016 were PFOA followed 
by PFHxA/PFBA, PFDA.14 PFAS can be released to the environment from industrial and municipal waste-water treatment 
plants,  landfills,  recycling  and  incineration  plants  and  from  re-use  of  contaminated  sewage  sludge.  The  number  of  sites 
potentially emitting PFAS has been estimated to be approximately 100 000 in Europe  (25). PFAS pollution is found in 
surface and groundwater throughout Europe, sometimes in high concentrations, and is also detected in water, sediment and 
animals  in  all  seas.  Although  PFAS-free  solutions  already  exist,  these  chemicals  are  still  unnecessarily  added  to  many 
consumer products creating an irreversible toxic legacy within the EU. 

Substances are considered for listing under the EQSD and the GWD based on the scientific 
assessment  of  their  toxicity  to  humans  and  the  aquatic  environment,  e.g.  because  they  are 
directly toxic, limit  organisms’ ability to  reproduce or because they bio-accumulate in  food 
chains  and  have  the  potential  to  cause  cancer.  The  key  element  of  this  evaluation  is 
(eco)toxicological  data  on  persistence,  bioaccumulation,  carcinogenicity,  mutagenicity, 
reprotoxicity  and  endocrine  disrupting  potential  of  chemicals.  Since  the  adoption  of  the 
existing  EQSs  in  2008  and  2013,  new  evidence  has  become  available  for  some  substances 
already on the Priority Substance (PS) list. This recognises that the scientific understanding 
has  advanced  considerably,  and  that  the  aquatic  environment  is  not  protected  as  well  as  it 
could be, either because the threshold is too high, thus underplaying the risk, or because it is 
too low, hence overplaying the risk and potentially drawing resources away from other, more 
harmful substances. 

Furthermore, without addressing pollutant mixtures, ecosystem and human health protection 
will also remain inadequate. It is estimated that hundreds of chemical mixture combinations 
occur in water bodies throughout the EU  (21). Significant pressures stem from the possible 
cumulative  effects  of  pollutant  mixtures,  as  these  may  be  more  toxic  than  individual 
compounds comprising the mix.  

Finally, the occurrence of certain pollutants within water bodies, such as pesticides, can vary 
significantly  dependent  on,  for  example,  seasonal  economic  activities.  In  agriculture,  for 
example,  specific  application  windows  for  certain  pesticides  can  result  in  large  temporal 
variations of levels in water bodies. Obtaining the peak concentration value is important for 
an adequate health and environmental risk assessment.  

Box  4:  Views  on  key  regulatory  issues  contributing  to  surface  and  groundwater  pollution  expressed  during 
consultation activities 

During  the  Open  Public  Consultation  (OPC),  stakeholders  considered  the  most  important  issues  to  be  the  lack  of 
investment for emissions reduction and lack of incentives to take control measures (such as technological improvements) 
at the source of pollution (both with average score of 3.8 on a scale from 1 – not at all – to 5 – very much; rated ≥4 by 
66%  and  65%  of  respondents,  respectively).  Many  respondents  also  felt  that  there  was  a  lack  of  enforcement  and 
implementation  of  existing  legislation  and  lack  of  use  of  ‘precautionary’  and  ‘polluter  pays’  principles  when  assessing 
risks from new emerging substances (both with average score of 3.7; rated ≥4 by 62% of respondents). 

14 https://norden.diva-portal.org/smash/get/diva2:1118439/FULLTEXT01.pdf 

17 

 
 
 
 
                                                           
2.1.2  2.1.2  Implementation deficits 

The  2019  Fitness  Check  found  that  there  is  a  trade-off  between  the  flexibility  of  the 
Directives,  which  is  needed  to  enable  location-specific  water  management,  and  the 
complexity  that  this  flexibility  creates,  which  forms  an  impediment  to  enforceability  and 
achieving better results. Lack of a harmonised approach among MS to derive EQSs for river 
basin-specific pollutants (RBSPs, which are identified by MS as ‘locally’ relevant pollutants, 
but  do  not  pose  an  EU-wide  risk)  has  resulted  in  significant  differences  in  the  number  of 
identified  substances  and  their  corresponding  EQS  values.  In  addition,  the  differences 
between  national  quality  standards  (QS)  set  by  MS  for  groundwater  polluting  substances 
under Annex II of the GWD are much larger than could be explained by national disparities 
in,  for  example,  chemical  use.  In  many  cases,  these  variations  occur  due  to  various  other 
factors, such as political will, resistance to change or insufficient technical capacity. The lack 
of  harmonisation  was  found  by  the  FC  to  render  the  comparison  between  MS  difficult  for 
substances in Annex II, thus hindering the assessment of EU-wide risks.  

The administrative burden of data management and reporting, although not disproportionate 
given  the  breadth  and  complexity  of  the  legislation  and  the  need  for  it  to  underpin 
implementation  and  enforcement,  remains  comparatively  high.  Reporting  systems  require  a 
very large amount of data and are resource-intensive, needing significant human and financial 
contributions.  Moreover,  because  reporting  only  informs  whether  a  water  body  (WB)  is  in 
good status or not, the insights into the magnitude of exceedances and the related ‘distance to 
target’ are severely limited. This leads to opaque decision-making processes on remediation 
and policy actions to improve water quality, as it is unclear if the most important problems 
and the biggest exceedances are tackled first. Moreover, the data are often outdated, also at 
EU level, which reduces the effectiveness of policy making.  

Finally, updating the lists of pollutants affecting surface and groundwaters can only be done 
via  the  ordinary  legislative  procedure.  Apart  from  being  resource  intensive  and  time-
consuming, it could also be argued that, for what is essentially adapting to scientific progress, 
the ordinary legislative procedure is not the most adequate. The time lag between the initial 
risk  assessment  and  subsequent  legislative  changes  slows  policy  response  to  emerging 
environmental and human health risks. 

Box 5: Progress in WFD implementation 
The  6th  WFD  implementation  report  reveals  improvements  in  knowledge  and  reporting  on  the  WFD  compared  to  the 
previous cycle15. MSThe trend of continuous decline of water quality has been stabilised and partly reversed. Although 
compliance  with  the  WFD  objectives  is  slowly  increasing  achieving  full  compliance  with  the  objectives  of  EU  water 
legislation before the end of the third cycle (in 2027) looks very challenging.  

2.2  2.2 

What are the problem drivers? 

The  problems  described  above  are  largely  driven  by  gaps  and  inefficiencies  of  the  legal 
framework.  Findings  of  the  2019  FC  of  the  WFD  and  the  FD  conclude  that  ubiquitous 
pollutants  and/or  contaminants  of  emerging  concern,  pollutant  mixtures  and  seasonal 
variations of emissions are not adequately captured under the current legal scope; the existing 
flexibilities set out in the legislation are not effective and the reporting system is adequate but 
resource intensive. 

15 https://ec.europa.eu/environment//water/water-framework/impl_reports.htm 

18 

 
 
 
                                                           
2.2.1  2.2.1  Gaps in the legal framework 

2.2.1.1  Emerging pollutants 

While current regulatory efforts focus on monitoring and assessing various legacy chemicals, 
many more anthropogenic chemicals detected in surface waters are currently not included in 
the list of priority (hazardous) substances (PS/PHS) set out in Annex I of the EQSD, or in the 
list  of  harmful  substances  in  groundwater  laid  out  in  Annexes  I  &  II  of  the  GWD.  The 
outdated status of the EU legal scope leads to risks for ecosystems and human health. 

The technical process underpinning this impact assessment identified an EU-wide risk for 24 
substances  (or  substance  groups)  for  surface  water  and  3  groups  for  groundwater, 
highlighting the size of the scope gap. Data on the current levels of these pollutants in EU’s 
water  bodies  are  reported  under  the  mandatory  surface  water  and  voluntary  groundwater 
watchlist  mechanisms,  however,  the  picture  is  very  fragmented,  because  only  a  few  MS 
provide  actual  measured  concentrations  under  the  Surface  Water  Watch  List,  despite  an 
obligation to do so. Existing concentration data have been submitted by 1 to 10 countries (see 
Table A11.1 in Annex 11), therefore, data are only available for each new pollutant from a 
limited number of countries. On request of the MS, this data has been anonymised, hence it is 
not possible to name which MS reported specific values. For groundwater the picture is also 
incomplete. 

The delay of the process and the scope for identifying emerging pollutants is also of concern. 
The SW WL mechanism only  addresses  a limited number of  emerging pollutants, meaning 
that  the  legislation  is  not  up  to  date  with  the  latest  scientific  knowledge.  This  leads  to  a 
delayed  response  or  no  response  at  all  to  health  and  environmental  risks  from  emerging 
pollutants.  Stakeholders  support  the  SW  WL,  but  have  no  consensus  over  necessary 
monitoring frequencies or the frequency of updating the list of PS with WL substances. 

2.2.1.2  Pollutant mixtures 

Current  monitoring  and  reporting  practices  used  under  the  WFD  focus  only  on  individual 
substances  or  groups  of  substances,  and  do  not  adequately  capture  pollutant  mixtures. 
Individual  chemicals  may  interact  additively16,  synergistically17  or  antagonistically18  with 
each  other,  and  in  some  cases  prove  toxic  at  concentrations  below  those  at  which  they  are 
toxic on their own. Exposure to chemical mixtures does not necessarily translate into adverse 
biological  effects,  so  that  it  is  not  always  clear  whether  mitigation  measures  are  needed. 
Thus, adequate monitoring and assessment strategies are essential to provide information on 
which mixtures are present and which have associated combined effects. This knowledge is 
key  for  adequate  risk  evaluations,  as  currently  these  are  only  based  on  individual  risks  of 
single  substances,  but  not  on  the  combined  (cumulative)  effects  of  varying  mixtures  of 
different  substances.  Chemical  monitoring  of  a  few  selected  individual  chemicals  is  less 
informative for identifying the full extent of impacts on water quality, whilst the probability 
of overlooking significant risks is high (23). 

16 Additive interaction means the effect of two chemicals is equal to the sum of the effect of the two chemicals taken separately. 
17 Synergistic interaction means the effects of two chemicals taken together is greater than the sum of their separate effect at the same doses. 
18 Antagonistic interaction means that the effect of two chemicals is actually less than the sum of the effect of the two drugs taken 
independently of each other. 

19 

 
 
 
                                                           
2.2.1.3  Seasonal variation of emissions 

Another  identified  gap  is  that  monitoring  does  not  adequately  capture,  in  some  cases, 
seasonal variations of emissions. This applies to the monitoring of substances listed under the 
WFD/EQSD and the GWD as well as under the SW and GW WL mechanisms. The current 
once-per-year monitoring may miss annual peaks of, for example, pesticides with a specific 
application  window  used  in  agriculture.  Consequently,  risks  may  be  underestimated  and 
managing  the  full  extent  of  the  impacts  on  biological  and  other  water  quality  elements  is 
difficult.  This  is  important  for  example  with  regard  to  mercury.  Understanding  spatial  and 
temporal  trends  for mercury is  crucial in  assessing measures taken both  at  European and at 
global level. It is only by understanding the movement and interaction of mercury within our 
environment that this persistent problem can be tackled. This would also allow to monitor the 
effects of revised Best  Available Technique (BAT) conclusions for large (coal) combustion 
plants, and an EU wide ban on dental amalgam. 

2.2.2  2.2.2  Inefficiencies of the legal framework  

2.2.2.1  Flexibility 

Surface and groundwater pollution is a problem in many parts of Europe19, even if the gravity 
and the exact type of pollutants vary between river basins. Although part of this divergence 
can  be  explained  by  the  different  natural,  geological  and  hydromorphological  conditions  of 
each  river  basin,  an  important  contribution  comes  from  anthropogenic  activities  (from 
agriculture,  industry,  urban  areas  or  other  human  activities),  whose  impact  on  the  status  of 
waters may be of different magnitude and last for variable time lengths. The legislation takes 
this fact into account by setting common standards for EU-relevant pollutants while leaving 
MS the freedom  to  set  river basin  specific standards for other pollutants, which play a role 
locally or regionally, but not per se EU-wide. Therefore, limited guidance for setting national 
chemical  quality  standards  for  RBSPs  is  prescribed  in  the  WFD  (Annex  V  section  1.2.6). 
This  inherent  flexibility  has  however  resulted  in  poor  comparability  of  the  EQS  values 
between  MSs  for  RBSPs20  and  the  corresponding  monitoring  schemes  and  regulatory 
measures.  Furthermore,  the  contrasting  methodologies  used  to  select  RBSPs  also  result  in 
inconsistent identification of relevant substances. The FC concluded that ‘this is an instance 
where the flexibility left to the MS has led to sub-optimal results’.  

Similarly,  the  GWD  allows  considerable  flexibility  for  MS  when  setting  national  threshold 
values  (TVs)  for  the  pollutants  that  are  only  relevant  in  some  MS  and  therefore  listed  in 
Annex  II.  The  process  usually  takes  into  consideration  receptors,  risks,  and  pollutant 
background  levels.  The  inherent  flexibility  provided  in  the  GWD  has  resulted  in  largely 
varied  ranges  of  TVs  across  the  EU21.  For  pollutants/indicators  with  at  least  10  nationally 
established TVs, the differences range from a factor of 1 to 50. Some of these variations are 
logical, as they depend on the natural background levels determined by the geological nature 
of the area, but others depend exclusively on the methodologies used to set the TVs. The FC 
therefore  concluded  that  the  'national'  thresholds  route  does  not  work  effectively,  thus 
justifying harmonised EU action. Moreover, the voluntary nature of the Groundwater Watch 

19 Of the 146,460 surface water bodies in Europe, 31% is affected by atmospheric pollution, 33% by diffuse sources and 15% by point 
sources (EEA). 
20 Surface water: Standard types and threshold values for RBSPs [table] and Surface water: Standard types and threshold values for RBSP 
[country overview] 

20 

 
 
                                                           
 
List  (GW  WL)  limits  the  evidence  gathered  of  pollutants  present  in  groundwater  bodies, 
ultimately limiting the development of groundwater regulation and the establishment of TVs. 

Substances no longer found 

Emissions  of  some  currently  listed  substances  have  decreased  or  ceased  and  the  scientific 
consensus  (considering  legal  bans  of  substances  and  actual  measurements  of  the  concerned 
substances) indicates that there may no longer be an EU-wide threat to surface water quality 
from  some  such  substances.  It  stands  to  reason  that  the  small  numbers  of  MSs  reporting 
failures, and the exceedances being of a very limited magnitude, that it is justifiable that these 
substances are candidates to be proposed for deselection as they no longer pose an EU-wide 
risks. 

2.2.2.2  Resource intensity 

The  existing  legal  framework  for  updating  the  lists  of  pollutants  is  partially  built  on  the 
Watch List system and occurs on a 6-year review cycle. Substances which are identified as 
having a significant EU-wide risk are then considered as candidates for the next review of the 
PS list. However, the noted time lag between revisions and simultaneous delay in obtaining 
conclusive data makes it challenging to have an up-to-date legislative alignment with science 
and a quick response to relevant health and environmental risks. 

Furthermore, the reporting and data sharing system set up under EU water legislation could 
be improved via simplification and automation. Monitoring techniques utilising satellite data, 
automated sensing technologies, citizen science and smartphone applications are still under-
implemented in some MS. Although progress has been made towards further digitalisation of 
monitoring and reporting, the potential is still far from exploited.  

Box 6: Views on ways to improve policy effectiveness expressed during consultation activities 

During  the  OPC,  the  vast  majority  of  stakeholders  supported  all  improvements  listed  in  the  questionnaire.  Improved 
collection of data on new pollutants in a harmonised format via a common information platform was considered the most 
essential (average score of 4.2 on a scale from 1 – not at all – to 5 – very much; rated ≥4 by 77% of respondents). More 
swift updates of GWD Annexes (average score of 3.7; rated ≥4 by 62% of respondents) and of the priority substance list 
(average  score  of  3.6;  rated  ≥4  by  58%  of  respondents)  were  considered  overall  less  important  in  future  strategies  to 
address pollution. 

2.3  2.3 

How likely is the problem to persist? 

The  problem  of  an  insufficient  level  of  protection  of  the  ecosystem  and  human  health  is 
overall  likely  to  persist.  The  dynamic  baseline  scenario  (Chapter  0)  shows  that,  despite  the 
implementation of existing legislation and planned new initiatives that address the problem of 
pollution at source, pathway and end-of-pipe (IED and UWWTD revisions, PFAS ban, SUPD 
revision, etc.), there continues to be a need to track actual progress and identify pollutants of 
emerging concern also at the level of surface and groundwater bodies. Consequently, revising 
the  EU  water  legislation  is  necessary  to  better  protect  the  aquatic  environment  and  public 
health  from  risks  related  to  (emerging)  toxic  pollutants  and  their  mixtures.  All  mentioned 
groups of pollutants have common problems that arise from legislation not being up to date 

21 

 
 
 
 
with  science,  as  well  as  a  lack  of  harmonisation,  inconsistent  implementation,  and 
burdensome data management due to lack of adaptation to digital progress. 

2.3.1  2.3.1  Persisting industrial substances and PFAS pollution  

In the past decade, scientists identified several industrial substances that act as environmental 
contaminants  with  estrogen-like  properties 
including,  dicofol,  nonylphenols,  PCBs, 
endosulfan and Bisphenol-A. Endocrine disruptors are e.g. found in food containers, plastics, 
furniture,  toys,  carpeting  and  cosmetics.  Estrogenic  hormones  and  endocrine  disrupting 
chemicals (EDCs) are detected at polluting levels in surface waters, e.g. sites close to waste 
water treatment facilities, and in groundwater at various sites globally. There is evidence of a 
causal  relationship  between  estrogens  in  the  environment  and  breast  cancer  and  prostate 
cancer.  Estrogens  also  perturb  fish  physiology  and  can  affect  reproductive  development  in 
both domestic and wild animals (24). 

The group of Per- and polyfluoroalkyl substances (PFAS) is extremely prevalent in Europe’s 
water. Some PFAS  are classified as Persistent,  Bioaccumulative  and Toxic (PBT) and very 
Persistent  and  very  Bioaccumulative  (vPvB)22.  The  persistence,  mobility  and  bio 
accumulative nature of PFAS leads to negative effects for human health and biodiversity. The 
bio-accumulative  effects  are  e.g.  illustrated  by  the  results  of  an  EU  LIFE  project  which 
showed that Per-fluoro-octane sulfonic acid (PFOS, one of the many PFAS substances, used 
in  stain  repellents,  impregnation  agents  for  textiles,  paper,  and  leather;  in  wax,  polishes, 
paints,  varnishes,  cleaning  products  for  general  use,  in  metal  surfaces,  and  carpets) 
concentrations in the livers of top predators are severely elevated compared to those present 
in the fish they eat.  

Apart  from  PFAS  used  in  firefighting  foam,  PFAS  emissions  from  coatings  of  carpets, 
clothes, furniture, and paper (incl. food packaging), land spreading of residues from the paper 
industry,  car  wash  facilities,  etc.  will  continue  to  cause  water  related  environmental  and 
health concerns. Many countries23 currently deal with a myriad of PFAS related problems at 
national  level,  e.g.  by  introducing  PFAS  restrictions  and/or  purification  measures.  The 
increasing  number  of  national  measures  underlines  the  need  to  urgently  adopt  EU-wide 
harmonised  quality  standards.  To  avoid  shifting  the  problem  by  substituting  one  PFAS 
substance by another, a quality standard must be set for PFAS substances as a group. This is 
particularly  important  for  substances  like  (ultra)short-chain  per-alkyl  acid  (such  as 
trifluoroacetic acid - TFA) of which very little toxicological data are yet available, but which 
are rising and are expected to entail the same human health risks as other PFAS substances. 

The harmful effects and persistence of PFAS are well-known; thus, several EU policies and 
initiatives  already  partly  tackle  PFAS  pollution,  such  as  the  European  Chemicals  Agency 
(ECHA) proposal,  under the Chemical  Strategy  for Sustainability, to  ban  forever chemicals 
like PFAS from firefighting foams (26).  

2.3.2  2.3.2  Persisting microplastics pollution 

22  Perfluorohexane  sulphonic  acid  (PFHxS)  and  its  salts,  perfluorooctanoic  acid  (PFOA),  perfluorononanoic  acid  (PFNA)  and  its  salts, 
nonadecafluorodecanoic acid (PFDA) and its salts (https://echa.europa.eu/candidate-list-table) 
23 Countries like BE, DE, DK, ES, FR, IT, NL, SE and UK introduced (drinking water) standards up to a maximum 2 ng/l for PFAS 
substances. Also, Denmark introduced a national ban on PFAS in food packaging. 

22 

 
 
 
                                                           
Microplastic  pollution  is  omnipresent.  Microplastics  are  detected  in  80%  of  our  livestock 
feed,  blood,  milk  and  meat  (27),  and  is  also  present  in  human  blood  (28).  Microplastic 
pollution  spreads  across  borders,  regions,  species  and  ecosystems.  An  OECD  report  (29) 
echoes  the  scale  of  the  problem,  indicating  that  "microplastics  have  been  observed  in  all 
surface  waters  and  sediments  of  EU  lakes  (30)  and  rivers,  as  well  as  in  drinking  water”. 
Scientists  find  microplastics  practically  in  every  water  sample  from  EU  lakes  and  rivers. 
Studies from 2016 on the annual amounts of plastics entering surface and groundwater report 
numbers  between  1.15-2.41  million  metric  tons  (31),  whereas  recent  studies  from  2021 
already rate the global annual plastic input at between 9-23 million metric tons (14) (32) (33). 
In the absence of action, the amount of plastic waste entering aquatic ecosystems could triple 
(34)  to  around  53  million  tonnes  per  year  by  2030  (32)  and  quadruple  by  2050.  Recent 
research  showed  that  between  31,000  and  42,000  tons  of  microplastics  (or  86–710  trillion 
microplastic particles) are spread on EU farmlands every  year by the use of sewage sludges 
in  agriculture.  Consequently,  an  average  plot  of  farmland  likely  mirrors  the  microplastic 
levels of ocean surface waters (35). Once in the environment, plastic particles break down to 
nano-plastics.  As  a  result,  concentrations  of  microplastics  will  continue  to  rise  for  decades 
even  if  all  plastic  emissions  cease  now  (14).  Combined  with  the  continuous  degradation  of 
plastics  already  in  the  environment  to  micro  and  nano-plastics,  this  will  result  in  a  50-fold 
increase  of  surface  water  and  ocean  (micro)  plastic  concentrations  by  2100.  Although  EU 
initiatives  like  the  Single  Use  Plastics  Directive,  the  proposed  restriction  of  intentionally 
added  microplastics  (36),  the  upcoming  initiatives  on  unintentional  releases,  the  Textile 
Strategy and other planned EU actions will reduce microplastics at source, their anticipated 
effect  will  only  result  in  an  expected  reduction  of  emissions  by  10%  to  30%  at  best  (see 
Chapter  0  and  Annex  4).  Projected  increases  in  plastic  production,  road  transport  volumes 
and  synthetic  textile  production  in  the  next  decades  also  predict  an  exponential  growth  in 
plastic  emission  levels  under  the  business-as-usual  scenario.  For  unintentional  releases  of 
microplastics from tyre wear, JRC estimates show a 16% increase in driving mileages from 
passenger road transport by 2030 and 30% for by 2050. Freight transport mileage is estimated 
to  increase  by  33%  by  2030  and  55%  by  2050  (37).  Climate  change  effects,  e.g.  more 
frequent  heavy  rainfall  events, 
will  exacerbate  the  problems 
linked  with  releases  of  those 
microplastics  via  urban  runoff 
and  storm  water  overflows 
(SWO),  which  the  upcoming 
revision  of  the  UWWTD  aims 
to  at  least  partly  reduce.  Also, 
for  unintentional 
projections 
releases 
fibre 
foresee a 50% increase by 2030 
business-as-usual 
under 
scenario (see Figure 2.3.1).  

textile 

from 

a 

2.3.3  2.3.3  Persisting pharmaceuticals pollution  

Figure 2.3.1: World fibre production per type in million metric 
tonnes between 1980 and 2030. 

Pharmaceutical  products (mainly medicinal products,  but  also  other personal  care products) 
can act as environmental contaminants (38) (39) (40) (41) (42).  

23 

 
 
 
Personal Care Products (PCPs)  

Personal Care Products  (PCPs), including disinfectants, conservation agents, fragrances and 
UV  screens,  contain  substances  that  are  problematic  in  the  aquatic  environment  such  as 
silver,  triclosan,  microplastics  and  PFAS.  Like  pharmaceuticals,  PCPs  are  designed  to 
maximise their biological activity at low concentrations and produce a prolonged action. The 
major point source for PCPs are waste water treatment plants. Partially effective, the effluent 
of waste water treatment plants does contain PCP residues, subsequently reaching surface and 
groundwater.  

Pharmaceuticals 

Approximately  more  than  100,000  tons  of  medicinal  products  are  consumed  every  year  by 
human patients, the European Union (EU) market being the second biggest consumer in the 
world  after  the  United  States  of  America  (USA)  (43)  (44).  Moreover,  559  active 
pharmaceutical  ingredients  are  found  in  environmental  sectors  such  as  surface  water, 
groundwater, soil etc. 

Some  pharmaceuticals  degrade  relatively  slowly,  and  their  constant  use  can  lead  to 
continuous environmental releases exceeding degradation rates. While the EU has a proactive 
approach  to  reduce  antibiotic  use  in  animals  as  growth  promotors  /  feed  additives  and 
preventive use (45), the projected worldwide increase in the use of antibiotics in feed used for 
rearing livestock animals (67% by 2030 compared to 2015 levels) (18) could nullify progress 
or even potentially aggravate the problem. Ageing populations will also lead to an increased 
use  of  pharmaceutical  products  increasing  sales  of  medication  ‘over  the  counter’,  and  a 
higher  demand  for  control  of  health  risks  for  vulnerable  age  groups.  In  Germany, 
pharmaceutical usage is projected to increase by 43-67% by 2045 as a result (from a baseline 
of 2015). It is estimated that around 8-10% of pharmaceutical substances in the environment 
originate from improperly disposed medicines - flushed down the toilet, poured into drains, 
or  otherwise  disposed  inappropriately  in  household  waste  by  patients  or  even  by  medical 
institutions (46) (47). Increasing awareness amongst citizens across the EU can therefore lead 
to a change in behaviour that can make a substantial difference; a fact recognised under EU 
waste policy. On top of the emissions from unused medicines, between 30-90% of the active 
ingredients in pharmaceuticals are excreted unchanged after consumption (48), and enter the 
environment via sewage treatment works24. Alongside metabolites and degradation products, 
they contaminate water and soil, threatening wildlife and human health. Incorrect disposal of 
unwanted drugs and pollution from pharmaceutical manufacturing plants further compounds 
the problem. In Portugal, 1% of the solid waste produced originates from the medicine sector 
(49). 

Since  conventional  wastewater  treatment  plants  are  not  equipped  to  fully  remove 
pharmaceuticals  from  wastewater,  concentrations  of  active  pharmaceutical  ingredients  in 
soils, biota, sediments, surface water, groundwater and drinking water are likely to increase, 
and thus action at EU level is necessary. The IA underpinning the upcoming revision of the 
UWWTD  states  that  pharmaceuticals  represent  a  large  share  of  potentially  harmful 
substances found in wastewater, corresponding to the toxic environmental load of 264 million 

24 https://www.pharmaceutical-technology.com/comment/commentgreen-pharma-the-growing-demand-for-environmentally-friendly-drugs-
5937344/ 

24 

 
 
                                                           
population  equivalent  (p.e.).  Over  half  of  this  amount  (158  million  p.e.)  comes  from 
centralised treatment plants, with the rest emitted by other sources. Pharmaceutical pollution 
is also tackled via other EU policies25 and initiatives such as the EU Strategic Approach to 
Pharmaceuticals in the Environment which proposed over 30 actions across the life cycle of 
pharmaceuticals (see Box 6 for a state of implementation). 

Box 7: Status of the implementation of the Strategic Approach to Pharmaceuticals in the Environment 

The EQSD, through article 8c of the amended Directive of 2013, required the development of a   Strategic Approach to 
Pharmaceuticals  in  the  Environment.  Since  its  adoption  in  2019, good  progress  has  been  made  in  implementing  the  33 
actions  it  contains  (see  Figure  B1.1),  with  some  being  well  advanced  or  already  completed.  Most  notably,  the  possible 
revision of Urban Waste Water Treatment Directive (UWWTD) to address the increasing problem of micro-pollutants, is 
scheduled for adoption by the Commission this year. The introduction of new pharmaceuticals in the Surface Water Watch 
List26, will increase knowledge about presence of pharmaceuticals in water. Within the same time frame, the revision of 
the  pharmaceutical  legislation,  should  lead  to  more  effective  Environmental  Risk  Assessment  of  pharmaceuticals.  In 
addition, the EU is funding research projects on pharmaceuticals in the environment, e.g. support for the manufacturing of 
greener pharmaceuticals.  

15%

Started

Ongoing

24%

61%

Good Progress

Implemented/Achi
eved

Figure B6.1: Status of actions under the Strategic 
Approach to Pharmaceuticals in the Environment 

2.3.4  2.3.4  Persisting pollution from metals 

Silver  is  a  rare  but  naturally  occurring  metal,  often  found  deposited  as  a  mineral  ore  in 
association  with  other  elements.  Emissions  from  smelting  operations,  manufacture  and 
disposal of certain photographic and electrical supplies, coal combustion, and cloud seeding 
are some of the anthropogenic sources of silver in the biosphere (CICADS, 2002). Silver is 
registered  under  the  REACH  Regulation  and  is  manufactured  in  and  /or  imported  to  the 
European  Economic  Area,  at  ≥  10  000  to  <  100  000  tonnes  per  annum27,  whereas  ECHA 

25 Examples of EU legislation are mentioned in (124) and include Regulation (EC) No. 2160/2003 of the European Parliament and of the 
Council of 17 November 2003 on the control of salmonella and other specified food-borne zoonotic agents; 2013/652/EU: Commission 
Implementing Decision of 12 November 2013 on the monitoring and reporting of antimicrobial resistance in zoonotic and commensal 
bacteria and Directive 2003/99/EC of the European Parliament and of the Council of 17 November 2003 on the monitoring of zoonoses and 
zoonotic agents, etc. 
26 Commission Implementing Decision (EU) 2022/1307 of 22 July 2022 establishing a watch list of substances for Union-wide monitoring 
in the field of water policy pursuant to Directive 2008/105/EC of the European Parliament and of the Council EUR-Lex - 32022D1307 - EN 
- EUR-Lex (europa.eu) 

27 https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/40a35be9-f2e1-4221-b12b-4d3c3f8fcb9d 

25 

 
 
 
 
 
 
                                                           
information  from  2018  indicates  that  the  current  manufacture  and  use  of  silver  amounts  to 
between 100,000 – 1,000,000 tonnes /year28. The use of silver is steadily increasing (year-on-
year increases vary between 5-13% in recent years)29. 

This substance is used in the following products: metals, welding & soldering products, metal 
surface  treatment  products,  adhesives  and  sealants,  biocides  (e.g.  disinfectants,  pest  control 
products),  coating  products,  laboratory  chemicals,  lubricants  and  greases,  metal  working 
fluids and pharmaceuticals. The antibacterial activity of silver has led to an increased use of 
silver in an ever wider range of consumer products. The different forms of silver, including 
silver salts(e.g. silver nitrate), silver oxides and silver materials appear as silver wires, silver 
nanoparticles  (Ag-NP)  and  others,  which  are  used  in  consumer  and  medical  products.  In 
medical care, forms of (nano)silver are used, for example in wound dressings and catheters to 
reduce infections. In consumer products, forms of (nano)silver are used, for example in sports 
and other textiles, washing powders and deodorants, where (nano)silver should reduce odours 
producing bacteria.  

Products  containing  silver  (in  ionic  form  and  as  nanoparticles)  can  act  as  environmental 
contaminants  in  general  and  in  relation  to  the  development  of  anti-microbial  resistance. 
Releases  into  the  environment  of  silver  are  likely  to  occur  from  industrial  use:  in  the 
production of articles and manufacturing of the substance. Other releases to the environment 
of  silver  are  likely  to  occur  from:  indoor  use  in  long-life  materials  (e.g.  flooring,  furniture, 
toys,  construction  materials,  curtains,  foot-wear,  leather  products,  paper  and  cardboard 
products,  electronic  equipment)  and  outdoor  use  in  long-life  materials  (e.g.  metal,  wooden 
and  plastic  construction  and  building  materials)  (ECHA,  2021).  A  number  of  silver 
substances  are  under  evaluation  under  the  Biocides  Regulation  (EU)  No  528/2012  (BPR)  . 
Some  of  the  biocidal  product  types  under  which  the  substances  are  notified  require  the 
deliberate  release  of  silver  into  water  in  order  to  exert  the  claimed  effects,  for  example  for 
human  hygiene,  disinfection  of  food  and  feed  areas,  disinfection  of  drinking  water  or  the 
prevention of pathogens in cooling systems. Other applications may result in release of silver 
into  the  environment  via  the  sewage  system  or  when  exposed  to  rain  outdoor,  for  example 
preservation of paints or preservation of fibre, leather, rubber and polymerised materials. 

When evaluating the end-of-life phase of silver containing products, it is assumed that their 
waste management (recycling, wastewater treatment, landfilling, and incineration) is similar 
to conventional products. Consequently, silver content in non-recycled waste ultimately ends 
up in the environment, as waste in landfills, emissions from wastewater treatment plants, or 
as residual waste from incineration plants.  

According  to  ECHA  information  based  on  REACH  dossiers,  and  tests  performed  with  the 
smallest  nanoform  with  the  highest  specific  surface  area,  have  indicated  that  silver  nitrate 
(ionic  silver)  is  more  toxic  than  the  nanoform  of  silver  (toxicity  to  algae  and  long-term 
toxicity  to  aquatic  invertebrates)  and  that  silver  nitrate  is  equally  or  more  toxic  than  the 
nanoform of silver (toxicity to soil microorganisms).  

28 Substance Evaluation Conclusion as required by  the REACH substance evaluation process (Article 48 of REACH Regulation (EC) No 
1907/2006) and evaluation report for Silver: EC No 231-131-3 

29 https://www.silverinstitute.org/silver-supply-demand/ 

26 

 
 
                                                           
Scientific evidence demonstrates that micro-organisms become resistant against silver. Since 
silver  exhibits  bactericidal  activity  at  concentrations  that  are  not  cytotoxic  to  human  cells, 
they  are important  for medical  use  especially in  the context  of treatments of multi-resistant 
bacteria.  Also,  silver  strongly  enhances  the  antibacterial  activity  of  conventional  antibiotics 
even  against  multi-resistant  bacteria  through  synergistic  effects30.  Consequently,  they  are 
important  as  a  ‘last’  resort  for  treating  infections  with  multi-resistant  bacteria31.  The 
bacterium  ‘Acinetobacter  baumannii’  (a  bacterial  pathogen)  is  listed  as  the  "number  one" 
critical  level  priority pathogen because of the significant  rise of  antibiotic resistance in  this 
species32. Currently, silver still has proven bactericidal activity towards this bacterium even 
against  strains  that  display  multi-drug  resistance.  Therefore,  it  is  of  utmost  importance  to 
avoid  /limit  silver  resistance  in  bacteria  to  avoid  limiting  its  effectiveness  in  treatments  for 
infectious  diseases.  With  the  rise  of  antibiotic  resistant  bacteria,  there  are  also  serious 
concerns of pathogens developing resistance to silver. 

An  OECD  project  focusing  on  availability  of  vitro  methods  for  the  assessment  of  the 
genotoxic  potential  of  nanomaterials,  by  specific  testing  of  nanomaterials  in  a  stepwise 
approach,  evaluated  the  uptake  of  selected  representative  nanomaterials  and  their  in  vitro 
cytotoxicity. For silver it was demonstrated that  silver NMs induced cytotoxicity to various 
degrees depending on the sensitivity of the used cell line 33. While resistance to ionic silver is 
recognised  for  many  years,  many  scientific  studies  also  demonstrate  increasing  bacterial 
resistance  to  silver.  Some  resistance  related  mutations  in  bacteria  are  uniquely  associated 
with resistance to NAg, while others are protective against both NAg and ionic silver. These 
mutations  continued  to  be  detected  after  the  silver  exposure  had  stopped,  indicating  that 
heritable resistance characteristics continue to spread even after discontinued silver use. This 
shows that silver cross-resistance occurs, and indicates the importance of avoiding heritable 
silver resistance. Avoiding Ag-resistance is extra relevant as scientific evidence demonstrates 
that,  bacteria  pre-exposed  to  sublethal  dose  of  silver  also  exhibited  increased  resistance 
toward antibiotics (ampicillin and Pen-Strep) with the half maximal inhibitory concentration 
(IC50)  elevated  by  3  to  13-fold34.  Scientific  evidence  of  silver-driven  co-selection  of 
antibiotic resistance determinants  is  mounting and indicates that an increasing  development 
of  resistance  to  silver  will  additionally  increase  the  resistance  to  other  antibiotics. 
Consequently,  it  is  of  utmost  importance  to  avoid  (further)  antibiotic  resistances  from 
emerging  through  the  process  of  co-selection35,  e.g.  by  reserving  the  use  of  silver  based 
antimicrobials only for treating infections36, in order to preserve its efficacy. 

30  Bacterial  resistance  to  silver  nanoparticles  and  how  to  overcome  it;  Aleš  Panáček,  Libor  Kvítek,  Monika  Smékalová,  Nature 
nanoparticles, 2018, volume 13 p.65-71: https://www.nature.com/articles/s41565-017-0013-y 

31 Effect of Graphene Oxide and Silver Nanoparticles Hybrid Composite on P. aeruginosa Strains with Acquired Resistance Genes; Povila 
Lozovskis et.al., International Journal of Nanomedicine, 17 July 2020, p. 5147-5163: https://pubmed.ncbi.nlm.nih.gov/32764942/ 

32 Emerging Concern for Silver Nanoparticle Resistance in Acinetobacter baumannii and Other Bacteria; Oliver McNeilly, et.al, Frontiers in 
Microbiology 16 April 2021, https://www.frontiersin.org/articles/10.3389/fmicb.2021.652863/full 

33 In vitro cytotoxicity and cellular uptake evaluation gold, silica and silver nanoparticles in five different cell lines: Caco-2, A549, CHO, 
V79 and TK6; Bogni Alessia et.al., 2022: https://publications.jrc.ec.europa.eu/repository/handle/JRC120791 

34 Mechanisms of antibiotic resistance in bacteria mediated by silver nanoparticles; Chitrada Kaweeteerawat, et.al., Journal of toxicological 
environmental health 2017; 80 p.1276-1289  https://pubmed.ncbi.nlm.nih.gov/29020531/ 

35 Emerging Concern for Silver Nanoparticle Resistance in Acinetobacter baumannii and Other Bacteria; Oliver McNeilly, et.al, Frontiers in 
Microbiology 16 April 2021, https://www.frontiersin.org/articles/10.3389/fmicb.2021.652863/full 

36  Heritable  nanosilver  resistance  in  priority  pathogen:  a  unique  genetic  adaptation  and  comparison  with  ionic  silver  and  antibiotics: 
Elizabeth Valentin et.al. Nanoscale, 28 January 2020 p.2384-2392: https://pubmed.ncbi.nlm.nih.gov/31930233/ 

27 

 
 
                                                           
The widespread over-use of (nano)silver and has already led to the release and accumulation 
of silver in water and sediment, in soil and even, wastewater treatment plants (WWTPs) and 
is  thus  impacting  microbial  communities in  different  environmental settings.  The resistance 
mechanism is also linked to the increasing pools of many antibiotic resistance genes already 
detected in samples from different environmental media, which will likely find their ways to 
animals and humans. This is worrisome, as the increasingly indiscriminate over-use of silver 
in non-essential consumer products further promotes the development of silver resistance in 
bacteria. Finally, physical and chemical transformations of  silver can shift the diversity and 
abundance  of  microbes,  including  those  that  are  important  in  nitrogen  cycles  and 
decomposition of organic matter and other key metabolic processes. All in all, the combined 
impacts underline the importance of minimising water related silver-emissions37. 

2.3.5  2.3.5  Persisting pesticide (incl. nrMs) pollution  

Use of pesticides in Europe has not decreased in recent years. In 2019 almost 350,000 tonnes 
of herbicides were sold in Europe, for use in the agricultural sector. The continued high level 
of  sales  is  consistent  with  measurements  of  high  levels  of  pesticides  in  EU  surface  and 
groundwater bodies.  

In  2021  the  EEA  assessed  pesticide  levels  in  surface  and  groundwaters  between  2013  and 
2019.  The  findings  showed  that  one  or  more  pesticides  or  their  metabolites  were  detected 
above  their  effect  threshold  at  13-30%  of  all  surface  water  monitoring  sites  each  year. 
Exceedances were mainly  caused by the insecticides  imidacloprid  and malathion in  surface 
waters, and the herbicides MCPA, metolachlor and metazachlor. Exceedances of one or more 
pesticides were detected at between 3% and 7% of groundwater monitoring sites, mainly by 
atrazine and its metabolites (50). Atrazine, no longer approved for use continued to be found 
in groundwater due to its persistence.  

Exceedance rates of more than 30% were reported in 13 out of 29 countries for surface waters 
and in one out of 22 countries for groundwater. High exceedance rates were mainly reported 
at monitoring sites in small and medium-sized rivers. 

Pesticides and pesticide degradation products (often classed either as ‘relevant metabolites’, 
‘metabolites of no concern’ or ‘non-relevant metabolites’, nrMs)38, have been identified (51) 
in  many  surface  water  and  groundwater  bodies  across  the  EU.  New  nrMs  are  emerging, 
whilst concentrations of known nrMs are increasing. Also, the impact of cocktail effects on 
(ground)water  quality,  i.e.  from  mixtures  of  various  substances  (incl.  nrMs),  remains 
unaddressed  in  the  absence  of  EU  action.  Monitoring  results  from  recent  SW  WL  show 
increasing  concentrations  of  pesticides  across  the  EU.  For  groundwater  ecosystems  the 

37 The impact of silver nanoparticles on microbial communities and antibiotic resistance determinants in the environment, Kevin Yonathan 
et.al. Environmental Pollution 15 January 2022, p.293- 

38 Sanco guidance (45), which is linked to the pesticide authorization regulation (EC 1107/2009), provides the following definitions: 
Relevant metabolite as “a metabolite for which there is reason to assume that it has comparable  intrinsic properties as the active substance 
in terms of its biological target activity, or that it has certain toxicological properties that are considered severe and unacceptable with regard 
to the decision-making criteria described in the text.” 
Metabolite of no concern as “a) CO2 or an inorganic compound, not containing a heavy metal; or (b) an organic compound of aliphatic 
structure, with a chain length of 4 or less, which consists only of C, H, N or O atoms and which has no "alerting structures" such as epoxide, 
nitrosamine, nitrile or other functional groups of known toxicological concern or (c) a substance, which is known to be of no toxicological 
or ecotoxicological concern, and which is naturally occurring at much higher concentrations in the respective compartment.” 
Non-relevant metabolite as “a metabolite which does not meet the criteria for “relevant metabolites” or that for “metabolites of no 
concern”. 
Some MS do not differentiate between nrM and relevant metabolites and consider all pesticide metabolites as “relevant metabolites”. 

28 

 
 
                                                           
situation is also worrying as they are generally more vulnerable to pollutants than freshwater 
ecosystems  due  to  slower  biological  and  physical  degradation  processes  combined  with 
longer residence times for water. This results  in prolonged  exposure times for  groundwater 
flora  and  fauna  due  to  longer  persistence  of  chemicals.  Also,  given  the  great  difficulty  to 
restore contaminated groundwater bodies, an increased protection of groundwater ecosystems 
is essential. Although pesticide emissions are expected to be partly tackled by upcoming EU 
initiatives like the revision of the EU Sustainable Use of Pesticides Directive (SUPD), their 
combined  anticipated  effect  in  short-  to  medium-term  is  modest  (an  expected  emissions 
reduction by 10-30% at best; see Chapter 0 and Annex 4) due to legacy pollution, the use of 
substitutes and stocks. 

2.3.6  2.3.6  Implementation deficits 

Most problems referred to under implementation deficits (Chapter 2.1.2) are intimately linked 
to the existing EU legislation and, therefore, certain to persist without changes made to it, or 
non-legislative  measures with  the same  effect  such as voluntary higher  frequency  reporting 
by  MS.  Issues  linked  to  monitoring,  reporting  and  the  processing  of  data  are  a  mixture  of 
requirements  of  EU  legislation  and  voluntary  practices  developed  over  the  years.  While 
incremental  improvements  (e.g. facilitating correct  and efficient  reporting) are continuously 
made, the implementation deficits will by and large persist if no further initiative is taken. 

2.3.7  2.3.7  Best practice to reduce water pollution at EU level 

The  evaluations  of  the  Industrial  Emissions  Directive  (IED)  and  the  EU  Pollution  Release 
and  Transfer  Register  (E-PRTR)  concluded  that  industrial  installations  covered  by  the  IED 
/E-PRTR, account for about 20% of pollutant emissions by mass to water (52). Consequently, 
an  effective  implementation  of  the  IED  and  E_PRTR,  leads  to  reduced  impacts  on  human 
health  and  the  environment  through  lower  emissions  to  air,  water  and  soil,  reduced  waste 
generation and higher resource efficiency. Figure  3-7 from this evaluation shows that, for a 
number  of  pollutants,  an  absolute  decoupling  of  the  total  mass  emissions  to  water  from 
industry Gross Value Added (GVA) took place. There is a visible declining trend for heavy 
metals  (Cd,  Hg  and  Pb).  In  the  case  of  Nitrogen  (N),  Phosphorous  (P)  and  Total  Organic 
Carbon (TOC) releases have declined since 2007 as well, although to a lesser extent. At the 
same time, figure 3-8 of the same evaluation also shows that, based on 2017 data, despite the 
significant reductions seen to date in emissions from industrial activities, they still contribute 
a significant proportion of total EU emissions for some important pollutants. 

3 

3  WHY SHOULD THE EU ACT?  

3.1  3.1 

Legal basis 

The WFD, EQSD and GWD are based on Article 192(1) of the Treaty on the Functioning of 
the European Union (TFEU) and so will be the revision proposal. Article 191(2) of the TFEU 
states policies shall be based on the precautionary, the polluter pays and the preventive action 
principles (see glossary). As recently re-affirmed by the Zero Pollution Action Plan and the 
zero-pollution hierarchy explained therein, further action needs to be taken according to these 
key  provisions. While water quality standards for pollutants are science-based (see Chapter 
5.1), the application of the precautionary  principle is  particularly  pertinent  for the pollutant 
groups  of  microplastics,  PFAS  and  nrMs.  According  to  the  TFEU,  the  EU  shares 
29 

 
 
competences  with  MS  to  regulate  environment  and  health  in  the  field  of  water,  while 
considering the principles of necessity, subsidiarity and proportionality. 

Also, WFD Article 7(3) contains an obligation for MS to ensure the necessary protection for 
water  bodies  to  avoid  a  deterioration  of  their  quality  and  reducing  the  level  of  purification 
treatment required in the production of drinking water. This includes setting stricter values at 
EU  level  to  ensure  harmonised  implementation  of  this  requirement  and  contribute  to 
compliance with the revised DWD. Finally, EU water legislation includes review clauses that 
enable the revision of the relevant annexes to adjust to technical progress and ensure that a 
high  level  of  protection  is  maintained.  Currently,  the  WFD  Article  16(4)  stipulates  the 
Commission’s obligation to review, every 6 years, the list of PS that pose a risk to the aquatic 
environment. Specifically, for surface water, the requirement to review Annex X of the WFD 
(the PS list) is enshrined in Article 8 of the EQSD; while, for groundwater, Article 10 of the 
GWD requires a review of Annexes I and II every 6 years. 

3.2  3.2 

Subsidiarity: Necessity of EU action  

Surface and groundwater bodies in the EU are polluted by a range of different contaminants, 
ranging  from  residues  of  pharmaceuticals,  pesticides,  microplastics,  industrial  chemicals, 
metals, residues from products used domestically, and nutrients. While existing EU policies 
contribute  to  reducing  the  emissions  at  source  as  well  as  at  pathways,  only  the  setting  of 
sufficiently  strict  environmental  quality  standards  allows  to  check  whether,  across  the  EU, 
surface  and  groundwater  pollution  levels  remain  below  concentrations  harmful  to  the 
environment and/or human health – subject to proper monitoring and implementation by MS. 

The  potential  for  long-term  and  irreversible  risks  to  ecosystems  and  human  health  from 
emerging contaminants necessitates EU measures to halt the bioaccumulation and limit health 
risks. While some of these pollutants can in part be addressed through end-of-pipe measures 
(such as the UWWTD), upstream solutions are also essential to limit pollutant emissions and 
to  avoid  passing  the  bill  for  treatment  to  the  end-user.  This  is  particularly  important 
considering  that  Article  7(3)  of  the  WFD  (protection  of  areas  used  for  the  abstraction  of 
drinking  water),  is  ‘under-implemented’  and  necessitates  drinking  water  and  urban  waste 
water treatment plant operators to deploy costly treatment methods.  

Measures to be taken to reduce the presence of the listed pollutants are often a combination of 
EU  (e.g.  EU  product  bans  or  operating  standards)  and  local  action  (e.g.  industrial  emission 
limits or waste water plant operating conditions adjusted to local circumstances). Addressing 
pollution  without  action  at  international  level  would  in  many  cases  be  prohibitively 
expensive,  especially  for  downstream  countries.  Therefore,  action  at  EU  level  is  of 
paramount importance. 60% of European river basin districts are international (either shared 
between  MS  or  between  a  MS  and  a  3rd  country)  and  the  WFD  made  cooperation  between 
countries sharing a basin within the EU mandatory. Pollution often finds its source in part or 
entirely  in  one  country,  making  international  cooperation  essential  to  reduce  pollution  in  a 
cost-efficient  manner.  Substances  listed  under  the  legislation  automatically  become  part  of 
the mandatory cooperation (for intra-EU river basins) or of the “endeavours” (for river basins 
shared with non-EU countries) MS are required to make according to WFD Article 13. 

A failure to address risks from emerging pollutants swiftly via EU wide quality standards can 
lead to  incorrect  risk assessments  for  groups of substances regulated  at  EU level.  This  also 
leads  to  an  underestimation  of  human  health  and  environmental  risks  associated  to  certain 

30 

 
 
groups of substances of very high concern. Finally, if unaddressed, the cumbersome reporting 
and  a  lack  of  data  sharing  between  different  legislative  areas  and  between  countries  will 
continue to lead to potentially delayed and inefficient policy measures. 

Box 7: Views on the relevance of EU water legislation expressed during consultation activities 

OPC  respondents  considered  the  water  directives  and  regulations  highly  relevant  for  environmental  protection  (average 
score  of  4.2  on  a  scale  from  1  –  not  at  all  –  to  5  –  very  much),  agriculture  sector,  wastewater  treatment  and  health 
protection (each scored at 4.1), and biodiversity protection (4.0), with the relevance deemed highest at EU level (4.3) for 
all these areas. Overall, the directives were not seen as relevant for the circular economy (3.6), particularly at a local level 
(3.3). 

3.3  3.3 

Subsidiarity: Added value of EU action  

The  2019  FC  of  EU  water  legislation  confirmed  the  added  value  of  the  WFD,  EQSD  and 
GWD.  The  Directives  have  triggered  or  reinforced  action  at  European  level  to  address  the 
transboundary  pressures  on  water  resources  at  river  basin  level,  both  nationally  and 
internationally.  Experts  interviewed  during  the  FC  consultation  highlighted  the  power  of  a 
long-term binding policy target  and the fact  that  the Directives’ level  of  ambition is  higher 
than what  could have been expected without them. Additionally, stakeholders consulted for 
this  Impact  Assessment  considered  imposing  stringent  standards  at  EU  level  to  be  more 
effective  in  addressing  surface  and  groundwater  pollution  than  action  at  national  level  (see 
Box 8). 

Box 8:  Views  on  effective  strategies  to  address  surface  and  groundwater  pollution  expressed  during  consultation 
activities 

During the OPC, stakeholders were asked to rate from 1 (not at all) to 5 (very much) the effectiveness of certain strategies 
in  addressing  surface  and  groundwater  pollution.  “Regulation  of  the  application  and  use  of  pesticides  and  biocides” 
(average  rating  of  4.3,  rated  ≥4  by  74%  of  respondents)  was  considered  to  be  the  most  effective,  closely  followed  by 
“Regulations  at  EU  level  to  ensure  pollutant  presence  and  exceedance  are  minimised  through  stringent  standards”, 
“Regulation of emissions from UWWTPs” and “Point source-based pollution control through regulation (legally binding)” 
(average rating of 4.2, rated ≥4 by 79%, 74% and 72% of respondents respectively). “Regulations at MS level to ensure 
pollutant presence and exceedance are minimised through stringent standards” were viewed to be less effective (average 
rating of 4.0, rated ≥4 by 68%).. 

Specifically  in  relation  to  pollutants,  the  legislation  distinguishes  between  substances  most 
appropriately legislated  at  EU level  and those to be regulated at  river basin  or  groundwater 
basin  level.  The  substances  considered  for  addition  to  the  pollutant  lists  belong  to  the  first 
category as they raise an EU-wide concern (see Chapter 5.1.1 for explanation of how these 
are selected). This revision process also identified a small number of existing PS that are no 
longer considered substances of EU-wide concern, but which might still need to be addressed 
at national level as (RBSPs). Those substances are covered under surface water policy option 
4 (possible deselection). For the latter, it supports a mechanism transferring former EU EQSs 
to  an  EU-wide  repository  of  standards,  to  be  applied  if  the  substances  are  identified  as 
RBSPs,  to  safeguard  a  harmonised  approach  to  the  extent  possible,  and  thus  contribute  to 
maintaining a level playing field between MSs. 

Market authorisation and risk assessment of many of the substances concerned takes place at 
EU level (e.g. pharmaceuticals, pesticides, industrial chemicals) even if national procedures 
co-exist,  providing  for  a  harmonised  and  cost-efficient  approach,  as  well  as  a  level  playing 
field to those who sell and use the substances.  

31 

 
 
 
 
4 

4  OBJECTIVES: WHAT IS TO BE ACHIEVED?  

Having regard to the accelerated need to reduce the presence of toxic chemicals in water in 
light  of the on-going  triple planetary crisis  (climate change, biodiversity  and pollution), the 
aim  of  this  regulatory  intervention  is  to  update  the  lists  of  substances  and  their  quality 
standards  set  in  the  Annexes  of  the  EQSD  and GWD,whilst  clarifying  their  importance  for 
future drafting and assessments  of RBMPs and modernising the modalities to  keep them in 
pace with scientific and technological developments. .  

4.1  4.1 

General objectives 

Taking into account the overarching objective of EU water policy, the general objectives of 
this initiative are to increase the protection of EU citizens and natural ecosystems in line 
with  the  Biodiversity  Strategy  and  the  Zero  Pollution  ambition  embedded  in  the  European 
Green  Deal,  and  to  increase  effectiveness  and  reduce  administrative  burden  of  the 
legislation,  hence  facilitating  a  quicker  response  to  emerging  risks.  Both  of  these  are  long-
term  aims  that  will  see  limited  positive  progress  without  further  action  under  EU  water 
legislation.  Whilst  implementation  of  other  EU  and  international  policies  can  and  will 
contribute  to  lowering  the  emerging  risks  to  or  via  the  aquatic  environment  (see  dynamic 
baseline assessment in section 0 and Annex 4), none of the other initiatives can guarantee an 
adequate level  of protection is  achieved, hence rendering action under EU water legislation 
essential. 

4.2  4.2 

Specific objectives 

The specific objectives  represent the short-to-medium-term  goals  set to  achieve the  general 
objectives of this revision, and bring closer the overall aim of EU water legislation described 
above. The planned EU intervention would have the following specific objectives: 

1.  Align  the  lists  of  pollutants  affecting  surface  and  groundwater  with  the  latest  scientific 

knowledge. 

2.  Improve  monitoring  of  the  state  and  evolution  of  surface  and  groundwater  pollution  to 

gather more comprehensive evidence for future risk assessments. 

3.  Harmonise the ways pollutants in surface and groundwater are classified and tackled.  
4.  Provide a legal framework that can be more swiftly and easily aligned with science  and 

promptly respond to contaminants of emerging concern. 

5.  Improve  transparency  and  access  to  data,  thereby  facilitating  implementation  (also  of 

existing quality standards) in the MS, as well as reducing administrative burden. 

Because these objectives aim to address specific shortcomings of the WFD, EQSD and GWD 
identified  by  the  Fitness  Check,  they  will  not  be  influenced  by  other  policy  initiatives 
considered under the dynamic baseline (see section 0 and Annex 4).  

5 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS?  

The policy options were derived taking into account the identified problems and objectives as 
described in Chapters 2 and 4, respectively. The intervention logic, introduced in Chapter 2, 
explains  how  the  main  options  are  expected  to  address  the  problems,  their  drivers  and 
consequences while delivering on the specific objectives.  

32 

 
 
This  chapter  outlines  the  methodology  used  to  select  candidate  substances  and  set  their 
quality standards (QS), describes the baseline in case of no legislative action in the field of 
water policy, and presents the policy options identified for consideration. 

5.1  5.1 

Methodology to select substances and set the quality standards 

This section summarises the key elements of the technical processes carried out to prioritise 
substances  for  listing  under  EU  water  legislation  and  derive  their  respective  QSs.  Further 
details can be found in Annexes 4 and 5 of this impact assessment. 

5.1.1  5.1.1  Substance selection 

Identification of new substances to consider listing is based on the risk to or via the aquatic 
environment.  The  risk  assessment  follows  the  criteria  set  out  in  WFD  Article  16(2)  and 
includes, as a minimum, weighing of:  

 

the  intrinsic  hazard  of  the  substance  concerned,  and  in  particular  its  aquatic 
ecotoxicity and human toxicity via aquatic exposure routes; 

  evidence from monitoring of widespread environmental contamination; and 
  other  proven  factors  indicating  the  possibility  of  wide-spread  environmental 
contamination, such as production / use volumes of a substance, and use patterns. 

The  prioritisation  process  for  surface  water  serves  as  a  basis  for  the  determination  of 
substances  either  to  be  selected  as  candidate  PS,  RBSPs  or  for  inclusion  on  the  SW  WL. 
Introduced  by  the  amendment  of  EQSD  in  2013,  the  SW  WL  has  so  far  resulted  in  the 
adoption  of  three  Commission  implementing  decisions  establishing  a  list  of  substances  for 
Union-wide monitoring in the field of water policy. Under the SW WL, emerging substances 
are monitored at selected EU representative monitoring stations for at least 12 months, and up 
to  4  years.  Monitoring  data  for  pollutants  listed  in  the  first  two  Commission  implementing 
decisions have been used to derive the candidate PS list for this initiative. The candidate PS 
indicate the pollutants for which an EU-wide risk has  been established, warranting an EQS 
derivation  and  impact  assessment.  This  process  resulted  in  24  individual  substances  and  a 
group of 24 PFAS being selected. 

There is an urgent need to address microplastics at source in view of the ever increasing loads 
of microplastics in EU surface and groundwater. A ban on the intentional use of microplastics 
in products, including fertilisers, cosmetics, detergents would prevent the release of 500,000 
tonnes  of  microplastics  into  the  environment  over  a  20-year  period.  Because  of  that, 
microplastics were considered but were not taken further as candidate PS because there is too 
little  data  to  perform  an  actual  risk  assessment.  Consequently,  gaps  in  relation  to  the 
measurement, monitoring and data collection of the actual concentrations of microplastics in 
surface  and  groundwaters  need  to  be  addressed  first,  to  allow  setting  an  actual  EQS  in  a 
second stage. 

The  prioritisation  process  for  groundwater  serves  as  a  basis  for  the  determination  of 
substances to be selected either for the voluntary Groundwater Watch List (GW WL), or for 
the  List  Facilitating  the  Review  (LFR)  of  Annexes  I  and  II  of  the  GWD.  The  GW  WL 
provides a list of substances that MS should consider adding to their monitoring programmes 
on  the  basis  that  these  pollutants  may  present  an  obstacle  to  the  achievement  of  the 

33 

 
 
environmental  objectives  of  the  WFD.  This  is  key  to  obtaining  data  for  new  or  emerging 
pollutants,  feeding  into  the  development  of  the  GWD.  Under  the  umbrella  of  the  Working 
Group Groundwater (WG GW), the sub-group on the voluntary GW WL has contributed to 
assessing data provided by the participating countries and the subsequent compilation of the 
LFR  for  this  initiative.  Pollutants  on  the  LFR  go  through  the  quality  standard  derivation 
process  as  described  below  and  are  then  included  in  the  impact  assessment.  The  process 
resulted  in  a  group  of  10  PFAS,  2  individual  pharmaceuticals  and  a  group  of  16  nrM 
substances being selected (22). 

It should be stressed that the prioritisation of substances for listing is based on the conclusion 
that they pose a risk at EU level, i.e. in all or most MS. The monitoring required as a result of 
the substances proposed for listing will inform future revisions of the lists. In this context, it 
should  also  be  noted  that  the  initiative  considers  various  improvements  to  the  monitoring 
regime (see Section 5.2.3), thereby improving future data availability. 

5.1.2  5.1.2  Setting the limit values 

The derivation of quality  standards for selected  substances (or ‘quality standards derivation 
process’) follows scientific methods and is subject to several rounds of scrutiny, as illustrated 
in  Figure  5.1.1.  The  technical  process  of  threshold  derivation  for  surface  and  groundwater 
pollutants  is  carried  out  by  the  JRC  in  collaboration  with  subgroups  of  experts  and 
rapporteurs.  The  approach  used  to  set  the  limit  values  for  candidate  PS  is  based  on  a 
Technical  Guidance  Document  on  Deriving  EQS  (53)  developed  in  2018.  It  starts  with 
collecting (eco)toxicity  data from  EU official reports, stakeholder inputs and peer-reviewed 
studies. Then the scientific papers are evaluated for reliability and a selection of critical data 
for  EQS  derivation  is  made.  For  substances  on  the  LFR  of  the  GWD,  the  QSs  are  drafted 
considering  specificity  of  groundwater  ecosystems,  any  national  threshold  values  (TVs)  set 
by MS, links with the Drinking Water Directive and EQS set for surface water. 

34 

 
 
 
 
Figure  5.1.1:  Process  of  setting  limit  values  for  surface  water  and  groundwater 
pollutants 

The support studies and draft quality standards are subject to quality control and validation by 
the  experts  of  Common  Implementation  Strategy  (CIS)  working  groups  (WG).  Comments 
received  are  addressed  by  the  JRC  and  the  derived  QSs  are  submitted  for  an  independent 
review  by  the  Scientific  Committee  on  Health,  Environmental  and  Emerging  Risks 
(SCHEER). The SCHEER considers whether the EQS have been correctly and appropriately 
derived,  in  the  light  of  the  available  information  and  the  TGD-EQS;  and  whether  the  most 
critical EQS (in terms of impact on environment/health) has been correctly identified. Values 
endorsed by the SCHEER are used in the impact assessment and the legislative proposal. The 
impact assessment incorporates the preliminary or final opinions on each of the substances / 
groups of substances, available at this point in time (September 2022). QS for substances for 
which no preliminary or final opinions are available, are based on the dossier prepared by the 
Commission  for  SCHEER.  The  QS  for  these  substances  are  denoted  by  square  brackets 
throughout the Impact Assessment and the Proposal. As opinions arrive, square brackets will 
be removed. 

What is the baseline from which options are assessed? 

The baseline describes a situation where no further changes would be introduced in policies 
directly  affecting  EU  water  quality  (i.e.  the  WFD,  EQSD  and  GWD).  In  designing  the 
baseline, it is assumed that the identified problems would remain, although their scale would 
be impacted by external trends influenced by existing and upcoming policy interventions (e.g. 
possible  chemical  substitution  of  a  banned  substance)  and  other  non-policy  drivers  (e.g. 
demographic  developments).  The  dynamic  baseline  therefore  reflects  the  likely  changes  to 
emissions and, by proxy, environmental concentrations in a “business-as-usual” scenario.  

To  understand  how  the  policy  landscape  will  change  the  baseline  situation,  each  candidate 
substance  was  assessed  against  each  relevant  EU  and  international  policy  instrument, 
indicating  the  expected  range  of  impact  on  emissions.  The  outcome  of  this  exercise  is 
provided in Table 5.1.1.  

initiative 

the  upcoming  REACH 

For  many  of  the  substances,  efforts  are  already  being  made  under  other  legislation  which 
might have a beneficial impact for the aquatic environment. This includes initiatives like the 
review of the industrial emissions directive (IED) and the UWWTD, as well as upcoming EU 
initiatives on micro-plastics and PFAS. The most significant of these is for PFAS, which have 
been a core focus within the EU Green Deal and are reflected across a basket of legislation 
(most  notably 
to  ban  non-essential  uses).  The 
Pharmaceutical Strategy should address issues with many pharmaceuticals, however, for non-
prescription  medicines  like  ibuprofen  data  gaps  are  larger  and  controls  look  weaker, 
suggesting emissions will continue to grow in line with affluence, availability, and an ageing 
population. The continuous implementation of the existing Programmes of Measures (PoMs) 
under the WFD as well as the target under Farm to Fork Strategy to limit use of hazardous 
pesticides  will  likely  reduce  pesticide  releases  to  the  environment.  These  could  have 
synergistic  benefits  for  the  candidate  PS  that  are  pesticides  and  their  non-relevant 
metabolites. Only five parent pesticides of the 16 nrMs listed in the LFR are still authorised: 
glyphosate,  metazachlor,  flufenacet,  dimethachlor,  and  fluopicolide.  The  bans  already  in 
place for the other parent pesticides of the remaining nrMs are expected to entail, over time, 

35 

 
 
significant reductions in the concentrations of nrMs in groundwater. A detailed overview of 
the  dynamic  baseline  and  the  expected  contribution  of  EU  initiatives  for  pollutants  is 
included in Tables A4.1 and A4.2 in Annex 4. 

For  four  candidate  PSs  as  well  as  five  substances  considered  for  EQS  amendment,  no 
significant decrease or increase in emissions (+/- ≤10%) was found, even in the presence of 
other key policies aiming to drive down emissions. The ‘no change’ outcome is the product 
of  complex  issues,  such  as  multiple  pathways  to  the  environment,  other  drivers,  or  legacy 
issues which are likely to prevent real change in emissions to water before 2030 and therefore 
necessitating additional measures by MS if their water bodies fail to meet the standards set. 
For  all  five  existing  PS  that  have  been  proposed  for  deselection,  the  baseline  is  also 
considered to be no change in the current situation. This is because three of these chemicals 
are banned for many years, and emissions of the other two appear to be stable for years. 

Table 5.1.1: Outcomes of the dynamic baseline assessment 

Policy option 

Significant reduction  
(30% - ≤50%) 

Some reduction  
(10% - ≤30%) 

No change  
(≤10%) 

Substances 
considered for 
addition to PS 
list / GWD 
Annexes 

Pharmaceuticals: 
Macrolide antibiotics 
(azithromycin, 
clarithromycin, 
erythromycin) 

Industrial chemicals: 
PFAS 

Substances 
considered for 
amendment of 
existing EQS 

Metals: Mercury 

Substances 
considered for 
deselection from 
PS list 

Pharmaceuticals: Diclofenac, 
Carbamazepine, estrogenic hormones 
(E1, E2, EE2) 

Pesticides: Neonicotinoids 
(Acetamiprid, Clothianidin, 
Imidacloprid, Thiacloprid, 
Thiamethoxam), Pyrethroids 
(Bifenthrin, Deltamethrin, 
Esfenvalerate, Permethrin), 
Nicosulfuron, nrMs 

Industrial chemicals: Microplastics 

Metals: Silver 

Pesticides: Chlorpyrifos, Cypermethrin, 
Diuron, Tributyltin 

Industrial chemicals: PAHs, 
Nonylphenol, PBDEs 

Metals: Nickel 

Pharmaceuticals: Ibuprofen 

Pesticides: Triclosan, 
Glyphosate 

Industrial chemicals: 
Bisphenol A 

Pesticides: Dicofol, 
Heptachlor / Heptachlor 
oxide, Hexachlorobenzene 

Industrial chemicals: 
Dioxins, Fluoranthene, 
Hexachlorobutadiene, 
HBCDD 

Pesticides: Alachlor, 
Chlorfenvinphos, Simazine 

Industrial chemicals: 
Carbon tetrachloride and 
Trichlorobenzenes  

Note: Baseline assessment does not account for the revisions of the UWWTD and SSD as 
these were premature at the time of analysis. 

The dynamic baseline reflects emission rates to water and does not consider the persistence or 
residence time in different environmental compartments, which would have a further impact 
on ambient concentrations. Furthermore, physical properties and environmental fate will vary 
substance  by  substance,  adding  uncertainty  to  this  analysis.  However,  consideration  of 
emission control under existing or upcoming policy interventions helps  understand whether 
we  could  expect  the  ambient  concentrations  in  water  to  go  up,  down,  or  remain  broadly 
similar to current levels. 

36 

 
 
 
 
5.2  5.2 

Description of the policy options 

5.2.1  5.2.1  Surface water policy options 

Based on the problem definition for surface water and to address specific objective 1 of this 
initiative, a total of four policy options were identified (listed in Table 5.2.1 below) that add 
substances  to  the  existing  PS  list,  change  environmental  quality  standards  or  deselect 
(remove)  currently  listed  substances.  Policy  options  1  and  2  focus  on  the  listing  of  new 
candidate substances, i.e. if and how (e.g. individually or as groups39) they should be listed, 
therefore  constituting an “either-or” selection as  they  represent different  approaches  for the 
same candidate substances. Policy options 3 and 4, on the other hand, are independent of all 
other options and the choice there is only whether, for each of the substances involved, the 
respective  option  should  be  implemented.  The  recommended  EQSs  for  each  substance  or 
group of substances under Options 1, 2 and 3 are listed in Annex 8. 

When  looking  at  possible  policy  measures  to  address  substances  that  are  included  in  the 
substance  lists  under  the  Directive,  it  is  important  to  differentiate  between  PS  and  priority 
hazardous substances (PHS) since the regime of possible measures is different. Measures for 
PS  are  mainly  aimed  at  reducing  emissions  in  view  of  complying  with  the  EQS  values, 
whereas  measures  for  PHS  are  aimed  at  phasing  out  emissions  entirely.  From  all  the 
candidate  substances  under  consideration,  only  PFAS  and  Bisphenol  A  (BPA)  meet  the 
criteria for PHS status. 

Table 5.2.1: Surface water policy options 

Policy 
option 

Description 

List of substances 

Policy 
option 1:  

Additions.  Include  each  candidate  priority 
set 
individually 
substance 
corresponding individual EQS.  

and 

Policy 
option 2:  

Include 

candidate  priority 
Additions. 
substances as groups of substances where 
appropriate. Set corresponding EQS using 
markers  or 
substance 
the 
concentrations in the case of groups. 

sum  of 

Policy 
option 3:  

Amendments. Revise EQS where necessary 
based  on  new  scientific  data  for  existing 
priority substances.  

Policy 
Option 4: 

Deselection.  Remove  substances  from  the 
list following agreed deselection criteria. 

Pharmaceuticals: 17-alpha-ethinyl-estradiol (EE2), 17–beta-
estradiol  (E2),  estrone  (E1),  Azithromycin,  Erythromycin, 
Clarithromycin, Diclofenac, Carbamazepine, Ibuprofen 
Pesticides:  Nicosulfuron,  Acetamiprid,  Clothianidin, 
Imidacloprid,  Thiacloprid,  Thiamethoxam,  Bifenthrin, 
Esfenvalerate,  Deltamethrin,  Permethrin,  Glyphosate, 
Triclosan 
Industrial chemicals: 24 PFAS, Bisphenol A (BPA) 
Metals: Silver and its compounds 
Other: microplastics  

Note:  only  PFAS and  BPA  meet  the  criteria  for designation 
as PHS. 

Dioxins, 

chemicals: 

Pesticides:  Chlorpyrifos,  Cypermethrin,  Diuron,  Dicofol, 
Hexachlorobenzene, Heptachlor/Heptachlor epoxide 
Industrial 
Fluoranthene, 
Hexabromocyclododecane,  Hexachlorobutadiene,  Nonyl 
following  5  PAHs: 
phenol,  PAHs 
other 
Benzo(a)pyrene 
compounds); 
Benzo(b)fluoranthene; 
Benzo(k)fluoranthene; 
Benzo(g,h,i)perylene; 
Indeno(1,2,3-CD)pyrene),  PBDEs, 
Tributyltin 
Metals: Mercury, Nickel 

(consisting  of 
for 
(marker 

Pesticides: Alachlor, Chlorfenvinphos, Simazine  
Industrial 

chemicals: 

Carbon 

tetrachloride 

and 

39 This covered the possible grouping of the three estrogenic substances, three macrolide antibiotics, five neonicotinoid pesticides, four 
pyrethroid pesticides and 24 PFAS substances. Also including pesticides as a group in surface waters is considered as part of option 2, with 
a group standard of 0.5 μg/l, i.e. corresponding to that in the GWD and the DWD. 

37 

 
 
 
                                                           
Policy 
option 

Description 

List of substances 

Trichlorobenzenes 

It should be noted that the legislation currently provides MS with a period of time to comply 
with the newly listed substances and the modified TVs, going beyond the 2027 deadline for 
achieving good chemical status set in the WFD. For revised surface water EQS this additional 
time  was  set40  at  6  years  (2021,  plus  12  more  years  in  case  of  technical  infeasibility  or 
disproportionate cost). For new surface water substances, it is 12 years (2027, plus 12 more 
years in case of technical infeasibility or disproportionate cost). 

Box 9: Views on surface water options expressed during consultation activities 

Option  1:  Overall  agreement  for  including  all  candidate  substances  on  the  Priority  Substance  list,  with  ≥55%  of  TEC 
respondents supporting listing PFAS, BPA, Diclofenac, Carbamazepine and Ibuprofen. 
Option  2:  Clear  preference  for  PFAS  and  slight  preference  for  macrolide  antibiotics  to  be  added  as  groups  rather  than 
individually. 
Option  3:  More  stringent  EQS  values  were  supported  for  Chlorpyrifos,  Diuron  (AA/MAC)  and PAHs  (biota);  whereas 
current  AA/MAC  EQS  for  Nickel  and  biota  EQS  for  Mercury,  Hexachlorobenzene  and  Hexachlorobutadiene  were 
considered correct. Views that EQS should be less stringent for Heptachlor/heptachlor epoxide (MAC) and PBDEs (biota) 
were expressed. 
Option 4: ≥50% of TEC respondents saw no EU-wide risk for Alachlor, Chlorfenvinphos and Simazine. 

5.2.2  5.2.2  Groundwater policy options 

Three policy options have been developed to address the pollution of groundwater by PFAS, 
pharmaceuticals  and  nrMs.  The  major  policy  choice  is  whether  to  add  these  emerging 
contaminants  to  Annex  I  (as  individual  substances  or  groups)  or  Annex  II  of  the  GWD. 
Additions  to  Annex  I  must  be  accompanied  by  an  EU-wide  groundwater  quality  standard 
(currently  covered  are  nitrates,  pesticides  and  their  relevant  metabolites),  whilst  substances 
added to Annex II must be considered by MS during the risk assessment phase of river basin 
management planning, and appropriate TVs set at national level. 

The options, listed in Table 5.2.2, represent an “either-or” choice for each of the substances 
(or groups of substances), which are assessed independently of each other under each option. 
The  SCHEER  endorsed  quality  standards  are  based  on  available  (eco)toxicological  data, 
harmonised with surface water quality standards in several cases, and, where necessary, the 
precautionary principle. All of the options address specific objective 1 of this initiative.  

Table 5.2.2: Groundwater policy options 

Policy 
option 

Description 

List of substances 

Policy 
Option 1 

Add LFR substances to GWD Annex I 
individually  or  as  a  group  of  specific 
chemicals,  and  assign  an  individual  or 
a 
“sum  of”  EU-wide  GW  QS 
respectively. 

Industrial chemicals: PFAS (Group of 24 as for surface water)  
Pharmaceuticals: Carbamazepine and Sulfamethoxazole 
Pesticides: All nrMs 

Policy 
Option 2 

Add LFR substances to GWD Annex I 
as  groups  of  all,  and  assign  an  EU-

Industrial chemicals: All PFAS  
All Pharmaceuticals 

40 At the most recent revision, in 2013; for groundwater the current initiative is the first revision. 

38 

 
 
 
 
                                                           
Policy 
option 

Description 

List of substances 

wide GW QS for the group “total”. 

Pesticides: All nrMs  

Policy 
Option 3 

Add  LFR  substances  to  GWD  Annex 
II  for  MS  to  consider  setting  a TV  for 
specific  substances  posing  a  risk  to 
groundwater bodies (GWBs). 

Industrial chemicals: All PFAS  
All Pharmaceuticals, Carbemazepine and Sulfamethoxazole are 
included in the minimum list of pollutants (part B). Additionally, 
as  a  guideline,  a  reference  to  the  GWWL  is  added,  which 
includes nine pharmaceuticals  
Pesticides: All nrMs 

Box 10: Views on groundwater options expressed during consultation activities 

PFAS addition to Annex I was most strongly supported in the targeted expert survey. Listing a limited number of named 
PFAS was favoured by 49% of respondents, whereas 19% preferred including all PFAS with a group ‘total’ standard. 
The general consensus for pharmaceuticals was to include them in Annex I (individually - 33% of TEC respondents; all as 
a group – 18%). Annex II listing was favoured by 27% of respondents. 
Most  TEC  participants  endorsed  inclusion of  nrMs  in  Annex  I  (46%  favoured  listing  a  limited  number  of  named  nrMs 
with  individual  QSs,  whereas  13%  preferred  including  all  nrMs  with  a  group  ‘total’  standard).  Annex  II  listing  was 
supported  by  23%  of  respondents.  Contrasting  views  on  the  quality  standards  were  expressed  during  all  consultation 
activities, with industry stakeholders preferring less stringent QS, and MS and drinking water sector representatives noting 
the widespread presence of nrMs in groundwater and urging stricter regulation at EU level.  

5.2.3  5.2.3  Monitoring, reporting and administrative streamlining options 

To  address  specific  objectives  2  to  5  of  this  initiative,  15  discrete  actions  were  identified. 
These were categorised into four groups of policy options based on their subject matter (e.g. 
monitoring, reporting) and nature (e.g. voluntary, legislative). Table 5.2.3 lists the four policy 
options  and  the  respective  specific  sub-options  considered  under  each.  The  four  thematic 
policy  options  are  not  mutually  exclusive  and  all  the  (sub)options  can  be  implemented  in 
combination  with  each  other  within  and  across  these  groupings.  All  these  (sub)options  are 
complement the surface and groundwater-specific options described above. 

Providing / improving guidance and advice on monitoring, including Effect Based Methods 
(EBMs), modern instruments,  digital  techniques etc., is  necessary to address  the significant 
pressures  stemming  from  emerging  pollutants  (such  as  microplastics)  and  possible 
cumulative  effects  of  pollutant  mixtures.  Regarding  microplastics,  no  commonly  agreed 
standard for measuring their presence in EU freshwaters exists. Such a standard is, however, 
a prerequisite for monitoring and taking targeted policy action like setting an EQS/GW QS. 
In  addition,  there  are  a  range  of  innovative  monitoring  techniques,  including  automated 
sensing technologies, which could provide important insights into pollutant levels, but which 
are  yet to be commonly adopted.  Improved sharing of knowledge and best-practices among 
MS may help facilitate wider implementation of such innovative methods. 

Establishing  /  amending  existing  obligatory  monitoring  practices  is  needed  to  gather  more 
specific  evidence  on  the  evolution  of  pollution.  Mandatory  monitoring  would  help  fill  the 
existing data gaps (e.g. on the combined effects of estrogenic substances, emerging pollutants 
in  groundwater,  seasonal  variations  of  emissions  in  surface  waters)  and  inform  future  risk 
assessments. 

Actions to harmonise / simplify reporting and classification would improve transparency and 
access  to  data  as  well  as  reduce  the  administrative  burden  of  MS  in  the  medium  and  long 
term.  

39 

 
 
 
 
Box 11: Which kind of information are stakeholders interested in? 

During the OPC, the majority of respondents indicated a need for access to more information for all of the items listed in 
the questionnaire (i.e. average rating ≥3.5 on a scale from 1 – not at all – to 5 – very much). Stakeholders expressed the 
most interest (average score of 4.2) in information on the presence and concentration of individual/groups of pollutants 
(rated  ≥4  by  80%  of  respondents)  as  well  as  sources,  nature  and  associated  risks  of  pollutants  (rated  ≥4  by  79%  of 
respondents). 

The  legislative  and  administrative  changes  are  needed  to  enable  more  effectiveness, 
efficiency, coherence, responsiveness and flexibility in the legislation. 

40 

 
 
 
Table 5.2.3: Policy options related to monitoring, reporting and administrative streamlining 

Objective 
addressed 

Specific 
objective 2 

Policy 
Option 

Description 

List of sub-options 

Policy 
Option 
1 

/ 

Provide 
improve 
guidance  and 
advice 
on 
monitoring 

Policy 
Option 
2 

Establish 
amend 
obligatory 
monitoring 
practices 

Policy 
Option 
3 

/ 

Harmonise 
simplify 
reporting  and 
classification 

a)  Develop  guidelines  on  applying  innovative  methods  in  monitoring  procedures, 

including continuous/automated monitoring techniques. 

b)  Follow-up to improve existing guidelines on EBMS in view of setting application 
‘trigger values’ in practice to improve monitoring of groups/mixtures of pollutants 
by using EBMs, and trigger values. 

c)  Develop  a  harmonised  measurement  and  monitoring  methodology  and  guidance 
for  microplastics,  as  a  basis  for  mandatory  MS  reporting  on  microplastics  and  a 
future listing under EQSD/GWD. 

Specific 
objectives 
2, 3 

d)  Develop guidelines on sampling frequency for PS and RBSPs. 

e)  Provide  a  repository  for  sharing  best  practices  from  MS  regarding  available 

monitoring techniques, and foster cooperation to implement these. 

Specific 
objective 2 

a) 

Include an obligation in the EQSD to use EBMs to monitor estrogens. 

b)  Establish an obligatory GW WL mechanism analogous to that for surface waters41 
and  drinking  water,  and  provide  guidance  as  necessary  on  the  monitoring  of  the 
listed substances. 

Specific 
objectives 
2, 3 

/ 

c) 

Improve the monitoring and review cycle of the SW WL so that there is more time 
to process the data before revising the list. 

Suggested  improvements  consist  of  a)  increasing  the  monitoring  frequency  for 
pollutants  with  seasonal  emission  patterns  (e.g.  pesticides);  b)  extending  the 
obligatory  monitoring  period  from  12  to  24  months;  and  c)  increasing  the  review 
frequency from 24 to 36 months (by modifying WFD Article 8b). 

Specific 
objective 2 

a)  Establish  an  automated  data  delivery  mechanism  for  the  EQSD  and  the  WFD  to 
ensure  easy  access  at  short  intervals  to  monitoring/status  data  to  streamline  and 
reduce  efforts  associated  with  current  reporting,  and  to  allow  access  to  raw 
monitoring data. 

Specific 
objective 5 

b) 

Introduce a reference list (repository of standards) of EQS for RBSPs as an annex 
to the EQSD and modify Annex V of WFD section 1.2.6 (Procedure for the setting 
of chemical quality standards by MS) accordingly, and incorporate RBSPs into the 
assessment of chemical status for surface waters 

Specific 
objectives 
3, 5 

a)  Use an annex in the EQSD instead of Annex X to the WFD to define the list of PS, 
and update the lists of SW and GW substances by Comitology or delegated acts. 

Specific 
objective 4 

Policy 
Option 
4 

Legislative 
and 
administrative 
aspects 

b)  Change  the  status  of  the  ‘eight  other  pollutants’  added  to  the  EQSD  from  the 

former Dangerous Substances Directive (76/464/EEC) to that of PS/PHS. 

Pesticides: Aldrin, Dieldrin, Endrin, Isodrin, DDT (all to PHS); Industrial chemicals: 
Tetrachloroethylene, Trichloroethylene (to PHS), Carbon tetrachloride 

c)  Change the status of some existing PS to that of PHS where it fulfils the criteria of 

the POP Regulation and/or Article 57 of REACH Regulation. 

Industrial 
Pentachlorophenol; Metals: Lead 

chemicals: 

1,2-Dichloroethane, 

Fluoranthene, 

Octylphenol, 

Specific 
objective 3 

Specific 
objective 1 

41 The maximum number of substances that can be included for monitoring might differ for the surface and the groundwater watch lists. 

41 

 
 
                                                           
5.3  5.3 

Options discarded at an early stage 

For  the  identification  of  possible  policy  measures,  a  two-step  approach  was  used.  In  a  first 
step, a wide range of possible measures were identified. For each problem, different solutions 
were envisaged, ranging from soft approaches - mainly based on non-binding guidance to MS 
-  up  to  stricter  regulatory  measures.  In  a  second  step,  based  on  a  'feasibility’  screening,  a 
selected number of possible policy measures were retained for further analysis.  

The  option  of  not  updating  other  aspects  of  this  legislation  that  are  not  directly  linked  to 
chemical  pollution  was  discarded  early  on,  given  the  outcomes  of  the  FC  and  the  political 
commitment not to seek a change in the WFD in the short run. Also rejected was the option 
in relation to targeted substances to directly ban certain pharmaceuticals, pesticides or other 
chemicals.  In all these  cases the EU has  a  well-functioning system  of risk-screening before 
market  authorisation  for  their  intended  use.  Therefore,  while  possibly  effective  from  an 
environmental  standpoint,  these  options  would  be  inconsistent  with  the  established  policy 
approaches.  As  regards  substitutes  for  potential  new  substances,  the  impact  assessment  did 
not  consider  substitutes  that  are  over  3.5  times  more  costly  than  the  original  substance,  as 
beyond this price difference they are no longer regarded as a realistic substitute (substitutes 
considered are detailed in Annex 10). 

6 

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS AND WHO WILL BE AFFECTED?  

This  section  describes  the  impact  assessment  methodology,  discusses  the  impacts  of  policy 
options  and  stakeholders  particularly  affected  by  them.  The  assessment  of  the  addition  or 
removal of substances or groups of substances selected through the methodology described in 
Chapter  5.1  has  been  based  on  the  distance  to  target,  including  application  of  the  dynamic 
baseline,  and  an  assessment  of  additional  measures  that  might  be  needed  to  achieve  the 
recommended quality standards (listed in Annex 8).  

Note that EU water legislation does not specify exact measures to be taken to reach a given 
water  quality  standard.  Therefore,  the  assessment  of  possible  costs  and  benefits  of  policy 
options is based on the potential measures that MS might take because of this initiative, 
additionally  to  the  existing  measures  and  any  requirements  imposed  by  other  EU 
legislation.  

It is not possible, in this impact assessment, to identify the isolated cost and benefit of listing 
substances since this will depend on measures chosen by MS and on distance to target in the 
concerned  water  bodies.  Moreover,  water  legislation  works  in  sync  with  other  legislation 
(waste  water  treatment,  source  control,  international  requirements,  etc).  Figures  in  this 
section and in section 8 are therefore often related to estimated costs / benefits from groups of 
substances with similar characteristics or effect (eg cost of removing all PFAS, or all health 
effects of hormone disturbing chemicals) but are not to be understood as costs and benefits 
solely associated with this initiative.  

A more detailed overview of impacts, for each of the surface water and groundwater options, 
can be found in Annex 9.  

EN 

  EN 

 
 
Box 12: Implications of listing a substance under the water legislation 

For surface water, MS might need to: 

  Monitor concentrations to obtain representative information of the water body and its chemical status. 
 
 

In case of EQS exceedances MS must act (source control measures take priority over others). 
If  a  substance  is  persistent,  mobile  and  toxic  (PMT)  and/or  very  persistent,  very  mobile  (vPvM)  and  thus  also  bio-
accumulates, then it is classified as priority hazardous substance (PHS). 
For priority substances (PS) MS must implement measures to progressively reduce pollution, for PHS MS must implement 
measures to cease or phase out emissions completely. 
Include  new  substances  in  the  national  inventory  of  emissions,  containing  a  timetable  for  cessation  or  phase-out,  and 
reduction. 

 

 

For groundwater, MS might need to: 

 

Implement measures necessary to lower concentrations of any pollutant in groundwater and therefore  progressively reduce 
pollution. 

  Take  all  measures  necessary  to  prevent  inputs  into  groundwater  of  any  hazardous  substances  covered  by  the  groundwater 

quality standards in Annexes I and II of the GWD. 

6.1  6.1 

Impact assessment methodology 

6.1.1  6.1.1  Distance to target 

An  important  factor  to  understand  the  impacts  of  adding  new  substances  to  the  lists  of 
pollutants or amending existing EQS values is the ‘distance to target’. This refers to the size 
of the gap between the baseline situation and the target considered within the policy option. 
The  indicative  assessment  of  the  potential  exceedances  above  the  envisaged  limit  values 
helps evaluate the likely extent of measures required to address the issue. 

The  ‘distance  to  target’  assessment  followed  a  two-step  process.  First,  the  substances 
considered under each option were assigned to groups (large / medium / small) based on the 
predicted geographic scale (i.e. how many water bodies might fail chemical status; how many 
MS  might  need  to  take  measures)  and  the  magnitude  (i.e.  how  far  above  the  thresholds  do 
concentrations rise) of the current  gap. The general  criteria for these groupings is shown in 
Table 6.1.1 with further caveats (e.g. specificities for SW and GW assessment) explained in 
Annex 4.  

Table  6.1.1:  General  scale  and  magnitude  criteria  for  the  distance  to  target 
assessment 

Distance 
target group 

to 

Scale criteria (based on monitoring data) 

Small 

Predicted exceedances in ≤33% of MS  

Medium 

Predicted exceedances in >33 and ≤66% of MS 

Large 

Predicted exceedances in >66% of MS 

Magnitude 
on 
criteria 
compared to new quality standards) 

(based 

exceedances 

Mean monitored concentrations ≥0 and ≤33% over the 
new QS 

Mean  monitored  concentrations  >33  and  ≤66%  over 
the new QS 

Mean  monitored  concentrations  >66%  over  the  new 
QS 

There  is  currently  not  enough  detailed  information  to  allow  the  distance  to  target  to  be 
determined  for  each  Member  State  vis-à-vis  each  substance  or  group  of  substances  under 
consideration.  Indeed,  the  monitoring  data  underpinning  such  measurement  (typically 
gathered from the SW WL, the GW WL  and the WFD reporting) are in a number of cases 
incomplete. In such cases, extrapolation considering authorisation, use and emission data, and 

EN 

  EN 

 
 
 
expert  judgement  are  used  to  obtain  an  indication  of  the  existing  scale  and  magnitude  of 
pollution (see Annex 4 for details). 

Secondly, the dynamic baseline assessment (described in Chapter 0) was taken into account 
to reflect the expected change in emissions due to other (policy) drivers. The final distance to 
target,  therefore,  reflects  the  additional  EU-wide  effort  that  may  be  required  to  tackle 
the pollution caused by the candidate substances. Where there are no EU-wide measures 
introduced by other policy initiatives, MS will have to take action nationally, and the (large / 
medium / small) distance to target indicates the average relative effort required to tackle the 
relevant  substances.  Results  of  the  distance  to  target  assessment  are  presented  in  dedicated 
surface and groundwater sections below.  

6.1.1.1  Surface water 

The distance to target for surface water Option 1 (addition to PS list individually) and Option 
2 (addition to PS list as groups) has been determined using a combination of monitoring data 
gathered  from  the  SW  WL  and  the  assessment  conducted  within  the  EQS  dossiers.  The 
baseline  situation  is  represented  by  the  current  concentrations  measured  in  surface  water, 
whereas  the  target  is  the  value  considered  protective  of  human  health  and  the  aquatic 
ecosystem (i.e. the scientifically recommended EQS; see Annex 8). 

An overall relatively large distance to target was estimated for 3 pharmaceuticals (17 alpha-
ethinylestradiol  (EE2),  Diclofenac,  Carbamazepine),  Silver,  5  pesticides  (Bifenthrin, 
Deltamethrin,  Esfenvalerate,  Permethrin,  Glyphosate)  and  2  industrial  chemicals  (PFAS, 
Bisphenol A). 

An overall medium distance to target was estimated for 4 pharmaceuticals (17 beta-estradiol 
(E2), Estrone (E1), Azithromycin, Ibuprofen), 2 pesticides (Imidacloprid and Triclosan) and 
1 metal (silver and its compounds). 

An  overall  small  distance  to  target  was  estimated  for  2  pharmaceuticals  (Clarithromycin, 
Erythromycin), and 5 pesticides (Acetamiprid, Clothianidin, Thiacloprid, Thiamethoxam and 
Nicosulfuron). 

A  slightly  amended  approach  was  used  to  assess  the  distance  to  target  for  surface  water 
Option  3  (EQS  amendment),  because  the  impact  assessment  looked  at  possible  additional 
efforts required to tackle these substances once their EQS is amended. The baseline situation 
is,  therefore,  represented  by  the  current  gap  between  concentrations  measured  in  surface 
water and existing EQS, whereas the target is the new scientifically recommended EQS. 

The  scale  and  magnitude  of  the  current  gap  has  been  determined  using  a  combination  of 
monitoring data gathered from the WFD reporting and the assessment conducted within the 
EQS  dossiers.  Then,  based  on  the  new  recommended  EQS  (where  available,  see  Annex  8) 
and guidance from the JRC, an assessment has been made as to whether the size of the gap 
would  increase,  decrease,  or  stay  the  same  following  EQS  amendment.  Afterwards,  as  for 
other  policy  options,  the  impacts  of  the  dynamic  baseline  (see  Chapter  0)  were  taken  into 
account to re-group substances. 

An overall relatively  large distance to  target  was estimated for 1 industrial chemical  group 
(PBDEs) and 2 metals (Mercury, Nickel). 

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An  overall  medium  distance  to  target  was  estimated  for  4  pesticides  (Chlorpyrifos, 
Cypermethrin,  Diuron,  Tributyltin)  and  2  industrial  chemical  groups  (Dioxins  and  furans, 
PAHs). 

An  overall  small  distance  to  target  was  estimated  for  3  pesticides  (Dicofol,  Heptachlor  / 
Heptachlor  epoxide,  Hexachlorobenzene)  and  3 
industrial  chemicals  (Fluoranthene, 
Hexachlorobutadiene, Nonylphenol). 

6.1.1.2  Groundwater 

Unlike the surface water situation, an EU-wide monitoring network of emerging groundwater 
pollutants  does  not  exist.  Therefore,  the  likely  current  day  status  of  groundwater  bodies 
(GWBs) with respect to the LFR pollutants is needed to understand how much effort might 
be  required  to  reach  the  targets  proposed  by  the  various  policy  options.  This  baseline 
assessment was made by reviewing the most recent reported status of GWBs (i.e. 2nd River 
Basin Management Plans covering the 2015-2021 period) and the chemicals leading to failure 
with similar emission characteristics and environmental fate along pathways to groundwater. 
The scale was represented by % of MS likely to report failure, whereas the magnitude was 
defined as the level of exceedance above TVs already used by MS for the proxy substances. 

Then,  the  expected  distance  to  target  was  assessed  based  on  expert  judgement  and  the 
indication  of  the  likely  level  of  exceedance  over  the  potential  PFAS,  pharmaceuticals  and 
nrMs TVs. The level of exceedance is estimated by calculating the proportion of monitoring 
locations and MS reporting concentrations above the targets stipulated in the policy options. 
Afterwards,  the  impacts  of  the  dynamic  baseline  (see  Chapter  0)  and  the  lag-time  of 
groundwater  ecosystems  were  taken  into  account  to  adjust  the  grouping.  For  example, 
although  PFAS  emissions  are  expected  to  reduce  significantly  due  to  other  policy 
interventions,  this  will  be  reflected  in  groundwater  concentrations  much  later,  therefore 
having no impact on distance to target before 2030. 

An  overall  relatively  large  distance  to  target  was  estimated  for  PFAS  under  all  options  as 
well as nrMs under Option 1 (all individually in Annex I). 

An  overall  medium  distance  to  target  was  estimated  for  pharmaceuticals  under  Option  2 
(group of all in Annex I), and nrMs under Option 2 and Option 3 (addition in Annex II). 

An  overall  small  distance  to  target  was  estimated  for  pharmaceuticals  under  Option  1 
(carbamazepine  and  sulfamethoxazole  in  Annex  I)  and  Option  3  (group  in  Annex  II, 
considering Primidone). 

6.1.2  6.1.2  General considerations for all surface and groundwater options 

Impacts  of  the  policy  options  related  to  the  (de)listing  of  surface  water  and  groundwater 
substances are dependent on the specific measures taken to reduce the presence of pollutants. 
Measures come in four groups: source control (e.g. substitution, bans, emission prevention at 
production  stage),  pathway  disruption  (physical  barriers  preventing/reducing  pollution  to 
treatment  measures 
surface 

and  ground-waters), 

end-of-pipe42 

case 

this 

(in 

42 End-of-pipe treatment indicates the separate treatment of the generated pollutants  before entering the environment. This usually occurs 
either directly after the production process and/or after the use phase. 

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preventing/reducing  pollution  at  the  waste  water  stage)  and  finally  monitoring  and  risk 
attenuation at water bodies’ level. 

Key sectors likely to be impacted by groups of measures were identified. In many cases, the 
same measures are effective for addressing multiple substances in a complementary fashion. 
The importance of different measure categories varies depending on the substance. Table 6.1.2 
provides a quick reference for how the measure categories relate to the substance categories. 
Then,  an  overview  of  stakeholders  possibly  impacted  by  the  implementation  of  identified 
measures is presented in .  

Table 6.1.2: Overview of measure categories and substance categories 

Control Option 

Pharmaceuticals 

Pesticides 

Plant  Protection 
Products 

Biocides 

Industrial 
chemicals 

Metals 

Intervention at source 

Pathway disruption 

End-of-pipe 

Risk 
containment, 
monitoring,  and  natural 
attenuation 

 

* 

 

 

 

 

 

** 

 

 

 

 

*** 
 

 

*Relates  to  agricultural  runoff  from  farmed  animals  only  **Legacy  uPBT  pesticides  only 
***related to run-off from road only 

Table  6.1.3:  Overview  of  stakeholders  likely  impacted  by  measures  identified  (surface 
and groundwater) 

Pharmaceuticals 

Pesticides (incl. nrMs) 

Pharmaceutical and Personal Care Products 
manufacturers  and  distributors  (ranging 
from SMEs to multinationals) (EPR) 

Pesticide  manufacturers 
and distributors 

Healthcare sector 

Healthcare sector 

Farmers  and  veterinary  applications  – 
farmed animals and horses 

Society - costs to consumers/  

(ranging 

Farmers 
from 
SMEs  to  multinationals) 
and landowners 

Veterinary  applications  – 
biocides, 
particularly 
farmed 
and 
domestic pets 

animals 

Industrial  Chemicals 
(incl. PFAS) 

Metals 

Manufacturing  e.g.  of 
raw  chemicals,  clothing, 
textiles, 
cosmetics 
printing  

Manufacturing and use of 
chemicals,  disinfectants 
(multiple sectors)  

Infrastructure and roads 

Mining operations sector 

Manufacturing  industries 
–  particularly  smelting 
and  use  in  electronics  / 
automotive. 

Healthcare  sector  e.g. 
biocidal applications  

Society 
- 
consumers 

costs 

to 

Society 
- 
consumers 

costs 

to 

Wastewater  and  drinking  water  companies 
(mainly SMEs) 

Society 
- 
consumers  

costs 

to 

Wastewater  and  drinking 
water  companies  (mainly 
SMEs) 

Wastewater and drinking 
water companies (mainly 
SMEs) 

Member  State  Authorities  –  guidance  and 
enforcement 

Wastewater 
companies 
and 
(biocides) 
drinking water companies 

(EPR) 

Member 
State 
Authorities  –  guidance 
and permitting 

Member 
Authorities 
drainage 

State 
–  mine 
landfill 

and 

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Pharmaceuticals 

Pesticides (incl. nrMs) 

Industrial  Chemicals 
(incl. PFAS) 

Metals 

sites. 

Member State Authorities 
and 
guidance 
– 
enforcement 

Waste disposal (Landfill) 

6.2  6.2 

Surface water – impacts of policy options  

This  section  provides  a  summary  of  the  associated  environmental,  economic  and  social 
impacts  of  individual  policy  options.  The  evaluations  of  the  Industrial  Emissions  Directive 
(IED)  and  the  EU  Pollution  Release  and  Transfer  Register  (E-PRTR),  pieces  of  legislation 
with  which  the  WFD  interacts  strongly,  notably  on  water  management,  concluded  that 
industrial  installations,  covered  by  the  IED  /E-PRTR,  account  for  about  20%  of  pollutant 
emissions by mass to water this includes among others the main groups of pollutants covered 
by  this  evaluation  (pharmaceuticals,  industrial  substances,  and  metals).  For  pesticides  the 
picture is different since the main emitter of those substances is the agricultural sector who is 
the end-user of the products produced by industry. 

6.2.1  6.2.1  Policy option 1 – listing candidate PS individually 

Option 1 applies to all substance categories (industrial/pharmaceuticals/pesticides/metals). 

Industrial chemicals (PFAS and Bisphenol-A) 

Important  sources  of  PFAS  emissions  are  the  primary  manufacturers  of  manufacturers  of 
fluorochemicals  and/or  fluoropolymers,  as  well  as  cardboard  and  paper  mills  producing 
PFAS  coated  paper  for  a  myriad  of  applications.  The  number  of  PFAS  production  sites  in 
Europe is between 12 and 25 plants (25). Also, based on Eurostat data on the basis of NACE 
codes,  nine  additional  industrial  activities  where  PFAS  are  likely  used  (textiles,  leather, 
carpets,  paper,  paints  and  varnishes,  cleaning  products,  metal  treatments,  car  washes, 
plastic/resins/rubber)  were  identified.  Also,  regarding  environmental  discharges  from  paper 
mills, it is estimated that a “typical” paper mill that produces 825 tons of PFAS-coated paper 
per day and discharges 98.4 million liters of water per day which release more than 100,000 
ppt of PFAS in the wastewater effluent (55). Consequently, paper mill companies estimated a 
release of 43 to 102 kg of PFAS per day in their wastewater43. With 743 EU paper mills (56) 
this results in daily PFAS emissions between 31 to 76 tonnes. Companies also state that for 
10 kg of PFAS going from the manufacturing process into wastewater treatment, 9 kg end up 
in  biosolids and 1 kg is released into surface waters (57). That  means  the amount of PFAS 
ending up in  sludges across  the EU ranges  from  310 to  760 tonnes/day.  PFAS  can only be 
effectively removed from wastewater by reverse osmosis with operating costs of €0.4 /litre. A 
cost  model  calculating  the  capital  costs  for  building  PFAS  drinking  water  remediation 
resulted in baseline capital cost of $712,752 plus $2,070,142 per million gallons/day (MGD) 
which is simplified to $2 million per MGD which equals €520/m3/day. Measures at source 
would thus avoid costs at least €39.4 million EU-wide related to a complete removal of PFAS 

43 Information obtained by EDF through a Freedom of Information Act request to the US Food and Drug Administration for PFAS used to 
produce PFAS coated paper and board which is among others used for food contact applications. 

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from  paper  mills  effluents/sludges.  Note:  the  EU  has  comparatively  limited  information  on 
(industrial)  point  sources  of  PFAS  emissions  from  production  and  manufacturing  sites 
because  many  industrial  installations  do  not  have  to  monitor  PFAS  under  their  discharge 
permits. Consequently, US information (58) (59)  (60)  (61) was used.  

In 2018, a car wash facility in the US state of New Hampshire was cited as one of the sources 
of PFAS contamination in wells serving several nearby towns (62). Investigators tested wells 
on the car wash property and found levels for PFAS higher than expected – up to 158.8 ppt, 
compared  to  the  USEPA  lifetime  advisory  level  of  70  ppt.  The  facility  will  be  required  to 
take measures to prevent the contamination from continuing. According to the International 
Car Wash Association 79,000 car wash facilities are operating in Europe. These are likely to 
be  SMEs  employing  less  than  250  workers  (63).  It  is  not  known  how  many  of  these  use 
products containing PFAS. 

The industrial chemical Bisphenol-A (BPA), is produced in large quantities for use primarily 
in  the  production  of  polycarbonate  plastics.  It  is  found  in  various  products  including 
shatterproof  windows,  eyewear,  water  bottles,  and  epoxy  resins  that  coat  some  metal  food 
cans, bottle tops, and water supply pipes. For the environment, contaminated landfill leachate 
is an important source for both SW and GW. Consequently, an improved capture of landfill 
leachate  combined  with  wastewater  treatment  could  prevent  in  the  order  of  246MT  of 
leachate  being  emitted.  Annual  costs  associated  to  this  measure  are  estimated  to  amount 
around  €103.7  million,  with  an  assumed  25-year  asset  lifetime.  Avoided  economic  health 
related  costs  for  avoided  BPA  exposure  in  relation  to  childhood  obesity  are  estimated  to 
amount  to  around  €183144  million  (64).  Recent  findings  from  EHCA  (65)  also  support  a 
further restriction of BPA emissions. For human health, BPA in food and beverages accounts 
for  the  majority  of  daily  human  exposure.  BPA  can  leach  into  food  from  the  protective 
internal  epoxy  resin  coatings  of  canned  foods  and  from  consumer  products  such  as 
polycarbonate tableware, food storage containers, water bottles, and baby bottles. Lowering 
human  health  risks  comes  at  little  to  no  costs,  since  exposure  can  be  easily  limited  by 
behavioural  changes  such  as  not  microwaving  polycarbonate  plastic  food  containers, 
reducing the use of canned foods, and when possible, opt for glass, porcelain or stainless steel 
containers, particularly for hot food or liquids and finally choosing to use (baby) bottles that 
are BPA free. 

Pharmaceuticals 

Source control measures like restricting/reducing the use of candidate pharmaceuticals within 
the human population, e.g. by substituting the most harmful pharmaceuticals by less harmful 
alternatives (greening pharmacy), or by changing from over-the-counter to prescription-only 
systems,  will  be  important  to  limiting  their  emissions.  Additionally,  the  management  of 
unused, expired medicines /medicine containers to prevent the substance entering wastewater 
systems and/or landfills (see Box 13) could also be improved. Furthermore, new EU Ecolabel 
criteria  for  cosmetics  and  animal-care  products  (adopted  in  October  2021)  offer  proof  to 
consumers that they purchase products with MSverified environmental excellence, along the 

44 Based on an exchange rate of 1 EUR = 1.09 USD 

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entire  life  cycle45.  Price  impact  for  consumers  will  be  limited  since  alternatives  to  listed 
substances are available at little or no additional cost. 

The use of pathway disruption measures like buffer strips (costs €160 per hectare) or natural 
constructed wetlands (costs €43.7 per m3) are identified as potential cost-effective measures 
for reducing the entry of estrone (E1) and 17-beta estradiol (E2) into the environment. Under 
a  worst-case  scenario,  a  maximum  of  5%  of  all  pastoral  farmland  would  be  assumed  to 
require measures (buffer strip /constructed wetland / additional fencing. End of pipe measures 
directly  relate  to  the  revision  of  the  UWWTD.  The  costs  to  remove  micro-pollutants  from 
waste water under that legislation are shown in Table 6.2.1: Overview of measure categories 
and substance categories. 

Table 6.2.1: Overview of measure categories and substance categories 

Preferred  option  in  the  UWWTD 
revision SWD 

Costs 
(Million 
€/year) 

load 
Toxic 
avoided (p.e.) 

Avoided  Toxic 
load  
 in areas at risk 
(p.e.) 

Additional  GHG  (Million  t 
CO2e/year) 

All  plants  >100  k  p.e.  +  plants  10  k 
to 100 k in areas at ’risk’46 
As  regards  pharmaceuticals,  depending  on  policy  measures  at  national  level,  choice  of 
specific medication may be limited through different prescription policy. 

0 to 4.97 

1 185.51 

68 198 

41 836 

For  carbamazepine,  diclofenac  and  ibuprofen  a  range  of  (cheaper)  alternatives  exist. 
Technical  challenges  related  to  manufacturing  and  supply  chains  (increasing  supply  of 
alternatives), and issues related to the prescription of alternatives exist for some substances. 
Also,  for  specific  individual  patients  the  substitution  of  specific  medicines  might  not  be 
feasible and could thus limit the impact on emission reductions. For veterinary uses, pathway 
disruption could also help reduce diffuse emissions to surface water. 

End of pipe measures to remove pharmaceuticals from waste water are relatively costly and 
thus  not  preferred,  but  could  be  helpful  for  ibuprofen  and  carbamazepine.  Ozonation  could 
help  to  remove macrolide antibiotics. Diclofenac is  more costly to  remove. The revision of 
the UWWTD IA shows that the deployment of enhanced water treatment technology results 
in considerable additional resource and energy costs (resulting in a significant increase of the 
associated  carbon  footprint).  Also,  the  undesired  formation  of  bromide  as  unwanted 
breakdown product is relevant for some substances. Annex 10 contains overview tables with 
pharmaceutical substances, potential alternatives and the costs of each as well as tables with 
an overview of the most common end-of-pipe measures and their cost per substance. 

Increasing  interest  for  surface  and  groundwater  pollution  by  pharmaceuticals  is  fuelling 
interest  in  developing  new  pharmaceuticals  –  or  re-designing  existing  ones  –  to  be  more 
environmentally friendly, or ‘benign by design.’ This includes drugs that are better absorbed 
by  the  human  body,  or  that  biodegrade  more  rapidly  in  the  environment.  For  example,  by 
structurally modifying  propranolol  – a commonly  used and highly persistent beta blocker  – 

45  Currently,  three  out  of  four  PCP  sold  in  the  EU  display  some  kind  of  environmental  claim  or  label,  yet  many  of  these  claims  are 
untransparent about assessment criteria used, and/or difficult to understand or confusing for the consumer. 

46 In this IA, it was assumed that 70% of facilities between 10 000 and 100 000 p.e. with a dilution rate of 10 or less would be considered as 
‘at risk’- see UWWTD SWD Annex 4. 

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researchers have been able to synthesise a derivative that breaks down much more easily in 
the environment than its parent compound47. 

Green  Pharmacy  initiatives  are  already  operating  in  a  large  number  of  MS.  New  Green 
Pharmacy initiatives and actions, e.g. consisting of return schemes for unused and disposed 
medicines, will expectedly strongly benefit SMEs and start-ups. Cost of those initiatives are 
estimated to range between €1-10 million per MS. Local pharmacies / chemists and research 
institutes  are  important  players  in  such  initiatives  that  boost  innovation  and  employment 
including  in  SMEs.  In  the  pharmaceutical  sector,  SMEs  drive  innovation  and  play  a  major 
role  in  the  development  of  new  medicines.  More  than  4  out  of  10  medicines  selected  for 
Environmental  Medicine  Agency  priority  medicines  scheme  were  from  SMEs48.  Therefore, 
the push for substitutes will likely benefit those SMEs in the pharmaceutical sector.  

In the cosmetics and personal care products sector, SMEs also play an important role. In 2020 
France had 840 small and medium-sized enterprises (SMEs) specialized in the manufacturing 
of cosmetic products followed by Italy (735), Poland (606), Spain (515), Germany (348)49. 

Also, the EU-funded research projects such as ‘Implementation of Research and Innovation 
on Smart Systems Technologies’ (IRISS) have helped innovation and supported EU efforts to 
extend competitive advantages of European research institutes and industry (e.g. the Institute 
for Sustainable Chemistry, the Fraunhofer Institute, Starlab Barcelona, Siemens, Hitachi and 
other partners) related to Smart Systems research e.g. to help reduce hazardous substances in 
production  in  the  textile  and  plastics  industries  (66).  Such  projects,  illustrate  that  ‘Safe  by 
Design’ concepts increasingly find their way into politics and the chemical / pharmaceutical 
and personal care products industry (67). 

Pesticides 

For pesticides,  emissions are best  limited by  a  combination of use restrictions,  replacement 
by less harmful alternatives, pathway disruption (e.g. buffer strips) and end-of-pipe measures. 

The  most  important  pathway  to  the  (aquatic)  environment  is  run-off  from  fields. 
Consequently,  on-farm  measures  are  the  most  effective.  Currently  1472  active  substances, 
safeners  and  synergists  are  registered  in  the  EU  pesticides  database  (68).  This  implies  that 
there  are  numerous  approved  authorised  active  substance  that  can  be  used  to  identify  less 
harmful substitutes to replace more harmful pesticides. 

Less  toxic  chemical  alternatives  for  pyrethroids  are  limited  (often  other  pyrethroids).  For 
imidacloprid and triclosan (neonicotinoids) the primary uses relate to the use as a biocide and 
associated losses to the aquatic environment often to sewer. Imidacloprid is used to controls 
fleas  and  ticks  in  domestic  pets.  Primary  chemical  alternatives  for  imidacloprid  are  likely 
pyrethroids,  which  may  present  some  issues  for  certain  animals  sensitive  to  them  (69). 
Triclosan  is  mainly  used  in  medicated  soaps  /  disinfectants,  for  which  substitution  by  less 
harmful  alternatives  is  realistic. Silver is  commonly used as a substitute, but  also  has  risks. 
Annex 10 lists several pesticides, potential alternatives, and estimated costs of alternatives. 

47 https://www.pharmaceutical-technology.com/comment/commentgreen-pharma-the-growing-demand-for-environmentally-friendly-drugs-
5937344/ 
48 https://www.ema.europa.eu/en/human-regulatory/overview/support-smes 

49 https://www.statista.com/statistics/579043/number-of-smes-in-the-cosmetic-industry-in-europe-by-country/ 

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The  use  of  physical  barriers  is  not  at  saturation  level  in  the  EU  yet  and  could  thus  be 
envisaged by MS. Calculations undertaken to help derive indicative (orders of magnitude) of 
costs attributed to the use of pathway disruption for pesticides is included in Annex 10.  

Box 13: Implications of the Urban Wastewater Treatment Directive revision – advanced treatment to be applied over time 

The impact assessment for the revision of the Urban Wastewater Treatment Directive looks amongst others at the the increasing 
quantities  and  variety  of  micro  pollutants  (mainly  pharmaceuticals).  The  impact  assessment  suggests  a  phased  approach  to 
implementation of more advanced treatment, including: 

 
 

 

 

2025: setting up extended producer responsibility schemes. 
2030: identification of areas at risk (facilities from 10-100k people equivalent) and interim targets for facilities above 
100k people equivalent. 
2035: all facilities greater than 100k people equivalent equipped with advanced treatment and interim targets for areas at 
risk. 
2040: all facilities at risk equipped with advanced treatment. 

For  biocidal  uses,  particularly  within  indoor  settings,  the  potential  wash-off  or  rinsing  to 
drains during cleaning and maintenance is an issue. Consequently, end-of-pipe measures for 
those specific uses can have an added value. Annex 10 provides the results of indicative cost 
estimates for the removal of several substances in use as biocides. The IA for the revision of 
the  UWWTD  indicates  that  ozonation  could  be  reasonably  cost  effective  to  remove 
imidacloprid.  Removing  triclosan  requires  reverse  osmosis  (RO)  which  is  costly  and 
challenging to implement at local level. Removing Acetamiprid, Thiamethoxam, Permethrin 
requires  Granulated  Activated  Carbon  (GAC)  which  is  also  expensive.  Reverse  osmosis 
investment  costs  are  estimated  around  €100,000  to  €10,000,000  per  plant,  with  operating 
costs of €0.4 per dm3 (71). Also, RO results in an additional 20% water extraction needed to 
prepare drinking water (due to the requirement for membrane flushing/cleaning), which will 
add to existing water shortage pressure in many MS. 

The  main  costs  in  relation  to  the  reduction  of  pesticides  in  surface-  and  groundwater  are 
expected to be covered by the implementation of the revised legislation on the sustainable use 
of  pesticides  directive  (SUPD).  According  to  the  SUPD  evaluation  there  have  been  no 
remarkable drops in pesticide sales, or losses since 2009. 

Reducing concentrations of pesticides and chemicals overall in GW and SW will reduce costs 
of the drinking water purification sector, an important  share of which are SMEs. SMEs are 
for example active in monitoring and testing of (drinking) water and data analysis. EU wide 
treatment  costs amount to 510 million EUR per year.  If, in  line with  the targets  of the F2F 
strategy,  pesticide  use  is  decreased  by  50%,  treatment  costs  decrease  accordingly  by  205 
million/year.  Corresponding  costs  savings  for  consumers  are  then  around  EUR  5-10  per 
person/year (see Annex 3 for more details). 

According to  the progress  report from the European Commission  on the  implementation  of 
the EU Pollinators initiative (72) the economic value of pollinating insects to crop production 
in the EU is at least 3.7 billion EUR per year. New research shows pesticides are contributing 
to the decline in pollinators. In particular the neonicotinoids are very toxic and persistent and 
contribute to the loss of honeybees. Quite a number are known to be directly toxic for bees 
and  co-responsible  for  bee  poisoning  and  bee  death,  like  e.g.  Imidacloprid,  Clothianidin, 

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Thiacloprid, Thiamethoxam, Dinotefuran, Nitenpyran, Fipronil, and Oleofin. Neonicotinoids 
are extremely toxic to bees. LD50 rates (the rate at which half of the exposed population dies) 
for  clothianidin  are  22-44  nanograms  per  bee  for  direct  contact  and  2.8-3.7  nanograms  per 
bee for oral ingestion. In other words, a single corn kernel with neonicotinoid seed treatment 
potentially contains enough active ingredient to kill over 80,000 honey bees (73) (74). Some 
scientific studies show that bumblebees exposed to neonicotinoids have at least 10% smaller 
colonies  than  those  not  exposed  to  the  insecticide,  others  report  a  57%  decline  in 
reproduction rates (75), with pesticide exposure having the greatest impact on nesting activity 
and the number of offspring the bees produced. Assuming that between 10% or 50% of the 
economic  losses  from  pollinator  decline  are  attributed  to  pesticide  toxicity50,  this  results  in 
mean annual  benefits  of EU and MS action on such pesticides (one of which is  the current 
proposal) from 370 million to 1.85 billion EUR (see Annex 3 for more details).  

Pesticides  users  are  almost  exclusively  SMEs  (farmers,  landscapers,  etc).  As  regards  the 
production and production and marketing side, while a large number of SMEs are active here 
as well (fastest growing segment companies with 50-250 employees, the sector is dominated 
by  very  large  companies,  with  88%  of  the  market  share  for  the  top  7  crop  protection 
companies in the EU51. Impacts will depend heavily on the types of measures taken by MS to 
ensure compliance with the legislation. If users need to revert to alternative pest management 
methods or alternative pesticides this may lead to lower yields or higher costs. If the policy 
measures lead to a drive for innovation, both SMEs and large companies on the development 
and production side will profit. 

Metals 

For  silver  and  its  compounds,  a  myriad  of  sources  and  pathways  to  environment  exist.  For 
anthropogenic activities like smelting, combustion of coal, manufacturing of silver containing 
products, source control options consist of increased abatement and monitoring. Silver is used 
widely  as  antibacterial  agent  in  medicinal,  personal  care  and  other  consumer  products.  The 
widespread  use  of  silver  has  already  led  to  the  release  and  accumulation  of  the  AgNPs  in 
water  and  sediment,  in  soil  and  even,  wastewater  treatment  plants  (WWTPs)  and  is  thus 
impacting microbial communities in different  environmental settings. Scientific evidence of 
silver-driven co-selection of antibiotic resistance determinants is also numerous.  

The  resistance  mechanism  for  nanosilver  (NAg)  is  linked  to  indicated  to  increasing 
environmental  antibiotic  resistance  gene  pools  indicated  by  the  many  antibiotic  resistance 
genes already detected in samples from different environmental settings. These antimicrobial 
resistance genes could ultimately find their ways to animals and humans. This is worrisome, 
as  the  increasingly  indiscriminate  use  of  NAg  could  further  promote  the  development  of 
silver resistance in bacteria. The bacterium ‘Acinetobacter baumannii’ (a bacterial pathogen) 
was  recently  listed  as  the  "number  one"  critical  level  priority  pathogen  because  of  the 
significant  rise  of  antibiotic  resistance  in  this  species52.  Currently,  NAg  still  has  proven 

50  In the United Kingdom, 54% honeybee population lost in the last decades.  In the US 30–40% disappearance of the honeybee colonies 
attributed to colony collapse disorder.  

51 Study supporting the REFIT Evaluation of the EU legislation on plant protection products and pesticides residues 

52 Emerging Concern for Silver Nanoparticle Resistance in Acinetobacter baumannii and Other Bacteria; Oliver McNeilly, et.al, Frontiers in 
Microbiology 16 April 2021, https://www.frontiersin.org/articles/10.3389/fmicb.2021.652863/full 

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bactericidal activity towards this bacterium (A. Baumannii) even against strains that display 
multi-drug  resistance.  Therefore,  it  is  of  utmost  importance  to  avoid  silver  resistance 
developing in this bacterium also in the light of scientific reports on heavy metal-driven co-
selection of antibiotic resistance. Consequently, the widespread use of NAg in commercially 
available  products  promotes  a  prolonged  microorganism  exposure  to  bioavailable  silver, 
which enhances the advance of multi resistant bacteria / micro-organisms. 

Finally,  NAg  and  its  transformed  products  are  toxic  to  environmental  microbes.  Microbial 
and  gene  abundance  shifts  are  observed  in  various  environmental  settings.  Physical  and 
chemical  transformations  of  NAg  can  shift  the  diversity  and  abundance  of  microbes, 
including those that are important  in  nitrogen cycles and decomposition of organic matters. 
The  combined  ecological  impacts  of  NAg  call  for  a  prudent  use  of  silver  and  AgNPs  and 
minimising their water related emissions 53. 

Source  control  could  include  pre-treatment  or  onsite  waste  water  treatment  by  reverse 
osmosis (RO) prior to direct discharges or releases to sewer, amounting to an estimated cost 
of 0.1% of the industry’s annual turnover54. Alternatively, urban waste water treatment plants 
would need to invest in reverse osmosis to clean such effluents. Assuming that between 1-5% 
UWWTPs would have to deploy reverse osmosis, costs for EU taxpayers would be between 
€2,184,600  and  €109,230,000.  Assuming  the  benefits  of  reducing  silver  related  AMR  to 
equal between 50% to 100% of the AMR costs for antibiotics, this results in EU-benefits of 
between €22 to  €63  billion55  (2014 data, subsequently  corrected for inflation between 2014 
and 2021). 

Pathway disruption measures consist of capturing and treating of mine drainage water before 
it reaches water bodies. A targeted plan of action to tackle emission might be needed on a MS 
by MS basis. 

As  detailed  in  Annex  9,  table  A9.1,  the  social  impact  of  listing  additional  substances 
mentioned  in  this  paragraph  concerns  better  protection  of  health  in  particular  through 
addressing the health and environmental effects of nanosilver, including the role of silver in 
antimicrobial  resistance,  food  security  and  ecosystem  services  such  as  avoided  impact  on 
pollinators. 

53 The impact of silver nanoparticles on microbial communities and antibiotic resistance determinants in the environment, Kevin Yonathan 
et.al. Environmental Pollution 15 January 2022, 293: https://pubmed.ncbi.nlm.nih.gov/34793904/ 

54 An extrapolation of the RO costs based on the number of EU non-ferrous metals production facilities 84754 in 2019, assuming that around 
5% - 10% of effluents need treatment, would potentially result in EU wide costs ranging from €423,500 to €8,470,000. In relation to the 
annual turnover of the EU non-ferrous metals industry (120 billion54) this would equal 0.1%. 
55 Costs are converted using an average of USD 1 = EUR 0.75 for 2014, and then using an average inflation rate of 1.95% per year between 
2014 and 2021, producing a cumulative price increase of 14.5% 

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Box 14: Views on positive impacts of listing new PS expressed during consultation activities 

When  asked  to  estimate  the  significance  of  economic,  health,  social  and  environmental  benefits  /  impacts  resulting  from  the 
inclusion  of  new  candidate PS,  the  respondents  generally  found  all  impacts  to  be  cumulatively  positive  (i.e.  %  selecting  minor, 
moderate or major benefit outweighed the % rating as ‘no benefit’). Benefits from improved surface water quality, lower risk 
of damage to natural resources and benefits from improved environment and human health protection were valued most 
(respectively  34%,  32%  and  30%  of  respondents  selecting  ‘major’  benefits).  The  impacts  of  new  candidate  substances  on  the 
quality  of  process  water  for  agriculture  and  industry  received  the  greatest  number  of  ‘no  benefit’  responses  (16%).  Impacts 
regarding employment opportunities were identified as being largely unknown, indicated by the large share of ‘I do not know/no 
opinion’ responses (57%). 

6.2.2  6.2.2  Policy option 2 – listing candidate PS as a group 

Under  this  policy  option  substances  would  be  added  under  family  groupings:  PFAS56, 
estrogenic hormones, macrolide antibiotics, neonicotinoids and pyrethroids. This could limit 
the  burden  on  MS  as  well  as  disincentivise  substitution  with  another  similarly  hazardous 
substance in the same group. A group approach also helps better address overall cumulative 
risks  of  substances  with  similar  toxicity  and  modes  of  action  and  can  help  capture 
degradation products of the substances with the same effects. 

There  are  9,000+  per-  and  polyfluoroalkyl  substances  (PFAS)  in  existence,  which  makes 
regulating PFAS individually infeasible. It is estimated that an EU PFAS ban in firefighting 
foams may cost society €390 million per year over a 30-year period (26). For surface water 
the  major  pathway  is  fire-fighting  foams  providing  significant  losses  directly  to  the 
wastewater  system.  The  environment  of  oil-drilling  sites  and  airports  (due  to  drills  and 
exercises)  is  typically  highly  contaminated,  with  potential  remediation  costs  of  €0.6-2.5 
billion for the 85057 larger airports in Europe58 or even €18.3 billion when all EU military and 
small  airports59  are  included.  Economic  benefits  from  avoiding  PFAS  ending  up  in  water 
include  the  potential  for  water  reuse,  including  for  irrigation  purposes  in  line  with  the  new 
Regulation  on  minimum  requirements  for  water  reuse.  Benefits  (avoided  costs)  of  PFAS 
removal  in  waste  water  are  considerable:  at  least  €9.13  billion/year60.  Moreover,  PFAS 
removal processes create large additional amounts of waste (brine) – approximately 25% of 
treated  water  (76)  requires  separate  treatment  and  subsequent  re-mineralisation  to  create 
drinking  water.  Estimates  of  the  avoided  cost  for  reverse  osmosis,  specifically,  to  prepare 
drinking  water  amount  to  over  €1/m³  equalling  circa  €200  per  household  per  year  (77), 
equalling  avoid  water  treatment  costs  of  39.1  billion  annually,  if  applied  to  all  195  million 
EU  households.  Also,  not  having  to  use  RO  to  produce  drinking  water  will  result  in  20% 
savings of water extraction volumes compared to a situation in which RO would be required. 
Total annual health-related costs, for three different levels of exposure, were found to be at 
least EUR 52 to EUR 84 billion in the EEA countries. Non-health-based costs environmental 
PFAS remediation totalling EUR 821 million to EUR 170 billion (EEA/EU), with plausible 
best estimate EUR 10–20 billion. In addition, measures at source would avoid costs of at least 

56 Note PFAS substances include around 4,000 to 7,000 substances (depending on definition), so addition always requires grouping 
approaches. Consequently, in this initiative PFAS are grouped using a grouping metric (PFOA-equivalents) and relative potency factors 
(RPFs). 
57 Eurostat : https://appsso.eurostat.ec.europa.eu/nui/setupDownloads.do 
58 https://ourairports.com/continents/EU/ 
59 If counting all military and recreational airstrips the total number increases to 6106 airports: https://ourairports.com/continents/EU/ 
60 Results from the ZeroPM project (EU funded Horizon 2020) identified PFAS in 100% of the wastewater samples across the EU 
https://zeropm.eu/ and https://www.ngi.no/eng/Projects/ZeroPM 

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€39.4 million EU-wide related to a complete removal of PFAS from paper mills effluents and 
sludges. 

Health costs of hormone disrupting chemicals, including estrogenic hormones, are estimated 
at €150 billion a year61. Studies also show strong toxicological evidence for male infertility 
attributable  to  EDC  exposure,  with  a  40-69%  probability  of  causing  618,000  additional 
assisted  reproductive  technology  procedures,  costing  €4.71  billion  annually  (78)  (79)  (80). 
The effects of the exposure such endocrine disrupting substance (EDCs) have been linked to 
reproductive  problems  (e.g.  with  declining  sperm  counts),  some  cancers,  impaired 
intelligence, obesity and diabetes, but also with effects on animals, with invertebrates being 
the  most  sensitive  (81).  Studies  concluded  an  EDC  causation  for  IQ  loss  and  associated 
intellectual  disability,  attention-deficit  hyperactivity  disorder,  childhood  obesity,  adult 
obesity, adult diabetes, cryptorchidism, male infertility, and mortality associated with reduced 
testosterone,  e  estimated  to  cost  of  €157  billion  (corresponding  to  1.23%  of  EU  gross 
domestic product) annually (82). For macrolide antibiotics, measures across the life cycle of 
medication  are  required.  As  an  example,  many  pharmaceuticals  but  also  PFAS,  can  harm 
reproduction,  reproductive  success,  and  population  health  not  only  for  aquatic  species,  but 
indirectly  also  for  humans.  Therefore,  benefits  are  also  expected  for  the  aquaculture  sector 
through avoided costs associated with losses of fish and shellfish populations in aquaculture 
farms. Some of the most affected species are trout (2019 EU production value €677 million), 
seabass (€491 million), crustaceans (€1.05 billion) and salmon (€1.34 billion) (83). Assuming 
that 5% -10% of the production value can be related to EDC exposure results in annual EU 
wide avoided costs ranging from €177 - €355 million. 

Social impacts of the policy option assessed in this paragraph are, as mentioned in Annex 9, 
table  A9.3,  limited  to  more  effective  management  of  the  substances  when  grouped  as 
opposed to individual listing. 

6.2.3  6.2.3  Policy option 3 – revising EQS for certain existing PS 

The assessment finds that, for the substances concerned, the additional effort to be made by 
MS to reach the EQS will be small to relatively large (see Chapter 6.1.1 and Annex 4).  

For cypermethrin, a combination of source control, substitution by less harmful alternatives, 
and end-of-pipe measures are likely needed as the substance is commonly used as pesticide 
and wood preserving chemical. Costs to remove cypermethrin in UWWTPs are estimated at 
€26.2  (per  population  equivalent,  per  year).  PBDEs  and  Di-2-ethylhexyl  phthalate  (DEHP) 
and  its  compounds  are  associated  with  health  effects  such  as  cognitive  deficits,  (testicular) 
cancer  and  cryptorchidism  as  well  as  adult  obesity,  adult  diabetes,  and  reproductive  effects 
for  females  (endometriosis)  (84).  Mercury  and  its  compounds  and  organophosphate 
pesticides are associated with cognitive deficits resulting from exposure (85).  

For  diuron  and  chlorpyrifos,  market  authorisations  expired  recently,  meaning  remaining 
stockpiles will be used up and exemptions (emergency authorisations) will drive emissions. 
Other  topics  relate  to  legacy  issues  resulting  from  the  persistence  of  such  substances.  For 

https://www.bbc.com/news/health-31754366 

61 
https://www.theguardian.com/environment/2015/mar/06/health-costs-hormone-
disrupting-chemicals-150bn-a-year-europe-says-study and https://www.endocrine.org/news-and-advocacy/news-room/2015/estimated-costs-
of-endocrine-disrupting-chemical-exposure-exceed-150-billion-annually-in-eu  

and 

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diuron  a  possible  remediation  measure  could  be  removing  and  replacing  obsolete 
contaminated  wood-based  infrastructure.  In  some  instances,  the  use  of  dredging  may  be 
appropriate for the removal of substances bound to the sediment in waterbodies, which can be 
relatively cheap or very costly, depending on the level of after treatment required.  

The social impacts of this option are principally in greater human health protection from the 
chronic  or  bio  accumulative    nature  of  the  pollutants  concerned.  Details  can  be  found  in 
Annex 9, table A9.4. 

6.2.4  6.2.4  Policy option 4 – deselection of priority substances 

These substances were identified to no longer pose an EU-wide risk to the environment and 
public health.  Alachlor,  Simazine and Chlorfenvinphos  (herbicides) have  banned in  the EU 
for many years, and concentrations above the EQS are identified in a very limited number of 
water bodies (table A11.2). Therefore, the overall risk to the environment is considered to be 
low.  

Use  of  Trichlorobenzenes  (solvents  and  chemical  intermediates)  is  ongoing,  and  the 
substances are acutely toxic to the aquatic environment. The rates of EQS exceedance are not 
very high, but deselection is more questionable than for the other substances given the degree 
of risk they post and their relevant for the MSFD.  

Carbon tetrachloride is  not  recognised as a POP  and the rates of EQS  exceedances  are low 
with declining trends, indicating localised issues and no EU-wide risk. Also, the ongoing use 
of this substance is  directly or indirectly  controlled and monitored under other policies like 
REACH,  IED,  the  Regulation  for  the  Classification  and  Labelling  of  Chemicals  (CLP), 
therefore deselection from the PS list would not result in a negative environmental or societal 
impact.  

All substances have in common that, even if they were removed from the PS list, they might 
still be relevant as RBSPs, and MS could decide to continue monitoring them at national level 
where needed. Deselection could free up resources that can be reallocated to emerging risks, 
e.g. due to saved monitoring costs (between €4 and €12 million annually at EU level).  

Deselection as assessed in option 4 is not expected to have negative social impacts since the 
risk  of  exposure  to  the  substances  concerned  is  very  low.  A  possible  negative  effect,  in 
relation  to  trichlorobenzenes  and  carbon  tetrachloride,  may  be  that  less  monitoring  would 
reduce the information base for deciding on reduction measures. Hence for these substances 
an approach at River Basin level should be considered. 

Box 15: Views on impacts of deselection expressed during consultation activities 

Deselection of Alachlor, Chlorfenvinphos and Simazine was considered by most (respectively 47%, 46% and 45%) of the TEC 
respondents  to  have  no  negative  impacts  for  either  the  environment  or  human  health,  whereas  only  8%  thought  so  for  Carbon 
tetrachloride. The biggest concern raised for deselection was a loss of monitoring data to track trends. However, one respondent 
highlighted that if there was a concern a substance could be retained as an RBSP. 
Many  (i.e.  48-64%)  respondents  ‘didn’t  know/had  no  opinion’  regarding  the  economic  benefits  of  deselection,  however,  the 
remaining responses indicate deselection to have at least some economic benefits for all substances considered (28-45%). 
Note:  Trichlorobenzenes  were  not  included  in  the  consultation  surveys  due  to  their  late  addition  to  the  candidate  list  for 
deselection. 

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6.3  6.3 

Groundwater – impacts of policy options  

A  key  aspect  of  understanding  the  potential  impact  of  the  groundwater  policy  options  is 
defining the “gap” between the baseline situation and meeting the proposed GW QS or likely 
national TVs set at MS level for pollutants listed in Annex II of the GWD. Subsequently this 
assessment was used as the basis for determining the types and potential level of uptake of 
measures needed to get to good chemical status, and how their implementation would impact 
stakeholders. Likely environmental, economic and social impacts were assessed, and various 
impacts of the options described (incl. the administrative burden on responsible authorities). 

It needs to be noted however that the quality of the data for groundwater in Europe are, for 
several reasons62, of a lower quality compared to surface water. Consequently, the outcomes 
of the distance to target assessment and the comparison of the impacts of the policy options 
are subject to a higher level of uncertainty. 

Measures  to  address  PFAS,  nrMs  or  pharmaceuticals  can  be  remediation  of  soil  or  the 
groundwater (e.g. in case of polluted fire-fighting sites), source control (bans or restrictions 
on  use,  substitutes,  guidance  on  proper  use,  avoiding  production  losses)  and  end-of-pipe/ 
pathway disruption (wastewater or landfill leachate treatment, incineration or landfilling). 

Costs vary strongly depending on the type of measure. Examples can be found in Annex 10. 

6.3.1  6.3.1  Policy option 1 – listing LFR substances individually or as group of 

specific chemicals in GWD Annex I 

PFAS 

The  main  additional  expense  for  most  MS  will  be  the  costs  of  laboratory  analysis,  and  in 
particular Option 1 (a group of 24 PFAS in Annex I and assigned a GW QS of 4.4 ng/l PFOA 
equivalent), where a “sum of” methodology or very low concentrations need to be analysed 
and are likely to require more effort, and 2 (all PFAS in Annex I with a GW QS for “PFAS 
total”  of  0.5  µg/l).  The measures  likely  to  be  used  by  MS  are  similar  for  all  options  (aside 
from Option 3). 

A cheap source measure to reduce future emissions of one of the 24 specific PFAS would be 
to  use  other  PFAS  substitutes  not  used  yet.  This  would  however  potentially  trigger  new 
legacy  issues  in  the  future  because  of  PFAS  persistence.  For  the  regulated  PFAS  (PFOS, 
PFOA,  PFHxS,  PFHxA  and  the  C9-C14  carboxylic  acids)  stringent  measures  that  restrict 
emissions  are  already  in  place;  it  is  likely  that,  for  the  remaining  group  of  10  substances, 
which overlap with the DWD substances and the EQSD proposed substances, further controls 
should be instigated at the EU level with cost to industry.  

Pathway  disruption  measures  like  the  capture  of  contaminated  sludge,  containing  and 
incineration are very costly due the energy intensiveness, so these measures are suitable only 
in  extreme  circumstances.  Guidance  on  the  best  practise  use  of  waste  and  wastewater  by-
products  in  agriculture  would  be  a  cheaper  option.  However,  this  will  ultimately  result  in 

62 For the 15,930 GWBs reported by the EU27 in 2016, a large number of water bodies have no monitoring results. This means their status is 
assessed through grouping of characteristics including pressures and risk, extrapolation of evidence, and expert judgement. Generally, the 
GW WL data is of much lower quality compared to surface water watch list data for reasons like the voluntary nature of data collection and 
inconsistent reporting formats used. 

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PFAS accumulating in agricultural soils. Instead of using pathway disruption measures, it is 
more likely that for Options 1 and 2 actions to restrict use of PFAS and better management of 
waste streams are used, as well as groundwater or soil remediation. 

Pharmaceuticals 

As regards Option 1 (adding Carbamazepine and Sulfamethoxazole to Annex I), this would 
likely  lead  to  some  administrative  burden  on  those  MS  which  do  not  yet  monitor  these 
substances. A worst-case estimate is €2 million per year at EU level. 

nrMs 

The  costs  of  adding  nrMs  to  the  monitoring  networks  are  likely  to  be  limited,  since  the 
existing  framework  for  assessing  risk  to  groundwater  from  ‘parent’  pesticides  and  their 
relevant  metabolites  are  already  in  place.  A  small  increase  in  costs  is  likely  for  Option  1 
(adding  all  nrMs  to  Annex  I  as  individual  substances  with  a  GW  QS  of  0.1  µg/l),  since  it 
requires,  at  least  for  those  countries  which  are  not  already  doing  this,  that  “all  nrMs”  are 
included in the analysis. 

The implementation of the EU Farm to Fork Strategy will likely lead to reductions in the use 
of  any  permitted  parent  pesticides  of  the  nrMs  considered.  This  will  be  delivered  in  part 
through  the  planned  revision  of  the  Directive  on  the  Sustainable  Use  of  Pesticides  and 
national  action  plans  for  pesticide  use  reduction.  This  will  limit  what  additional  measures 
need  to  be  taken  to  protect  their  water  bodies.  By  including  all  nrMs  in  Annex  I  under 
Options  1  and  2,  the  administrative  burden  may  be  progressively  reduced  further  as  the 
legislation would be “future proofed”. 

Environmental  benefits  are  rather  similar  for  all  the  nrM  options  but  options  covering  all 
nrMs and setting a GW QS at EU level (i.e. Option 1 and 2) are expected to generate greater 
benefits.  Benefits  include  reduction  and  possibly  reversal  of  impacts  on  groundwater  biota, 
benefits  for  ecosystems  services  provided  by  the  groundwater  and  linked  surface  water, 
increased  quality  process  water  from  groundwater  /  surface  water  for  drinking  water, 
agriculture and industry. 

6.3.2  6.3.2  Policy option 2 – listing LFR substances as groups of substances in GWD 

Annex I 

By grouping similar pollutants, with a GW QS for the total group, legislation can deal with 
large substance groups with rapidly changing information on the impacts which would, in a 
sense, “future proof” legislation. 

PFAS 

The main additional expense under Option 2 (all PFAS in Annex I with a GW QS for “PFAS 
total” of 0.5 µg/l) for most MS will be the costs of laboratory analysis. 

Pharmaceuticals 

The main administrative benefit of Option 2 (adding all pharmaceuticals as a group to Annex 
I) is that it “future proofs” the listing by including substances which may become problematic 
in future and stimulates the modernisation of analytical techniques. The latter would result in 

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considerable  cost  savings  as  soon  as  modern  techniques  have  become  more  commonplace. 
Under Option 2b direct analytical costs will be around €5.5 million per year, with potential 
administrative costs taking this up to a total of €11 million per year. For Option 2c (adding all 
pharmaceuticals as a group to Annex II for MS to consider setting a TV), the analytical costs 
will vary between MS depending on the TVs adopted and the monitoring strategy used, but 
the impact on administrative burden to MS would be smaller. 

Estimated  costs  of  measures  for  Option  2  are  shown  in  Annex  10.  Many  of  these  are 
considered cost-effective and acceptable for society. The main environmental costs of adding 
pharmaceuticals to the GWD would be implementation of measures to deal with wastewater 
/biosolids  containing pharmaceuticals  which can be energy intensive and require the use of 
chemicals. The incineration /landfilling of biosolids is suggested as a last resort measure as 
there is currently no viable treatment to remove pharmaceuticals from these media. 

Environmental  benefits  of  adding  substances  largely  consist  of  lower  risk  of  (irreversible) 
damage to natural ecosystems. These benefits are greatest under Option 2, due to the wider 
range of pharmaceuticals addressed. 

Under Option 2 the understanding of the impact of pharmaceuticals on groundwaters is most 
pronounced.  Also,  the  aim  of  the  Pharmaceuticals  Strategy  to  reduce  the  level  of  anti-
microbial resistance is best supported by this option. 

nrMs 

The  costs  of  adding  nrMs  to  the  monitoring  networks  are  likely  to  be  limited,  since  the 
existing  framework  for  assessing  risk  to  groundwater  from  ‘parent’  pesticides  and  their 
relevant  metabolites  are  already  in  place.  A  small  increase  in  costs  is  likely  for  Option  2 
(adding all nrMs to Annex I with a group GW QS of 10 µg/l), since it requires, at least for 
those countries which are not already doing this, that “all nrMs” are included in the analysis. 

Environmental  benefits  are  rather  similar  for  all  the  nrM  options  but  options  covering  all 
nrMs and setting a GW QS at EU level (i.e. Option 1 and 2) are expected to generate greater 
benefits.  Benefits  include  reduction  and  possibly  reversal  of  impacts  on  groundwater  biota, 
benefits  for  ecosystems  services  provided  by  the  groundwater  and  linked  surface  water, 
increased  quality  process  water  from  groundwater  /  surface  water  for  drinking  water, 
agriculture and industry.  

6.3.3  6.3.3  Policy option 3 – listing LFR substances in GWD Annex II 

PFAS 

Option  3  for  PFAS  would  lead  to  TVs  being  set  by  individual  MS  using  drinking  water 
standards and likely focusing on point source pollution rather than on diffuse pollution. The 
most likely measures to deal with pollution point sources could be to initiate soil remediation 
measures, e.g. for pollution hotspots like firefighting sites. This option would moreover lead 
to  diverging  national  TVs  and  thus  be  detrimental  to  the  objective  under  Art.  7  WFD  to 
setting uniform EU quality standards for groundwater. Setting a uniform GW TV at EU level 
would, on the contrary, lead to savings in treatment costs. 

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Costs for all PFAS inclusion in Annex II for MS to consider setting a TV (Option 3) will be 
the lowest, given the DWD requirements and additional data collated. This is especially the 
case  for  the  MS  which  are  already  monitoring  PFAS  and  carrying  out  risk  assessments  for 
groundwater. 

Pharmaceuticals 

Option 3 will have significantly less environmental benefits compared to Options 1 and 2 and 
distortion of the ‘level playing field’. 

nrMs 

The  costs  of  adding  nrMs  to  the  monitoring  networks  are  likely  to  be  limited,  since  the 
existing  framework  for  assessing  risk  to  groundwater  from  ‘parent’  pesticides  and  their 
relevant metabolites are already in place. The administrative burden of Option 3 (adding all 
nrMs to Annex II for MS to consider setting a TV) will be smaller at EU level but higher at 
MS level, because of the need to set TVs at national level. 

Additional  measures  that  could  be  considered  by  MS  would  mainly  focus  on  the  amenity 
/legacy  pollution  including  substitution  through  less  harmful  substances,  remediation  of 
existing / historical sources and use of other weed control methods for amenity use. 

If measures taken by MS to reduce nrMs in groundwater would include source control such 
as restrictions on use this would have an impact on the farming sector and possibly also on 
crop yields. Estimated costs of using substitution products are shown in Annex 10: it should 
be  in  particular  stressed  that  less  toxic  alternatives  do  exists  for  at  least  the  five  permitted 
parent pesticides, with similar cost ranges. 

For  Option  3  (TV  set  at  MS  level)  greater  variance  in  environmental  benefits  is  expected 
between  MS.  Benefits  include  reduction  and  possibly  reversal  of  impacts  on  groundwater 
biota, benefits for ecosystems services provided by the groundwater and linked surface water, 
increased  quality  process  water  from  groundwater  /  surface  water  for  drinking  water, 
agriculture and industry.  

As specified in tables A9.7 through A9.9 social impacts are mostly related to better protection 
of  health  due  to  lower  exposure  to  substances,  in  particular  from  the  PFAS  group  and 
pesticides. Indirect social benefits are generated through improved ecosystem services (better 
protected water sources,  recreation, less polluted fish etc). Possible negative effects  include 
lower  yields increased  costs in  farming or higher costs,  as  well, in relation to  antibiotics, a 
limited reduction of choice in available antibiotics options.  

Impacts on SMEs under the groundwater options follow the same pattern as under the surface 
water options. 

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Box 16: Views on positive impacts of listing groundwater pollutants expressed during consultation activities 

Majority  of  TEC  respondents  were  unsure  about  the  significance  of  benefits  of  listing  new  groundwater  pollutants  (32-56% 
indicating  ‘I  don’t  know  /  No  opinion’).  Overall,  cumulative  positive  impacts  were  perceived  for  all  categories  included  in  the 
questionnaire, with the following significance levels most widely chosen: 

  Major  benefits  from  improved  water  quality,  improved  environment  and  human  health  protection  (35%),  lower 

production and maintenance costs through availability of cleaner raw water (32%), improved well-being (2%). 

  Moderate benefits associated with availability of clean GW for abstraction (24%). 
  Minor benefits from increased resource efficiency through reuse and recovery of materials (32%), climate change through 

reduced energy use (29%), lower risk of (irreversible) damage to natural resources (21%). 

Views  on  the  significance  of  benefits  from  increased  potential  employment  opportunities  were  inconclusive  (major  and  minor 
levels  each  selected  by  18%).  Respondents  were  most  sceptical  about  benefits  from  reduced  risk  of  water-related  illnesses  and 
premature deaths (21% selecting ‘No benefit’), benefits for agriculture and industry as well as wastewater treatment (15%). 

6.4  6.4 

Monitoring,  reporting  and  administrative  streamlining  –  impacts  of 

options 

The  impacts  of  all  policy  options  related  to  monitoring,  reporting  and  administrative 
streamlining  are  described  below.  Clear  synergies  exist  between  this  initiative,  the  Zero 
Pollution Outlook, and the Commission proposal for a Regulation of the Industrial Emissions 
Portal  (IEPR,  former  E-PRTR),  the  EU  Strategy  for  Data,  the  INSPIRE  Directive,  and  the 
Directive on Public Access to Environmental Information. In particular, data collected under 
policy options 3, 4, 6 and 7 would lead to better water quality data in shorter than the current 
6-years  intervals.  This  water  related  data  could  complement  and  be  cross  referenced  with 
publicly  available  data  on  emissions  from  industrial  installations  covered  by  the  IEPR  and 
help  monitor  the  effects  of  the  implementation  of  new  Best  Available  Techniques  on  the 
aquatic  environment  surrounding  such  installations.  Vice  versa,  an  improved  digital  data 
collection  on  geographical  and  seasonal  pesticides  use  under  the  envisaged  revised 
Sustainable  Use  of  Pesticides  Regulation,  would  be  highly  valuable  input  for  an  improved 
implementation of legislation like the WFD and the EQSDs, as well as the EU Biodiversity 
Strategy  2020,  the  common  agricultural  policy  (CAP),  and  the  Thematic  Strategy  on  Soils. 
Finally, for practically all of (sub)options, related to digitalisation, improved monitoring etc., 
existing EU research projects funded through FP7, H2020 and Horizon Europe can support a 
further  practical  development,  and  outcomes  of  past  and  ongoing  Research  &  Innovation 
(R&I) projects could consequently also help reduce costs of an increased digitalisation .  

Box 17: Views on monitoring, reporting, and administrative streamlining options expressed during consultation activities 

Regarding  monitoring  approaches,  varying  views  were  provided  on  guidelines  to  alternative  monitoring  methods,  noting  that 
innovative approaches (such as EBM) could improve freshwater quality yet may result in a greater monitoring burden to actors. 
Respondents voted the increase in monitoring frequency of substances in the Surface Water Watch List as the most effective 
method for improving the risk response and management (average score of 3.2 on a scale from 1 - not at all – to 5 – very much). 
However,  the  responses  received  displayed  significant  polarity:  26%  (n=12,  represented  by  a  mix  of  business  associations, 
companies  and  MS  competent  authorities)  rating  the  measure  as  non-effective  (i.e.  1)  and  another  28%  (n=13,  mostly 
representatives of MS authorities and academic research) as highly effective (i.e. 5). 
On data management, most benefits were perceived for guidelines to standardise data collection and reporting formats. Overall, 
the responses indicated that a combination of approaches may be more suitable in achieving the desired harmonization of the RBSP 
thresholds rather than just one specific measure. 

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6.4.1  6.4.1  Policy option 1 – Guidance and advice on monitoring 

Sub-option  (a):  Develop  guidelines  on  applying  innovative  methods  in  monitoring 
procedures, including continuous / automated monitoring techniques 

The  impacts  of  Sub-option  1a  are  limited  since  it  would  summarise  best  practise  examples 
and use those to detail how approaches can be implemented. The expected costs are limited, 
but  the  potential  impacts  and  associated  benefits  for  MS  monitoring  programmes  can  be 
significant  if  properly  implemented  and  would  lead  towards  harmonised  monitoring  and 
measurement approaches for contaminants of emerging concern. The costs for developing EU 
guidelines ranges from around €290,000 for simple guidance documents to around €500,000 
for more elaborate documents (see Annex 10). Based on the assumption that around 1 or 2 
guidance  documents  on  innovative  monitoring  methods  would  be  required,  total  EU  costs 
range from €580,000 to €1 million. 

Sub-option  (b):  Improve  existing  EBM  guidelines  to 
improve  monitoring  of 
groups/mixtures  of  pollutants  by  using  EBMs,  and  define  trigger  values  for  assessing 
the status of a water body. 

The impacts of Sub-option 1b involve the further development of guidelines on the types of 
effect-based  methods,  and  deriving  trigger  values63  for  mixture  pollutants  to  be  applied  in 
practise.  Effect-based  trigger  (EBT)  values  establish  the  likelihood  of  adverse  impacts  on 
water quality and are used to differentiate good from poor water quality. EBT values for in 
vitro bioassays can be used to assess if a water body is in good or poor status based on the 
effects on the aquatic organisms. Also, by dividing bioanalytical responses by their respective 
EBT  values,  effect-based  risk  quotients  can  be  obtained,  which  can  then  be  summed  per 
location to assess the cumulative ecotoxicological risks. Consequently, they are important for 
surface  water  quality  monitoring  while  considering  mixture  toxicity,  but  of  course  in  close 
alignment  with  EQSs  for  individual  chemicals.  Costs  for  the  further  development  of  EBM 
guidelines  are  comparable  to  those  of  a  simple  guidance  document  and  are  estimated  at 
€290,000. 

Sub-option  (c):  Develop  a  harmonised  measurement  and  monitoring  method  and 
guidance  for  microplastics  in  surface  water  and  groundwater,  as  a  basis  for  MS 
reporting on microplastics and a future listing under EQSD and GWD. 

Overall cost to society of microplastics is estimated between €10.8 to €19.1 billion (36) (86). 
One  major  microplastics  category  the  EU  intends  to  address  (others  are  textiles,  pellets, 
paints,  geotextiles,  detergents  capsules)  is  tyres.  A  recent  revision  of  the  Tyre  Approval 
Regulation has removed the worst performing tyres from the market (87) while EU labelling 
of tyres according to their abrasion rates is a strong incentive to push the market to the best 
performing  tyres  amongst  those  left  on  the  market.  Physical  barriers  to  avoid  microplastics 
ending  up  in  surface  waters  would  be  effective  measures  as  well  (so  called  gully  pots  to 
capture  particles  or  microplastic  filters  in  washing  machines  (88)  as  foreseen  in  the  EU 
microplastics initiative. End-of-pipe treatments for microplastics could be effective too, at a 
cost  between  €0.08-0.20  per  cubic  metre  of  wastewater  treated  per  year  (see  upcoming 

63 Bioassay responses are compared to effect-based trigger values to identify potential ecotoxicological risks in water bodies (126). 

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UWWTD  revision,  whereby  the  application  of  tertiary  level  treatment  in  WWT  plants  is 
being  proposed  for  larger  agglomerations  at  risk).  This  treatment  will  trigger  knock-on 
problems  with  the  plastic-contaminated  sludge,  which  are  being  assessed  in  the  ongoing 
Evaluation of the SSD 

The  impacts  of  Sub-option  1c  involve  the  costs  of  development  of  a  harmonised 
measurement  standard  and  guidelines  for  monitoring.  As  a  relatively  unchartered  territory, 
initial costs may be higher than for traditional chemical substances or groups of substances. 
Based on expert judgement  from  the JRC related to  developing a harmonised measurement 
and monitoring method for microplastics in drinking water, and information from EU funded 
projects supporting the EU Plastic Strategy64, the development of a harmonised measurement 
and monitoring methodology for microplastics and the accompanying guidance is estimated 
to cost between €290,000 to €500,00065. Once the method is developed, the annual EU costs 
for  measuring  and  monitoring  microplastics  are  estimated  to  range  from  €7.3  to  €13.4 
million66.  

A harmonised measurement  and monitoring method for microplastics is  a vital  prerequisite 
for  monitoring  by  MS  and  future  development  of  policies  to  reduce  emissions  to  surface 
water,  groundwater  and  coastal  waters.  Mandatory  monitoring  according  to  a  harmonised 
methodology  will  provide  a  wealth  of  monitoring  data  on  types  and  quantities  of 
microplastics  occurring  in  surface  water,  groundwater  and  coast  waters.  Firstly,  this  is 
paramount  for  improving  the  current  limited  understanding  of  the  environmental  fate  and 
behaviour  of  microplastics.  Secondly,  this  supports  follow-up  studies  like  the  Bleu2  study 
(89),  and  allows  developing  and  validating  future  simulation  models  (no  microplastics 
simulation  model  was  found  in  the  EC  Modelling  Inventory  (MIDAS)).  Finally,  obtained 
monitoring  results  could  facilitate  the  assessment  of  effectiveness  of  other  EU  policies 
dealing  with  microplastics  (e.g.  the  upcoming  initiatives  on  controlling  unintentional 
releases).  

Sub-option (d): Develop guidelines on sampling frequency for PSs and RBSPs. 

Sub-option  1d  involves  the  development  of  a  guidance  document  for  MS  on  best-practice 
sampling  approaches  for  PSs  and  how  to  integrate  such  approaches  into  water-quality 
assessments  and  monitoring  strategies.  This  sub-option  will  require  limited  administrative 
effort, particularly at EU level, while benefits relate to increased harmonisation of sampling 
frequencies across the EU, and therefore greater comparability of data between countries and 
river  basins,  allowing  for  more  targeted  policy  interventions.  Costs  to  develop  these 
guidelines are expected to be between €290,000 to around €500,000 (Annex 10). The Fitness 
Check of EU environmental reporting and monitoring acquis (10) estimated the approximate 
annual  administrative  burden  related  to  reporting  to  MS  for  the  EQSD  to  be  moderate  (i.e. 
within the range of €30,000 and €100,000 per MS). The estimated additional costs of aligning 
sampling frequencies to the developed guidance is expected not to exceed more than 5-10% 
of those costs. 

64 Horizon 2020 EUROqCHARM project works towards validated harmonised methods for monitoring & assessing macro-, micro- and 
nanoplastics in environment: https://www.euroqcharm.eu/en 
65 Estimate based on development of microplastics methodology for Drinking Water Directive and the qualification of guidance documents 
from Annex 10 Table A10.5. 
66 Based on the assumption that each MS will designate one of its water analysis laboratories as national laboratory of excellence for 
measuring microplastics. Between 5% and 10% of the total number of surface water bodies and groundwater bodies would be sampled. 
Estimates of CAPEX and OPEX costs were taken from literature. 

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Sub-option  (e):  Provide  a  repository  for  sharing  best  practices  from  MS  regarding 
available monitoring techniques, and foster cooperation to implement these. 

Option  4  foresees  the  development  of  an  online  repository  of  standards  and  best-practice 
approaches to improving MS monitoring techniques. This would build upon and complement 
option  1,  providing  a  living,  online  location  to  allow  consistent  updates  on  monitoring 
techniques and providing a forum for actors to facilitate knowledge transfer. This option will 
require  a  limited  administrative  effort,  particularly  at  EU  level.  Cost  of  developing  and 
hosting  a  simple  repository  of  best  practices  is  similar  to  those  for  drafting  guidance 
documents and ranges from €290,000 to €500,000 (Annex 10, Table A10.5). 

6.4.2  6.4.2  Policy option 2 – Obligatory monitoring practices 

Sub-option (a): Include an obligation in the EQSD to use EBMs to monitor estrogens. 

Option  2a  involves  the  mandatory  use  of  EBMs  to  monitor  estrogens  in  practice  (90). 
Commercially available bioassays (e.g. ER-CALUX, A-YES and others) are important tools 
for assessing the toxicity of water samples  (91).  License-free versions  of  this type of assay 
are  commercially  available  and  are  covered  by  international  inter-laboratory  trials.  ISO 
19040-3 defines validity criteria covering further cell-line-based reporter gene assays. Also, 
sample preparations do not require special treatment, and extraction / concentration methods 
are based Solid Phase Extraction (also used for analytical methods) which is very cheap. If 
performed in-house, costs of around €60/sample (incl. costs for personnel and consumables) 
are possible. If using commercial labs, costs are around €60-200 euros per sample. Standard 
Operating Procedures (SOPs) for this type of in vitro EBMs are available and three assays are 
even  ISO  standardised.  Standardisation  has  already  driven  down  costs,  but  future  further 
validation  and  inter-laboratory  studies  for  other  bioassays,  used  to  evaluate  effects  from 
estrogenic  compounds,  would  provide  a  wider  choice  of  methods  and  result  in  a  further 
decrease  of  costs  in  the  coming  years.  EBM  related  costs  can  also  be  reduced  by  reusing 
outcomes  of  FP7  funded  research  projects  like  ‘Solutions’.  Solutions  already  developed 
chemical,  effect‐based  and  ecological  tools  for  monitoring  and  assessing  the  presence  and 
effects of mixtures including contaminants of emerging concern (92). 

Sub-option (b): Establish an obligatory Groundwater Watch List mechanism analogous 
to that for surface waters and drinking water, and provide guidance as necessary on the 
monitoring of the listed substances. 

Impacts  of  this  sub-option  are  comparable  to  those  of  the  existing  SW  WL  and  consist  of 
annual sampling and analysing, by MS, of a limited number of substances. The information 
gathered would be collected and analysed at EU level, at an approximate annual cost below 
€1  million.  The  administrative  cost  at  MS  level  are  comparable  to  those  of  the  EQSD  (see 
option  1  sub-option  d),  i.e.  between  €30,000  and  €100,000  per  MS  per  year.  The  benefit, 
compared  to  the  existing  voluntary  watch  list,  is  in  achieving  a  much-improved  data  set, 
allowing more targeted and effective policy interventions at both EU and national level. 

Sub-option (c): Improve the monitoring and review cycle of the Surface Water Watch 
List so that there is more time to process the data before revising the list. 

increased  frequency  of 
The  sub-option  would  require,  for  some  substances,  an 
sampling/analysis for monitoring, which would however be compensated by an extension of 

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the watch list review cycle from 2 to 3  years. Therefore, it is  expected that the cost impact 
will  be  neutral.  The  major  benefit  is  in  capturing  substances  that  have  strong  seasonal 
fluctuations, rendering the watch list results more accurate. 

6.4.3  6.4.3  Policy option 3 – Reporting and classification 

Sub-option (a): Establish an automated data delivery mechanism for the EQSD and the 
WFD. 

Currently,  the  minimum  frequency  of  monitoring  of  priority  substances  in  surface  water  is 
once per month. However, the aggregated data are only reported every six years. The benefits 
of sub-option 3a are in  obtaining more frequent  accessibility of monitoring and status  data, 
allowing to show to the public and policy makers at EU and MS level intermediate progress. 
It  is  expected  that  this  will  require  a  significant  administrative  effort  both  at  EU  and  MS 
level. On the EEA side, the costs of facilitating an increased "digitalisation" to accommodate 
this option will require additional staff at EEA plus EUR 50-100K / year for IT consultancy 
and  hardware.  Preparedness  for  an  automated  data  delivery  mechanism  varies  across  MS 
authorities. While MS maintain their own data sources, data is not usually aligned in terms of 
spatial  coverage  and  temporal  trends  and  thus  requires  harmonisation.  Also,  the  system  of 
‘pass /fail’ does not provide much insight in the magnitude of exceedances and thus hampers 
focusing policy responses on pollution hotspots. If concentration data would be reported, this 
would  yield  valuable  information  to  investigate  the  nexus  between  better  water  quality  and 
improved  human  health  by  using  data  from  the  water  quality  monitoring  and  evaluation. 
Expected  efforts  needed  to  streamline  reporting  will,  in  the  long-term,  be  compensated  by 
reduced administrative burdens, with costs also likely to reduce in the medium to long term. 
In addition,  through digitalisation and automated data reporting, MS data and metadata can 
be  more  easily  and  more  frequently  accessed  and  compared,  and  made  available  via  an 
online, centralised platform, making them more transparent and up to date. This intervention 
is coherent with the Zero Pollution Monitoring and Outlook as it improves the basis for better 
Water  Pollution  Outlooks  reports  and  introduces  co-benefits  for  the  ‘1-substance-1-
assessment’ work by ECHA. 

The  harmonised  digital  automated  data  delivery  will  simplify  reporting  on  inventory  of 
emissions and increase links with the revised  Industrial  Emissions Portal.  This  is beneficial 
for the obligation for MS, according to Article 5 of the EQSD, to  establish an inventory of 
emissions,  discharges  and  losses  of  all  PS  and  pollutants  listed  in  Part  A  of  Annex  I  the 
Directive.  This  is  also  coherent  with  the  recent  Commission  proposal  establishing  an 
Industrial  Emissions  Portal  (93),  as  it  can  improve  the  exchange  of  data  between  the  EU 
European Pollutant Release and Transfer Register (E-PRTR) and the inventories of industrial 
emissions. This will enhance the implementation and policy making (including at EU level) 
through more transparent and real time data enabling focussed decision making and effective 
control. This would also be beneficial for an increased compliance by MS with the provisions 
of the EU  INSPIRE, and Access  to  Environmental  Information Directives.  It  also  increases 
coherence with the proposed EU Data Act (94). Whilst there may be an initial administrative 
burden resulting from the instalment of interoperable data sets which can be accessed by the 
EC  and  the  relevant  EU  Agencies,  considerable  gains,  including  a  reduced  administrative 
burden for MS, are expected in the medium and long run. 

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Sub-option  (b):  Introduce  a  reference  list  (repository  of  standards)  of  environmental 
quality standards (EQS) for RBSPs as an annex to the EQSD, and incorporate RBSPs 
into the assessment of chemical status for surface waters. 

Creating a repository assists MS in deriving national EQS, in turn allowing EU standards to 
be developed and included in the repository following adoption by comitology. This aligns to 
a  proposal  under  the  Chemicals  Strategy,  which  envisages  the  development  of  a  wider 
repository of all EU standards for chemical substances. EQS data could feed directly into that 
work. A harmonised repository would lower the overall administrative burden. 

A common repository of standards would secure that knowledge stays accessible to MS and 
stakeholders.  According  to  EEA  data,  MS  have  reported  around  150  RBSPs  under  the  2nd 
RBMPs. This data would be transferred to the EEA / JRC in a one-off migration to the newly 
created  EU  repository.  This  facilitates  quality  assurance  and  measures  for  RBSPs  at  River 
Basin  Districts  (RBDs)  level.  One-off  costs  for  developing  a  repository  of  standards  are 
comparable  to  those  for  developing  guidance  (€290,000  to  €500,000).  For  hosting  and 
maintenance 0.5 FTE plus EUR 10-20K / year for IT consultancy/hardware are required. 

The second part of this option aims at ensuring that, when assessing the chemical status, the 
results of the RBSPs assessment are included in the assessment of the overall chemical status 
of a SWB (currently the results are assessed as part of the ecological status assessment). This 
will improve the consistency within the WFD. This is a relatively significant change for MS 
and  stakeholders  and  would  result  in  a  one-off  alignment  of  reporting  systems.  Benefits 
would  consist  of  removing  the  bias  in  the  status  of  a  SWB  since  it  would  be  based  on 
harmonised EQSD for RBSPs as currently some MS might have implemented too strict or too 
lax  standards  for  their  RBSPs.  Another  expected  side-effect  is  that  the  number  of  WBs  in 
good  ecological  status  would  increase,  since  possible  exceedances  due  to  RSBPs  have  less 
effects on achieving good chemical status as they are generally in worse status. 

6.4.4  6.4.4  Policy option 4 – Legislative and administrative aspects 

Sub-option (a): Use an annex in the EQSD instead of Annex X to the WFD to define the 
list of PS, and update the lists of SW and GW substances by Comitology or delegated 
acts. 

This option would allow for a significant acceleration of the time required to update the lists 
of substances under the EQSD and the GWD. The main impact in administrative terms is on 
EU  Institutions,  which  would  be  called  to  act  via  delegated  acts  rather  than  through  the 
ordinary  legislative  procedure.  In  environmental  and  public  health  terms,  it  will  allow  a 
swifter  policy  reaction  to  emerging  pollutants,  and  a  faster  delisting  if  pollutants  are  no 
longer a threat, in line with the latest scientific progress and knowledge. Administrative costs 
will be lower at EU level while at Member State level no significant impact is expected. 

Sub-option  (b):  Change  the  status  of  the  ‘eight  other  pollutants’  added  to  the  EQSD 
from the former Dangerous Substances Directive (76/464/EEC) to that of PS/PHS. 

The  eight  pollutants  concerned  (pesticides  Aldrin,  Dieldrin,  Endrin,  Isodrin,  DDT,  and 
industrial chemicals Tetrachloroethylene, Trichloroethylene, Carbon tetrachloride) are listed 
in Annex I of the EQSD and have EQSs derived, but it is stated in footnote 7 of the Annex 
that these substances are not  Priority Substances. This  creates confusion  with  WFD  Article 

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16.7. Their existing EQS monitoring feeds into surface water chemical status assessment. The 
results  of  the  assessment  show  that  seven  out  of  eight  substances  either  a)  are  covered  by 
Regulation (EU) 2019/1021 on persistent organic pollutants (the POPs Regulation) obliging 
MS  to  put  into  place  and  maintain  inventories  for  such  substances;  b)  show  EQS  value 
exceedances  in  freshwater  (no  declining  emission  trends);  or  c)  are  covered  by  the  DWD. 
Therefore, these substances should be recognised as PS to avoid incoherencies with other EU 
legislation. Specifically, this concerns the cyclodiene pesticides (Aldrin, Dieldrin, Endrin and 
Isodrin),  DDT,  Tetrachloroethylene  and  Trichloroethylene.  Marking  them  as  PS  will  create 
greater  policy  coherence,  help  track  their  presence  in  water  and  inform  subsequent  risk 
assessments. Formally assigning them PS status is merely administrative and entails no costs. 

Furthermore, it is not clear why some of these substances have not been designated as PHS67 
under  Annex  II  of  the  EQSD.  Aldrin,  Dieldrin,  Endrin,  Isodrin,  DDT  are  POPs  and 
Trichloroethylene is SVHC, hence fulfilling the criteria for PHS status.  The result of that is 
that  most  of  them  (all  except  of  carbon  tetrachloride)  are  Persistent  Organic  Pollutants 
(POPs)  or  should  be  marked  as  priority  hazardous  substances  for  other  legislative  or 
toxicological reasons. 

Consequently,  with  the  exception  of  carbon  tetrachloride  which  is  proposed  for  deselection 
(see SW option 4), all substances should be formally recognised as PS under EQSD Annex I 
and some also as PHS under Annex II. Assigning PS/PHS status is merely an administrative 
change  without  further  negative  impacts,  but  formalisation  is  preferred  to  continue  their 
monitoring. 

Sub-option (c): Change the status of some existing PS to that of PHS where it fulfils the 
criteria of the POP Regulation and/or Article 57 of REACH Regulation. 

Since the last EQSD revision in 2013, five existing priority substances have been identified 
as PHS: 

  1,2-Dichloroethane is classed as SVHC under Article 57 of REACH Regulation.  
  Fluoranthene  PBT  vPvB  and  is  classed  as  SVHC  under  Article  57  of  REACH 

Regulation 

  Lead is classed as SVHC under Article 57 of REACH Regulation 
  Octylphenol  ethoxylates  (OPEs)  are  toxic  to  aquatic  organisms  even  at  low 
concentrations  and  show  edocrine  disrupting  properties.  They  break  down  easily  to 
octylphenols which are more harmful, not readily biodegradable and meet the criteria 
for  persistence  or  high  persistence  in  the  environment.  Consequently,  OPEs  are 
considered  as  SVHC requiring  authorisation  for specific use in  the EU according to 
Annex XIV of the REACH Regulation.  

  Pentachlorophenol (PCP) is covered by the POPs Regulation. 

67 PHS are a subset of PS that are identified as “toxic, persistent and liable to bio-accumulate, and other substances or groups of substances 
which give rise to an equivalent level of concern” (WFD article 2(29)). Substances identified by the following processes and legislations are 
relevant: Substances of Very High Concern (SVHC) under REACH, Persistent Organic Pollutants (POPs) under the Stockholm Convention 
and substances identified as Persistent, Bio-accumulative and Toxic (PBTs) under Regulation (EEC) No.793/93. 

EN 

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6.5  6.5 

Administrative burden  

As indicated in Chapter 6.4 the approximate annual administrative burden related to reporting 
ranges  from  €30,000  to  €100,000  per  MS.  The  impact  assessment  estimated  the  additional 
monitoring costs as €15-36 million per year for the whole EU. Costs of €2-4 million per year 
for the EU were estimated for a database and the costs to develop technical specifications for 
monitoring  were  estimated  at  <€0.2  million  per  year  for  the  whole  EU  (10).  However,  the 
Fitness Check on the EU environmental reporting and monitoring acquis also concluded that 
the  benefits  of  reporting  obligations  significantly  exceed  the  costs,  as  without  reporting 
obligations  the  Commission  cannot  verify  a  correct  implementation.  This  is  even  more 
pertinent in light of the revamped impulse provided by the European Green Deal and the co-
legislators’  agreement  to  put  in  place  an  encompassing  Environmental  Monitoring 
Framework  under  the  8th  Environmental  Action  Programme  (95).  In  particular,  the  outputs 
from  this  policy  intervention  would  feed  into  the  Zero  Pollution  Monitoring  and  Outlook 
Framework announced by the ZPAP. 

The  costs  related  to  putting  in  place  an  obligatory  monitoring  method  for  microplastics  are 
calculated to range from €7,298,800 to €13,362,700. 

The  administrative  burden  associated  to  the  groundwater  options  is  limited.  For  nrMs  and 
pharmaceuticals, these range between €2 and 11 million depending on the level of ambition, 
with no significant additional administrative costs for risk /status assessments of substances. 
For PFAS the EU costs are higher, and estimated between €15 and 48 million, depending on 
the  level  of  ambition,  with  no  significant  additional  administrative  costs  for  risk  /status 
assessments of substances. All options benefit from the focus on PFAS in the recast DWD, 
triggering more attention for monitoring relevant substances in source water. 

In the implementation of the WFD, EQSD and GWD, the Commission intends to concentrate 
all  work  related  to  the  identification  and  prioritisation  of  pollutants,  including  their  risk 
assessment, for inclusion in future revisions of the legislation and in the watchlists for surface 
water and groundwater, at ECHA. This will require reinforcement of the staff table of ECHA, 
though  it  should  be  noted  that  at  the  same  time  there  will  be  some  reductions  in 
administrative expenses in the Commission. 

6.6  6.6 

Note on impacts for individual MS  

The  differences  in  impacts  across  MS  will  vary  depending  on  national  measures  already  in 
place  and/or  newly  proposed  and  the  extent  of  pressure-exerting  activities  (agriculture, 
industry). For pharmaceuticals, for example, many MS already have compulsory or voluntary 
return  programmes  in  place  (Belgium,  Czech  Republic,  Denmark,  France  Greece,  Italy, 
Netherlands,  Spain,  Sweden),  and/or  launched  environmental  classification  schemes  for 
pharmaceuticals  (Finland)  and/or  started  other  Green  Pharmacy  initiatives  (Finland, 
Netherlands, Portugal, Sweden) and/or participate in EU funded projects in this area (the EU 
#Medsdisposal  campaign68  and  the  EU  project  "Priorisation  and  Risk  Evaluation  of 
Medicines  in  the  Environment"69).  The  best  practice  paper  on  Green  and  Sustainable 

68 EU Medsdisposal: is a pan-European interdisciplinary stakeholder collaboration campaign to raise awareness on the appropriate disposal 
of expired or unused medicines in Europe and includes associations representing European healthcare, industry and student organisations: 
http://medsdisposal.eu/ 
69 https://cordis.europa.eu/project/id/875508 

EN 

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Pharmacy  in  Europe70  lists  these  as  examples.  In  the  abovementioned  MS  the  potential 
impacts of proposed quality standards for pharmaceuticals will likely be less, than in MS who 
have not taken these (or other equivalent) measures.  

The impacts also vary depending on the distance to target. As explained in section  6.1.1, it 
was  not  possible  to  conduct  this  assessment  for  each  Member  State,  hence  the  distance  to 
target indicates the situation at EU level. However, it can be considered that in MS and river 
basin  districts  where  the  water  already  (mostly)  meets  the  proposed  standards,  the  impacts 
will be less than in MS and river basin districts where the distance to target is still (relatively) 
large. Generally, areas of intensive agriculture and pesticide use (DE, FR, ES and IT account 
for  2/3  of  sales  of  pesticides  in  the  EU),  those  where  domestic  wastewater  is  not  centrally 
collected and therefore less connected to treatment networks (e.g. areas with low population 
densities),  as  well  as  areas  where  the  legislation  on  UWWT  is  not  complied  with  (e.g.  BG 
and RO and parts of IT, ES, PT), and water bodies with a limited flow (i.e. less dissolution of 
pollutants) would see the highest impact. 

In summary, the EU water legislation does not specify exact measures to be taken to reach a 
given water quality standard, meaning that the respective efforts required by MS are largely 
dependent on the current status of pollution and individual choices (beyond what is required 
under EU legislation) of MS to address the situation with country specific measures. 

7 

7  HOW DO THE OPTIONS COMPARE AND WHAT ARE THE PREFERRED OPTIONS?  

The comparison, where relevant, and evaluation of proposed surface and groundwater policy 
options is structured around the pollutants being assessed, i.e. the following: 

  Pollutants considered for addition to the Priority Substance list (surface water options 

1 and 2); 

  Pollutants considered for existing EQS amendment (surface water option 3); 
  Pollutants  considered  for  deselection  from  the  Priority  Substance  list  (surface  water 

option 4); 

  Pollutants considered for addition to the GWD Annexes I and II (groundwater options 

1, 2 and 3); 

The evaluation of proposed monitoring, reporting and administrative streamlining options is 
structured around the policy elements being assessed, i.e. the following: 

  Policy elements addressing monitoring guidelines;  
  Policy elements addressing obligatory monitoring practices; 
  Policy elements addressing reporting and classification;  
  Policy elements addressing legislative and administrative aspects. 

The  assessment  is  presented  below,  with  tables  summarising  the  overall  magnitude  of 
impacts (considering the economic, environmental, and societal costs and benefits set out in 
Chapter 6, Annexes 3 and 9). 

In addition, the efficiency, effectiveness and coherence of each of the policy options has been 
assessed and the results are summarised in throughout the tables in this section. 

70 https://www.pgeu.eu/wp-content/uploads/2019/11/PGEU-Best-Practice-Paper-on-Green-and-Sustainable-Pharmacy-in-Europe.pdf 

EN 

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Quantitative  and  qualitative  factors  were  considered  in  assigning  the  rankings  for  each 
criterion.  The  scale  outlined  below  shows  how  "+"  and  "-"  are  attributed  to  positive  and 
negative impact expectations.  

Very 
large 
negative  
impact 
---- 

Large  
negative  
impact 

Medium 
negative  
impact 

Small 
negative  
impact 

Balanced 
impact 

Small 
positive  
impact 

Medium 
positive  
impact 

Large  
positive  
impact 

--- 

-- 

- 

+/- 

+ 

++ 

+++ 

Very  
large  
positive  
impact 
++++ 

The multi-criteria evaluation made of impacts, effectiveness, efficiency and coherence of the 
policy options provides support for the preferred policy package. 

7.1  7.1 

Surface water 

The substances in the surface water options were grouped into three different categories. A 
first  category  in  which  the  benefits  of  adding  candidate  substances  to  the  PS  list  clearly 
outweigh  the  costs  (with  a  sub-category  for  micro  and  nanoplastics).  A  second  category 
where  the  costs  and  benefits  are  more  balanced  (in  these  cases  a  clear  set  of  benefits  have 
been  identified,  meaning  that  adding  them  is  worthwhile,  but  there  is  a  closer  balance 
between the costs and benefits). For the third category, the costs outweigh the benefits. 

7.1.1  7.1.1  Pollutants considered for addition to the PS list  

The  individual  (SW  option  1)  and  group  (SW  option  2)  additions  of  candidate  priority 
substances  were  compared,  where  possible,  and  the  preferred  option  selected  for  relevant 
substances. More detailed information about the comparison of environmental, economic and 
social impacts of these options can be found in Annex 9.  

Benefits clearly outweigh the costs for: industrial chemicals - PFAS (all 24 named substances 
plus the total of all PFAS) (96); pesticides (Glyphosate, Triclosan); neonicotinoid pesticides 
pesticides 
(Acetamiprid, 
(Deltamethrin,  Permethrin,  Bifenthrin,  Esfenvalerate);  pharmaceuticals  (Carbamazepine, 
Diclofenac); macrolide antibiotics (Azithromycin, Clarithromycin; Erythromycin); estrogenic 
hormones (17-Alpha-Ethinyl estradiol (EE2), 17-Beta estradiol (E2), Estrone (E1)). 

Imidacloprid,  Thiacloprid,  Thiamethoxam); 

pyrethroid 

As detailed in Annex 9, benefits largely relate to avoided healthcare costs stemming from an 
expected reduced exposure to harmful substances  – to be noted this is exposure through all 
environmental  media,  not  only  groundwater  or  surface  water.  Specifically,  for  PFAS,  the 
avoided health costs thanks to reduced exposure (via consumer products, background levels)  
a  result  of  all  EU  and  Member  States  policies  addressing  PFAS  –  therefore  not  only  those 
linked  to  this  initiative  –  are  estimated  at  €52-84  billion/year.  According  to  the  Centre  for 
Disease  Control  and  Prevention  (CDC),  antimicrobial  resistance  adds  a  20-billion-dollar 
surplus in direct healthcare costs in the United States, which is exclusive of about 35 billion 
dollars in  loss of productivity annually. Numbers for the EU are comparable.  The threat  of 
antimicrobial resistance is of particular importance in the category of antibiotic resistance in 

EN 

  EN 

 
 
 
bacteria.  The  European  Union  has  an  annual  mortality  rate  of  27,000  attributable  to  AMR. 
This  is  comparable  to  the  United  States  where  2  million  people  are  affected  every  year  by 
AMR  and  about  23,000  die  as  a  result71.  Worldwide,  700.000  people  die  annually  from 
resistant  infections  and  this  means  that  if  no  action  is  taken,  the  estimated  annual  deaths 
attributable to AMR will be 10 million by 2050 (a 14-fold increase). Water can be a reservoir 
of  bacteria  resistant  to  pharmaceuticals  due  to  the  presence  of  pharmaceuticals  as  pressure, 
and/or  bacteria  that  are  co-resistant  to  both  antibiotics  and  silver  (bacteria  share  the  same 
mechanism of the resistance). OECD analyses from 2018 found that investing just EUR 1.5 
per capita per year in a policy package to tackle AMR is effective and cost-saving, avoiding 
27 000 deaths and saving around EUR 1.5 billion each year in EU/EEA countries72. Without 
action AMR related costs will likely also increase 14-fold by 2050 which could then result in 
annual AMR related costs of around 21 billion by 2050. The EU benefits from an enhanced 
protection against the development of AMR is estimated at around €1.5 billion/year based on 
healthcare  costs  and  productivity  losses  (relevant  e.g.  for  the  substances  Azithromycin; 
Clarithromycin;  Erythromycin).  The  annual  benefits  from  a  reduced  exposure  to  endocrine 
disruptors  are  estimated  at  €163  billion.  This  is  due  to  the  fact  that  endocrine  disruptors  in 
Europe  contribute  substantially  to  neurobehavioral  deficits  and  diseases,  as  well  as  to 
childhood obesity, costing costs €1.54 billion annually. 

Avoided/reduced 
impacts  on  pollinators  and  agriculture  (Acetamiprid,  Clothianidin, 
Imidacloprid,  Thiacloprid,  Thiamethoxam,  Bifenthrin,  Deltamethrin  Esfenvalerate, 
Permethrin)  account  for  approximately  €14.6  billion  annually.  Costs  for  packages  of 
measures such as source control, pathway disruption and end-of-pipe are significant, but they 
tend  to  be  lower  after  initial  investment  or  one-off  costs,  while  health  and  environmental 
benefits  are  recurring.  Examples  of  costs  are  pathway  disruption  for  glyphosate  (buffer 
strips),  estimated  at  around  €285  million.  Additional  controls  and  treatment  for  farmed 
animal use of deltamethrin could cost around €185 million. 

The  following  substances  have  “balanced”  impacts:  Ibuprofen,  Nicosulfuron,  Clothianidin, 
Bisphenol A, and Silver and are suggested for inclusion. 

For silver, costs of listing are expected to be high but comparable to the benefits. This is in 
particular  related  to  its  role  in  avoiding  antimicrobial  resistance  of  bacteria  (see  also 
pharmaceuticals  sections  related  to  AMR).  Water  can  be  a  reservoir  of  bacteria  resistant  to 
the silver due to the presence of silver as pressure, and/or bacteria that are co-resistant to both 
antibiotics and silver (bacteria share the same mechanism of the resistance). Since silver has 
antimicrobial  effects  comparable  to  pharmaceuticals  similar  costs  are  assumed  to  occur  for 
silver73 (around €1.5 billion/year based on healthcare costs and productivity losses). Similar 
to  pharmaceuticals,  without action AMR  related  costs will likely  increase also  increase 14-
fold by 2050, resulting in annual AMR related costs of around 21 billion by 2050. Therefore, 
this substance is also suggested for inclusion on the PS list.  

71 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6929930/ 

72 https://www.oecd.org/health/Antimicrobial-Resistance-in-the-EU-EEA-A-One-Health-Response-March-2022.pdf 

73  State 
https://publications.jrc.ec.europa.eu/repository/handle/JRC114775 

contribution 

of  water 

the 

the 

art 

on 

of 

to 

antimicrobial 

resistance:  Sanseverino 

eta 

al., 

2018, 

EN 

  EN 

 
 
                                                           
These benefits and costs apply do not arise exclusively from this initiative, but would be the 
result of joint EU and Member State action, based on all policy instruments that address these 
pesticides and antimicrobials. 

Table 7.1.1: Pollutants considered for addition to the Priority Substance list – preferred 
option 

Substances  

Policy option 

Estrogenic 
hormones 
17-alpha-ethinyl-
estradiol  (EE2),  17–
(E2), 
beta-estradiol 
estrone (E1) 

Macrolide 
antibiotics 
Azithromycin, 
Clarithromycin, 
Erythromycin 

Policy  Option 
1 
(individual 
addition) 

Policy  Option 
2 
(group 
addition) 

Policy  Option 
1 
(individual 
addition) 

Policy  Option 
2 
(group 
addition) 

Carba-
mazepine 

Policy  Option 
1 
(individual 
addition) 

+
+
+ 

+
+
+ 

+
+ 

+
+ 

+
+
+ 

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

s
t
c
a
p
m

i

l
a
i
c
o
S

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

e
c
n
e
r
e
h
o
C

Justification 

Pref
erre
d 
opti
on 

Yes 

+/
- 

+/
- 

- 

- 

+
+ 

++
+ 

+ 

Estrogenic  impacts  on  environment  are  of 
EU-wide  concern.  Pharmaceutical  strategy 
covers  this  in  part  but  no  other  regulatory 
drivers.  Listing  in  the  EQSD  would  be  an 
effective  and  efficient  means  to address  the 
issue and place onus on source control. 

+
+ 

++
++ 

-- 

The  potency,  pathway  to  environment,  and 
treatment  options  vary  significantly  across 
the  three  substances.  A  group  listing  would 
likely have negative effects for coherence.  

No 

- 

-- 

+
+
+ 

++
+ 

++ 

- 

-- 

+
+ 

++
+ 

++ 

+/
- 

+/
- 

+
+
+ 

+
+
+ 

++
+ 

+ 

++
+ 

+ 

over 

control 

concerns 

strategy  highlights 
The  pharmaceutical 
anti-microbial 
strong 
largely 
resistance  (AMR).  The  strategy 
source. 
address  use 
at 
and 
Environmental  monitoring 
is  a  weaker 
element.  Addition  to  the  EQSD  would 
address this issue and therefore has positive 
elements  for  effectiveness,  efficiency,  and 
coherence. Alternatives exist but can assume 
negative  impacts  for  society  from  more 
limited access and use 
The  potency,  and  treatment  options  vary 
significantly  across  the  three  substances.  A 
group 
likely  mean 
treatment  and  reduced 
compromise  on 
effectiveness. 
Distance  to  target  is  large,  with  the  EQS 
dossier highlighting EU-wide concerns. This 
suggests a large positive impact from listing. 
Alternatives  do  exist  (although  many  are 
more  expensive),  suggesting  control  of 
releases  through  limitations  on  use  should 
be  cost  neutral.  Environmental  monitoring 
likely  key  to  help  manage  and  control  the 
for 
issues.  Suggests 
effectiveness and efficiency. 

strong  positives 

listing  would 

is 

Targeted  consultation  suggests  that  this 
substance 
the  highest  environmental 
concern  of  all  candidate  pharmaceuticals. 
Strong  environmental  benefits  of  listing. 
Alternatives  exist  and  treatment  options 
look  reasonable.  Similar  to  carbamazepine 
environmental  monitoring  needed  to  help 
track  and  control  the  issue.  Strong  benefits 
for  effectiveness  and  efficiency  of  listing 
under the EQSD. 

Yes 

No 

Yes 

Yes 

Diclofenac 

Policy  Option 
1 
(individual 
addition) 

+
+
+ 

+ 

+/
- 

l
a
c
i
t
u
e
c
a
m
r
a
h
p

r
e
h
t
O

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Substances  

Policy option 

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

s
t
c
a
p
m

i

l
a
i
c
o
S

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

e
c
n
e
r
e
h
o
C

Justification 

Ibuprofen 

Policy  Option 
1 
(individual 
addition) 

+ 

+/
- 

- 

+
+
+ 

++
+ 

+ 

Distance to target is set at medium, with the 
environmental benefits of listing suggesting 
a  small  positive  benefit.  Other  alternatives 
are available on the market suggesting costs 
could be neutral. The bigger concern is that 
use  is  increasing  suggesting  environmental 
concentrations  may  also  increase.  A  listing 
could be an effective and efficient means of 
tracking 
and 
controlling 
environmental concentrations.   

release 

and 

Neonicotinoid 
pesticides 
Acetamiprid, 
Clothianidin, 
Imidacloprid, 
Thiacloprid, 
Thiamethoxam 

Pyrethroid 
pesticides 
Bifenthrin, 
Deltamethrin, 
Esfenvalerate, 
Permethrin 

  Glyphosate 

Policy  Option 
1 
(individual 
addition) 

Policy  Option 
2 
(group 
addition) 

+
+ 

- 

+/
- 

+
+ 

++
+ 

++
++ 

+
+ 

- 

+/
- 

+ 

++ 

++ 

Policy  Option 
1 
(individual 
addition) 

+
+
+
+ 

-- 

- 

+
+
+ 

++
+ 

++
+ 

Policy  Option 
2 
(group 
addition) 

+
+
+
+ 

-- 

- 

+ 

+ 

++ 

Policy  Option 
1 
(individual 
addition) 

+
+
+ 

- 

+/
- 

+
+ 

++ 

+/- 

Primary  concern  for  neonicotinoids  relates 
to pollinators. However, impacts on aquatic 
is  a 
species,  particularly  crustaceans 
concern.  Wider  protection  of  the  aquatic 
environment  would  be  beneficial.  Actions 
have  already  been 
taken  under  other 
legislation,  meaning  strong  positives  for 
coherence,  particularly  the  farm  to  fork 
strategy.  Where  other  activities  are  already 
underway 
is 
pollinators, expect the effectiveness to have 
medium benefits. 

concern 

primary 

and 

The  regulatory  status  of  the  individual 
neonicotinoids  varies.  This  means  a  group 
listing  would  mask  some  of  the  granular 
data  and  reduce  both  effectiveness  and 
coherence. 

Distance  to  target  was  large  with  the  EQS 
dossier predicting widespread failures due to 
the highly toxic nature of the substances for 
aquatic  environment.  Expect  very  large 
positive  benefits  for  environment.  Limited 
options  for  alternatives  and  high  costs  for 
suggesting  medium 
WWTW  expected 
negative  economic  costs.  Some  of 
the 
substances  are  already  no  longer  approved 
for  plant  protection  products,  while  there 
would be positive coherence outcomes with 
the farm to fork strategy. 

The regulatory status of the four substances 
varies,  as  does  the  treatment  options  at 
WWTWs.  Suggests  a  group  listing  would 
impact  effective  management,  efficiency, 
and coherence negatively. 

Distance  to  target  is  large,  noting  that  this 
substance  is  one  of  the  highest  volume 
pesticide  actives 
in  Europe.  The  EQS 
threshold is based on risks to drinking water 
and  humans  given  how  widely  it  is  used. 
Expect  strong  environmental  benefits.  The 
effectiveness  and  efficiency  of 
listing 
predicts  medium  benefits  on  the  grounds 
that  better  monitoring  data  could  help 
characterise  the  issues  more  fully,  but  no 
specific coherence benefits identified. 

Pref
erre
d 
opti
on 

Yes 

Yes 

No 

Yes 

No 

Yes 

s
e
d
i
c
i
t
s
e
p
r
e
h
t
O

EN 

Nicosulfor

Policy  Option  + 

+/

+/

+

++ 

+ 

Distance to target is small, primary concern  Yes 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E
- 

s
t
c
a
p
m

i

l
a
i
c
o
S
- 

s
s
e
n
e
v
i
t
c
e
f
f

E
+ 

Substances  

Policy option 

on 

1 
(individual 
addition) 

Justification 

y
c
n
e
i
c
i
f
f

E

e
c
n
e
r
e
h
o
C

Triclosan 

Policy  Option 
1 
(individual 
addition) 

+
+ 

+/
- 

+/
- 

+
+
+ 

++
+ 

++
+ 

PFAS 

Policy  Option 
1 
(individual 
addition) 

+
+
+
+ 

--
- 

-- 

- 

--- 

-- 

Policy  Option 
2 
(group 
addition) 

+
+
+
+ 

--
- 

-- 

+
+ 

++
+ 

+/- 

Bisphenol A 

Policy  Option 
1 
(individual 
addition) 

+
+
+ 

+/
- 

+/
- 

+
+
+ 

++
+ 

++
+ 

from 

listing. 

could  be  application  by  boom-sprayers  and 
spray  drift.  Assume  small  benefits 
to 
environment 
Improved 
monitoring  data  could  help  identify  control 
options.  Assume  medium  benefits 
for 
effectiveness  and  efficiency,  and  small 
benefits  for  coherence  with  farm  to  fork 
strategy. 

Remaining  use  of  triclosan  is  very  limited, 
however,  environmental  persistence  and 
impacts  are  a  concern.  Suggesting  medium 
benefits  for  environment  to  better  control 
the issues. The issues posed largely relate to 
existing  environmental  impacts,  suggesting 
a  listing  in  the  EQSD  could  be  appropriate 
and  effective.  Also  adds  coherence  to  the 
wider legislative landscape that has aimed to 
phase-out use. 

Approximately  6,000  PFAS  substances 
exist.  A  total  of  24  were  identified  as 
potential  markers.  In  this  case  approaching 
them  individually  may  be  labour  intensive 
and  counter  intuitive.  Including  negative 
coherence impacts for how these substances 
have  been  managed  under  the    drinking 
water directive. 

Distance  to  target  is  large,  with  significant 
environmental  concerns,  suggesting  strong 
environmental  benefits  for  listing.  Control 
and  treatment  options  for  WWTWs  likely 
very  costly,  suggesting  strong  negative 
economic  impacts.  However,  given  that 
PFAS 
aquatic 
environment  a  group  listing  in  the  EQSD 
could be effective and a more efficient way 
to manage the issue than individual listings. 

impacts 

largely 

the 

to 

target 

Distance 
large,  suggesting 
is 
strongly  positive  benefits  for  environment 
with  an  EQSD  listing.  Within  the  wider 
legislative  network  controls  are  already  in 
place under REACH and IED, but the issue 
may relate to in-use stocks. A  listing in the 
EQSD  would 
therefore  have  coherence 
benefits,  and  likely  reflect  strong  positive 
aspects  for  effectiveness  and  efficiency  in 
terms  of  tracking  and  controlling  releases 
and  concentrations  within 
the  aquatic 
environment. 

Pref
erre
d 
opti
on 

Yes 

No 

Yes 

Yes 

No 

Silver 

Policy  Option 
1 
(individual 
addition) 

+ 

- 

-- 

+
+ 

+/- 

+/- 

Distance  to  target  was  small,  suggesting 
small  environmental  benefits.  The  diffuse 
nature  of  use  and  pathway  to  environment 
could pose challenges for control, while loss 
of  some  uses  (e.g.,  biocidal)  could  have 
negative  impacts  for  society.  The  issue  is 
further  complicated  by  naturally  occurring 
silver,  and  the  form  of  silver  monitored  for 
EQS.  Questionable  about  how  efficient  a 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
Substances  

Policy option 

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

s
t
c
a
p
m

i

l
a
i
c
o
S

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

e
c
n
e
r
e
h
o
C

Justification 

Pref
erre
d 
opti
on 

listing  would  be  in  terms  of  addressing  the 
issues,  and  no  coherence  benefits  identified 
with other legislation. As assume efficiency 
and  coherence  are  neutral,  but  a  listing  in 
the  EQSD  would  at  least  address  some  of 
the  issues,  and  therefore  assume  medium 
benefits for effectiveness. 

As indicated in Chapter 6, there are various reasons to use grouping approaches when adding 
substances to the priority substance list.  

The  assessment  shows  that,  out  of  the  four  possible  groups  identified  under  this  option 
(noting that the addition of PFAS as a group has already been included as part of Option 1) 
only for the macrolide antibiotics benefits outweigh the costs. Adding these substances as a 
group  would  ensure  greater  coherence  in  the  approach  to  AMR.  Also,  correlations  in  use, 
pathways to environment and measures will result in significant cost savings if managed as a 
group.  If  grouped,  possible  measures  by  MS  would  likely  be  based  on  the  EQS  for 
Azithromycin as is expected to show the biggest distance to target. 

A  grouping  approach  is  not  recommended  for  estrogenic  hormones,  the  neonicotinoid  and 
pyrethroid pesticides. 

For PFAS, the use of a relative potency factor (RPF74) approach was considered for setting a 
group EQS but the scientific justification for that is still too uncertain to be introduced in the 
legislation. Consequently, a sum of all PFAS approach analogous to the DWD (see Annex 7 
for more information) seems a more appropriate way forward. 

7.1.2  7.1.2  Pollutants considered for existing EQS amendment  

The  assessment  resulted  in  two  categories  of  substances.  A  first  category  of  substances  for 
which  the  re-assessment  of  the  threshold  concluded  that  the  benefits  of  an  improved 
protection  outweigh  the  costs,  or  where  a  less  stringent  threshold  value  has  only  limited 
impacts. For those an amendment of the EQS is preferable. The second category consists of 
substances for which the review and reappraisal of EQS concluded that additional measures 
may be warranted. In this case costs are higher but considered proportionate to the risks. For 
this category amendment is still considered preferable. 

74 PFOA-equivalent relative potency factors are an indication of the relative toxicity of a PFAS substance compared to PFOA. 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Table 7.1.2: Pollutants considered for existing EQS amendment – preferred option 

Substances  

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

s
t
c
a
p
m

i

l
a
i
c
o
S

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

e
c
n
e
r
e
h
o
C

Justification 

Chlorpyrif
os  

+++ 

+/- 

+ 

Cypermet
hrin 

+++ 

-- 

+ 

Diuron 

+++ 

- 

+ 

Dicofol 

+/- 

+ 

Hexachlor
obenzene 

+/- 

+ 

s
e
d
i
c
i
t
s
e
P

Heptachlo
r 
/ 
Heptachlo
r epoxide 

+/- 

+ 

+/
- 

+/
- 

+/
- 

++
+ 

++
+ 

++
+ 

+/- 

- 

- 

Dioxins 

+ 

- 

+ 

+/- 

Fluoranth
ene 

Hexabrom
ocyclodod
ecane 

Hexachlor
obutadien
e 

+/- 

+ 

+/- 

+/- 

++ 

+/- 

Nonyl 
phenol 

+ 

+ 

+/
- 

+/
- 

+/
- 

+/
- 

+/- 

+/- 

+/- 

+/- 

PAHs 

++ 

- 

+ 

+/- 

PBDEs 

+ 

- 

+ 

+ 

s
l
a
c
i
m
e
h
c

l
a
i
r
t
s
u
d
n
I

+
+
+ 

+
+ 

+
+
+ 

+/
- 

+/
- 

+/
- 

+/
- 

+/
- 

+/
- 

+/
- 

+/
- 

+/
- 

+/
- 

++
+ 

+/- 

+ 

+/- 

+/- 

+/- 

++ 

+/- 

+/- 

+/- 

+/- 

++ 

+ 

Evolving  science  and  nomination  as  POP  under  the  Stockholm 
Convention  suggests  the  proposed  threshold  is  appropriate. 
Would confer strong environmental benefits, while further use of 
EQSD  to  support  other  legislation  (particularly  the  POPs 
Regulation),  would  suggest  strong  benefits  for  effectiveness, 
efficiency, and coherence. 
Proposed EQS thresholds are lower than existing ones, leading to 
strong  environmental  benefits.  No  specific  new  coherence 
benefits identified. 
Proposed EQS thresholds lower than the existing ones, leading to 
strong environmental benefits. Approval of diuron as a pesticide 
ended  in  September  2020,  so  small  coherence  benefits  from 
reducing the EQS threshold. 
Proposed threshold for dicofol higher than the existing one. Rates 
of  exceedance  are  already  low  so  little  impact  for  environment. 
Possibly small economic benefits for being able to use analytical 
equipment with higher LOD. 
Proposed  threshold  for  higher  than  the  existing  one.  Rates  of 
exceedance  already  low  so  little  impact  for  environment. 
Possibly small economic benefits for being able to use analytical 
equipment with higher LOD. 
Proposed  threshold  is  higher  than  the  existing  one.  Rates  of 
exceedance  already  low  so  little  impact  for  environment. 
Possibly small economic benefits for being able to use analytical 
equipment with higher LOD. 
Proposed  biota  threshold  is  more  strict.  Dioxins  are  already 
addressed  by  a 
(particularly  POPs 
Regulation). Stricter controls have coherence benefits with aims 
of  POPs  Regulation  and  provide  environmental  and  societal 
benefits (food-chain) from a reduced EQS. 
Proposed  threshold  is  higher  than  the  existing  one.  Rates  of 
exceedance  are  already 
impact  for 
environment. Possibly small economic benefits for being able to 
use analytical equipment with higher LOD. 
Amendment of EQS justified through latest evidence. In reality it 
will  not  have  a  material  impact  on  environmental  protections, 
economics, or society. 
Amendment  would 
lower  EQS.  This  would  provide 
environmental benefits. The current distance to target is small but 
could be expected to include a wider number of waterbodies with 
exceedances. Assume the benefits would be medium positive. 
Amendment  would 
lower  EQS.  This  would  provide 
environmental benefits. Current distance to target small but could 
be  expected  to  include  a  wider  number  of  waterbodies  with 
exceedances. Assume benefits will be medium positive. 
Amendment  would  lower  EQS.  Distance  to  target  already 
medium,  therefore  medium  positive  environmental  benefits. 
Given potential for PAHs to bioaccumulate better controls would 
have  societal  benefits  (food-chain).  Also  expect  small  negative 
economic benefits if more advance analysis is needed to achieve 
the LOD/LOQ. 
Amendment  would 
lower  EQS  for  biota  (via  secondary 
poisoning). Distance to target already large, with other legislation 
listing  proposals  to  also  reduce  critical  thresholds.  In  particular 
the low POP content for waste under the POPs Regulation. Small 

low  so  expect 

legislation 

range  of 

little 

Prefer
red 
option 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Substances  

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

Tributylti
n 

+ 

+/- 

Mercury 

+++ 

-- 

s
t
c
a
p
m

i

l
a
i
c
o
S

+/
- 

+
+ 

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

e
c
n
e
r
e
h
o
C

+ 

+/
- 

+/- 

+ 

+ 

+/- 

Nickel 

++ 

-- 

+/
- 

+ 

+/
- 

+/- 

s
l
a
t
e

M

Justification 

positive benefits for coherence, and societal (food-chain). 
Proposed  EQS  more  strict  than  the  existing  one.  Therefore 
positive  benefits  for  environment,  and  effectiveness  of  the 
EQSD. 
Amendment  would  add  an  annual  average  EQS  (currently  only 
MAC).  Distance  to  target  large,  and  greater  control  to  manage 
the  issues  needed.  Would  lead  to  strong  environmental  benefits 
because  it  provides  more  granularity.  Medium  benefits  for 
society 
improved  protections,  small  benefits  for 
effectiveness  and  efficiency,  because  annual  average  EQS 
threshold aligns mercury with other priority substances. 
Amendments  for  nickel  would 
thresholds.  Existing 
distance to target is medium, with potentially more water bodies 
failing  to  meet  good  chemical  status.  Medium  positive  benefits 
for  environment  expected,  and  small  benefits  for  improved 
effectiveness.  Negative  economic  impacts  for  greater  use  of 
controls and POMs. 

through 

lower 

Prefer
red 
option 

Yes 

Yes 

Yes 

For the following substances the benefits of an EQS amendment outweigh the costs: Dicofol; 
Diuron; Heptachlor/heptachlor epoxide; Hexachlorobenzene; Tributyltin; Dioxins and furans; 
Fluoranthene; Hexachlorobutadiene; Nonyl Phenol; PBDEs. 

For  the  substances  Chlorpyrifos;  Cypermethrin;  PAHs;  Mercury  and  Nickel  the  impact 
assessment  showed  that  the  overall  balance  of  costs  and  benefits  will  be  neutral.  This  is 
because  the  revised  EQS  is  significantly  more  stringent  and  thus  yields  benefits  from 
increased  protection  (currently  risks  are  underestimated  and  therefore  additional  effort  is 
warranted) but could also trigger a need for new measures to help achieve the new EQS.  

7.1.3  7.1.3  Pollutants considered for deselection from the Priority Substance list  

Under  this  option  two  different  categories  are  identified:  1)  deselection  would  have  more 
benefits than costs; 2) the costs and benefits are more balanced. 

Table 7.1.3: Pollutants considered for deselection from the PS list – preferred option 

Substances  

l
a
t
n
e
m
n
o
r
i
v
n
E
Pesticides  Alachlor  +/- 

s
t
c
a
p
m

i

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E
+ 

s
s
e
n
e
v
i
t
c
e
f
f
E

s
t
c
a
p
m

i

l
a
i
c
o
S
+  + 

Justification 

e
c
n
e
r
e
h
o
C

y
c
n
e
i
c
i
f
f
E
+  +/
- 

Fully  meets  deselection  criteria,  which  would  assume  no 
negative  impacts  for  the  environment  if  deselected.  Small 
positive benefits in cost savings, and for society, effectiveness, 
and  efficiency 
for  other 
substances). 

(redeployment  of 

resources 

Prefe
rred 
optio
n 

Yes 

Chlorfen

+/- 

+ 

+  + 

+  +/

Fully meets deselection criteria, so no negative impacts for the  Yes 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Substances  

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

s
t
c
a
p
m

i

l
a
i
c
o
S

s
s
e
n
e
v
i
t
c
e
f
f
E

vinphos 

Simazin
e 

+/- 

+ 

+  + 

Industria
l 
chemicals 

Carbon 
tetrachlo
ride 

+/- 

+ 

+  + 

+/- 

+ 

+  + 

Trichlor
obenzen
es 

y
c
n
e
i
c
i
f
f
E

e
c
n
e
r
e
h
o
C
- 

+  +/
- 

+  +/
- 

+  +/
- 

Justification 

environment  if  deselected.  Small  positive  benefits  in  cost 
savings,  as  well  as  for  society,  effectiveness,  and  efficiency 
(redeployment of resources for other substances). 

Fully meets deselection criteria, so no negative impacts for the 
environment  if  deselected.  Small  positive  benefits  in  cost 
savings,  as  well  as  for  society,  effectiveness,  and  efficiency 
(redeployment of resources for other substances). 

Fully meets deselection criteria, so no negative impacts for the 
environment  if  deselected.  Small  positive  benefits  in  cost 
savings,  as  well  as  for  society,  effectiveness,  and  efficiency 
(redeployment of resources for other substances). 

Largely meet deselection criteria but still in use. Based on very 
low  exceedance  rates  deselection  would  have  neutral  impacts 
for  the  environment.  Also  provide  benefits  in  terms  of  cost 
savings  and  redeployment  to  other  substances.  Potential  issue 
due to loss in the time series if releases increased in the future. 

Prefe
rred 
optio
n 

Yes 

Yes 

No 

The  substances  Alachlor,  Simazine  and  Chlorfenvinphos  (herbicides)  are  placed  in  the  first 
category. They are banned in the EU for many years, and concentrations above the EQS are 
identified  in  only  a  limited  number  of  water  bodies.  The  overall  risk  to  the  environment  is 
considered to be low. Deselection could free up resources that can be reallocated to emerging 
risks. The deselection of substances is likely to bring cost savings estimated at €3.8 m- €11.7 
million per year. 

Trichlorobenzenes (solvents  and chemical  intermediates) are placed in  the second category. 
Their  use  is  ongoing,  and  the  substances  are  acutely  toxic  to  the  aquatic  environment.  The 
rates of exceedance are not very high, but deselection is more questionable than for the other 
substances given the risk quotient RQ and its MSFD relevance. To maintain protection, this 
substance could be monitored as a RBSP where needed. Consequently, trichlorobenzenes are 
not proposed for deselection. 

All substances have in common that, even if they were removed from the PS list, they might 
still be relevant as RBSPs, and MS could decide to continue monitoring them at national level 
where needed. 

7.2  7.2 

Groundwater 

Table 7.2.1: Pollutants for addition to GWD Annexes I and II – preferred option 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
Substances  

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

Policy 
Option 1 
(Annex 
I 
addition  as 
group 
of 
specific 
substances) 

Soils: 
+++ 
Carbo
n: -- 

Policy 
Option 2 
I 
(Annex 
addition  as 
group of all) 

Soils: 
++++ 
Carbo
n: --- 

PFAS 

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

--- 
(mitig
ation 
meas
ures) 
+++ 
(avoi
ded 
costs 
DW, 
health 
care) 

---- 
(mitig
ation 
meas
ures) 
++++ 
(avoi
ded 
costs 
DW, 
health 
care) 

Policy 
Option 3 
(Annex 
addition) 

---- 

+/- 

II 

Phar
mace
utical
s 

Policy 
Option 1 
(individual 
Annex 
addition) 

I 

+ 

- 

EN 

s
t
c
a
p
m

i

l
a
i
c
o
S

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

  Justification  
e
c
n
e
r
e
h
o
C

++++ 

++ 

++++ 

++++ 

+/- 

+++ 

+++ 

+++ 

pollution 

Carbon intensive  remediation  and 
reduced low cost organic material 
for  soils  are  negative,  whilst 
improved  ecosystem  health  and 
are 
reduced 
soil 
environmental 
benefits. 
Economically the cost of disposal 
is high, but balances with the cost 
of  avoided  health  treatment  and 
drinking  water  treatment  for  the 
listed  PFAS. 
  Socially  health 
impacts are  very large, but this is 
only effective and efficient for the 
specific PFAS.  Strong coherence 
with the DWD / EQSD.    
Carbon intensive  remediation  and 
reduced low cost organic material 
for  soils  are  negative,  whilst 
improved  ecosystem  health  and 
are 
reduced 
soil 
environmental 
benefits. 
Economically the cost of disposal 
is high, but balances with the cost 
of  avoided  health  treatment  and 
drinking  water  treatment  for  all 
PFAS.    Socially  health  impacts 
are  very  large  (more  than  Policy 
Option 1).  Strong coherence with 
legislation but goes further. 

pollution 

Prefer
red 
option 

Yes 

No 

Healt
h  & 
Equin
e 
indust
ry: -- 
AMR 
/ 
Chro
nic 
ingest
ion: 
++ 
Miner
al 
water
: ++ 

Healt
h: --- 
Fishe
ries: 
+ 
Miner
al 
water
: ++ 

-- 

+/- 

+ 

Environmentally  effective  only 
where  included  in  GW  risk  is 
identified and will not provide the 
same  level  of  protection  at  the 
Europe wide level. The ubiquitous 
nature  of PFAS  suggests  that  this 
will  not  be  an  effective  policy 
option.  Not  coherent  with  other 
legislation. 

No 

-/+ 

+ 

+ 

in 

Small  scale  environmental  and 
economic impacts restricted to the 
listed  substances.  Social  impact 
industry 
on  health  &  Equine 
(restriction 
versus 
use) 
potential  for  reduction  in  chronic 
ingestion and AMR. Effectiveness 
uncertain as human health may be 
impacts. 
more 
Coherence with aims of EU Green 
Deal reductions in AMR. 

important 

than 

Yes 

  EN 

 
 
 
 
 
 
 
 
 
 
Substances  

l
a
t
n
e
m
n
o
r
i
v
n
E

s
t
c
a
p
m

i

s
t
c
a
p
m

i

c
i
m
o
n
o
c
E

s
t
c
a
p
m

i

l
a
i
c
o
S

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

  Justification  
e
c
n
e
r
e
h
o
C

Policy 
Option 2 
(Annex 
I 
addition  as 
group of all) 

+++ 

-- 

+/- 

++ 

+++ 

+ 

health 

human 

investment 

Large scale environmental impact 
and  moderate  economic  impact 
green 
in 
from 
Social 
pharmacy  measures. 
impact 
and 
veterinary  medicines  (restriction 
in  use)  versus  health  benefits  of 
reduction in chronic ingestion and 
AMR.  Supported  by 
returns 
schemes 
effectiveness 
uncertain as human health may be 
more 
impacts. 
Coherence with aims of EU Green 
Deal reductions in AMR in soils. 

important 

than 

but 

Prefer
red 
option 

No 

Policy 
Option 3 
(Annex 
addition) 

--- 

+/- 

II 

Policy 
Option 1 
(individual 
Annex 
addition) 

I 

++ 

- 

Farmi
ng: - 
Miner
al 
water
: ++ 

Farmi
ng: - 
Miner
al 
water
: +++ 

-- 

+/- 

+ 

Little impact on reducing levels in 
GW  across  Europe  and 
little 
terms  of  economic 
change 
impact.    Social  impacts  will  be 
localised  to  where  an  issue  has 
been identified.  

in 

Only 
for 
primid
one 

++ 

++++ 

+++ 

impacts 

Environmental 
include 
reduced drinking water treatment, 
healthier  GW  ecosystems  (and 
services  such  a  denitrification). 
Economic  impacts  will  be  the 
costs  of 
finding  new  parent 
products  and  legacy  clean  up. 
Social  impacts  will  include  the 
challenge  to  pesticide  industry 
and farming for authorisations and 
restriction of use, whilst the water 
bottling  and  fisheries  sectors  will 
benefit.  Efficient 
group 
identified.    Coherent  with  EU 
Green  Deal  but  goes  beyond 
DWD. 

for 

nrMs 

Policy 
Option 2 
I 
(Annex 
addition  as 
group of all) 

Policy 
Option 3 
(Annex 

II 

+++ 

-- 

+/- 

+++ 

+ 

+++ 

impacts 

Environmental 
include 
reduced drinking water treatment, 
healthier  GW  ecosystems  (and 
services  such  a  denitrification). 
Economic  impacts  will  be  the 
costs  of 
finding  new  parent 
products  and  legacy  clean  up. 
Social  impacts  will  include  the 
challenge  to  pesticide  industry 
and farming for authorisations and 
restriction of use, whilst the water 
bottling  and  fisheries  sectors  will 
benefit.  Efficiency  is  uncertain 
due  to  the  GW  timelag.  Coherent 
with  EU  Green  Deal  but  goes 
beyond DWD. 

---- 

+/- 

+/- 

-- 

+/- 

+++ 

Small  impact  on  reducing  levels 
at 
scale  means 
environmental  impacts  are  low 

European 

No 

Yes 

No 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
Substances  

addition) 

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Prefer
red 
option 

change 
analysis 

impacts  where  used 

to 
with  minimal 
investment 
and 
in 
mitigation  measures.    Localised 
is 
social 
restricted.  Coherent  with 
the 
DWD  but  not  with  the EU  Green 
Deal.  Option  is  ineffective  and 
inefficient  at  dealing  with  the 
issue at the EU scale. 

Of all options, Option 3 (all PFAS in Annex II, TVs to be possibly set at MS level) not only 
provides  the  weakest  protection  of  groundwater,  but  would  also  result  in  a  fragmented 
approach per MS. Given the widespread pollution of PFAS in groundwater and the societal 
and environmental impacts, EU harmonised action is essential.  

For Option 1 (group of 24 PFAS in Annex I) the distance to target is large, meaning that the 
concentrations  in  a  large  number  of  locations  will  likely  exceed  the  proposed  GW  QS  in  a 
large number of MS. While the distance to target is similar for Option 2, a simple sum of all 
PFAS approach is suggested in order to future-proof the legislation. As the distance to target 
is  similar,  the  types  of  implementing  measures  (requiring  action  on  both  point  and  diffuse 
pollution) would be similar for both options and costs and benefits would also be within the 
same ranges. 

Option 2 are considered in line with the current DWD, but Option 2 would not “future proof” 
the  legislation  in  terms  of  the  remaining  PFAS  substances  and  is  therefore  not  considered 
protective enough of public health. On this basis Option 1 is selected as the preferred option 
for  PFAS.  The  latest  EFSA  opinion  on  the  maximum  tolerable  intake  also  points  in  this 
direction. 

The assessment, the SCHEER opinion and the results of the stakeholder consultation give a 
preference to Option 1 (add carbamazepine and sulfamethoxazole to Annex I, with individual 
GW QS). This option has generally smaller costs than Option 2 (adding the two substances as 
a  group).  Option  1  will  lead  to  a  reduced  pollution  of  groundwater  and  positive  impact  on 
shellfish  and  fisheries  where  groundwater  inputs  to  rivers  and  estuaries  are  of  considerable 
importance. Product  substitution  is  considered as a viable option for Sulfathemoxazole, but 
less for Carbamazepine. MS will likely not take measures such as the treatment of biosolids 
only for these two pharmaceuticals as that would be disproportionately expensive but rather 
turn  to  ‘Green  Pharmacy’75  initiatives  or  other  source  control  and  pathway  disruption 
measures.  

The  assessment  also  showed  that  there  is  enough  evidence  for  Primidone76  to  be  added  to 
Annex II77 (i.e. partly implementing Option 3), which would not have a large impact on costs 

75 Green pharmacy – a narrative review: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6296717/#b1-cm-91-391 
76 During the period of the SCHEER review, the Groundwater Watch List dataset was supplemented with additional data following a 
SCHEER request. 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
                                                           
or benefits. Adding Primidone means that MS have to establish suitable threshold values for 
this substance at national level. 

Most of the parent pesticides of the 16 nrMs identified are already banned. For the remaining 
parent pesticides, a number of strategies and legislation at EU level will drive down pesticide 
use,  as  well  as  national  action  plans  under  the  SUPD78.  Stakeholder  feedback  suggests  that 
there  is  a  common  understanding  that  nrMs  are  widely  found  in  groundwater  in  worrying 
concentrations and that the emissions of the parent substances need to be limited. 

The distance to target assessment suggests that options 3b (all nrMs as a group in Annex I) 
and  3c  (all  nrMs  as  a  group  in  Annex  II)  are  likely  to  maintain  the  status  quo  and  no 
additional measures beyond those identified under the dynamic baseline scenario are needed. 
Option 3e (all nrMs in Annex I with lower GW QS) are coherent with that. Given that the 16 
nrMs  are  already  detected  in  groundwater,  there  is  a  risk  of  further  substances  detected  in 
future  at  levels  of  concern.  Option  3e  extends  the  more  stringent  GW  QS  to  all  nrMs  of 
pesticides and thus future proofs legislation, whilst following the precautionary principle: it 
should therefore be selected. 

7.3  7.3 

Monitoring, reporting and administrative streamlining options  

Error!  Reference  source  not  found.  summarises  the  impacts  of  implementing  the 
monitoring,  reporting  and  administrative  streamlining  options,  compared  to  the  status  quo. 
The options presented are not mutually exclusive.  

Table 7.3.1: Monitoring, reporting and administrative streamlining – preferred options 

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+/- 

+/- 

+ 

+/- 

+/- 

++++ 

Impacts  on  environment  /  economy 
neutral  as  depending  on  uptake  from 
MS.  Similarly, 
and 
efficiency  will  depend  on  the  extent  of 
investment  and  uptake.  Option  coherent 
with provisions of WFD 

effectiveness 

+/- 

+/- 

+ 

+/- 

+/- 

++++  As above 

+/- 

+/- 

+ 

+/- 

+/- 

++++  As above 

Policy 
option  

Sub-option 

Option 1: 
Provide  / 
improve 
guidance 
and 
advice  on 
monitorin
g 

a)  Guidelines  on 
applying 
innovative 
methods. 

b) 

Improve 
existing 
guidelines  on 
EBMS. 

c)  Harmonised 
monitoring 
methodology 
and  guidance 
for 

77 During the March 2022 stakeholder workshop, participants concluded that from the 9 pharmaceutical substances (Clopidol, Cortamiton, 
Amidozoic Acid, Sulfadiazine, Primidone, Sotalol, Ibuprofen, Erythromycin, Clarithromycin) considered on the Groundwater Watch List 
only for Primidone there was enough evidence to consider inclusion at this point in time. 
78 COM(2022) 305, proposal for a regulation on the sustainable use of plant protection products. 

EN 

Preferr
ed 
option 

No 

Yes 

Yes 

  EN 

 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                                                     
Policy 
option  

Sub-option 

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microplastics. 

d)  Guidelines  on 
sampling 
frequency  for 
PS 
and 
RBSPs. 

e)  Repository 

for 
sharing 
best  available 
monitoring 
technique 
practices MS. 

a)  Obligation  in 
EQSD  to  use 
EBMs 
to 
monitor 
estrogens. 

b)  Obligatory 

Groundwater 
Watch 
List 
mechanism. 

c) 

review 
of 

Improve 
monitoring 
and 
cycle 
Surface 
Water  Watch 
List 

a)  Harmonised 
digital 
reporting 
automated 
data  delivery 
mechanism. 

/ 

b)  Reference  list 
for 
of  EQS 
and 
RBSPs 
incorporate 
RBSPs 
into 
assessment  of 
chemical 
status 

Option 2: 
Establish 
/  amend 
obligator
y 
monitorin
g 
practices 

Option 3: 
Harmonis
e 
reporting 
and 
classificat
ion 

+/- 

+/- 

+ 

+/- 

+/- 

++++  As above 

+ 

++ 

++ 

+/- 

+/- 

++++ 

+++ 

- 

+++  ++++ 

+/- 

++++ 

+++ 

- 

+/- 

++++ 

++ 

++++ 

++ 

+/- 

+/- 

++ 

+ 

++++ 

Impacts  on  environment  /  economy  and 
social  positive  as  it  enables  knowledge 
sharing. Efficiency positive as long term 
benefits  outweigh  investment  due  to 
savings 
in  unsuccessful  approaches. 
Effectiveness  depends  on  use  of  MS. 
Coherent with WFD 
Economic  impacts  high  but  benefits  to 
environmental  and  society  significant. 
Effectiveness  very  high,  whereas  the 
cost/benefit ratio means a neutral rating. 
Coherent with WFD 

but 

have 

Obligation for monitoring would inquire 
costs, 
significant 
environmental  benefits  in  short  term, 
term. 
and 
Effectiveness 
very 
positive  as  monitoring  stations  already 
in place. Option coherent with WFD 

long 
in 
efficiency 

social 
and 

likely 

such, 

burden 

reporting 

Significant  environmental  benefits  and 
reduced 
likely 
outweigh  possible  costs  of  monitoring. 
As 
considered 
effectiveness 
medium.  Efficiency  small  positive  as 
administrative costs are compensated by 
decrease  in  frequency  of  updating  list. 
Option coherent with WFD 

+ 

- 

+ 

+++ 

+ 

++++ 

Significant  benefits  in  the  long  run, 
however  substantial  cost  implications 
involved.  As  such,  the  effectiveness  is 
high but the efficiency remains positive, 
but 
the  benefits  would 
outweigh  cost  but  only  through  time. 
The  option  is  coherent  with  provisions 
of the WFD 

small  as 

+/- 

-- 

+++  +++ 

++ 

++++ 

actors 

Negative impact due to substantial costs 
MS  for  implementation  and  costs  for 
taking  measures. 
economic 
However,  positive 
through 
impacts 
harmonization  allowing  more  effective 
measures  and  providing  equal  standard 
of  water 
to  high 
effectiveness.  Benefits  will  outweigh 
costs thus efficiency also positive. 

resource 

leads 

Preferr
ed 
option 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
Policy 
option  

Sub-option 

a)  Update 

lists 
of  SW  and 
GW 
pollutants  by 
delegated 
acts. 

b)  Change  status 
of ‘eight other 
pollutants’  to 
that 
of 
PS/PHS. 

Option 4: 
Legislativ
e 
and 
administr
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aspects 

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Preferr
ed 
option 

+++ 

+/- 

+++  + 

+++ 

++++ 

improvement 

Cost of measures to be taken and minor 
costs  associated  to  delegated  acts  but 
balanced  by  stimulating  innovation  and 
in 
possible 
competitiveness.  Environmental 
and 
social  impacts  very  positive  leading  to 
positive  efficiency  rating.  Effectiveness 
will  depend  on  which  pollutants  are 
actually integrated. 

Yes 

+ 

- 

++ 

++ 

++ 

++++ 

increases 

consistency 

Five  of  eight  other  pollutants  are  POPs 
under  Stockholm  Convention,  therefore 
option 
and 
improve  efficiency  and  effectiveness 
with  their  management.  Three  other 
substances  are  solvents  with  known 
CMR  properties, 
for  which  water 
protection  currently  not  addressed. 
tetrachloroethylene 
Addition 
would have strong coherence benefits to 
REACH 
emissions 
directive.  

tri  and 

solvent 

and 

c)  Change  status 
some  existing 
PS  to  that  of 
PHS. 

n/a 

n/a 

n/a 

++++ 

Stockholm 

PHS  status  coherent  as  follows:    PCP 
(to  become  PHS  along  with  other  POP 
under 
Convention); 
Fluoranthene 
(grouped  with  other 
PAHs  recognised  as  POPs  under  the 
Long-Range 
on 
Convention 
Transboundary Air Pollution); . 
Lead  (other  metals  of  similar  class  are 
already  PHS);  1,2  dichloroethane 
(‘sufficient concern at community level’ 
as  in  REACH);  the  two  Octylphenol 
substances 
(coherence  REACH  and 
sufficient concern at community level)  

8 

8   PREFERRED POLICY PACKAGE  

8.1  8.1 

Preferred options summary 

The preferred policy options are aggregated in Table 8.1.1 below. The package of options all 
surface and groundwater options and the digitalisation, administrative streamlining and better 
risk management options marked as preferred in the preceding chapter. 

Yes, 
except 
carbon 
tetrachl
oride 
(see  SW 
option 
4) 

Yes 

EN 

  EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 8.1.1: Preferred policy initiatives 

Surface water 

Option  1:  Addition  to  PS  list  as  an  individual 
substance with EQS set for each individually 

24 individual substances: 
17-Beta  estradiol  (E2);  Acetamiprid;  Azithromycin;  Bifenthrin; 
Bisphenol  A;  Carbamazepine;  Clarithromycin;  Clothianidin; 
Deltamethrin; Diclofenac; Erythromycin; Esfenvalerate; Estrone (E1); 
Ethinyl  estradiol 
Imidacloprid; 
Nicosulfuron;  Permethrin;  Silver;  Thiacloprid;  Thiamethoxam; 
Triclosan, Silver 

(EE2);  Glyphosate; 

Ibuprofen; 

Option  2:  Addition  to  PS  list  as  a  group  with 
EQS set for “total” and/or “sum of” 

PFAS (sum of 24 named substances)  

Option 3: Amendment of existing EQS 

Option 4: Deselection 

Groundwater 

14 substances to more stringent: 
Chlorpyrifos; Cypermethrin; Dicofol; Dioxins; Diuron; Fluoranthene; 
Hexabromocyclododecane 
Hexachlorobutadiene; 
Mercury; Nickel; Nonyl Phenol; PAHs; PBDEs; Tributyltin 
2 substances to less stringent: 
Heptachlor/heptachlor epoxide; Hexachlorobenzene,  

(HBCDD); 

4  substances:  Alachlor;  Carbon  tetrachloride;  Chlorfenvinphos; 
Simazine 

Option  1:  Addition  to  Annex  I  with  GW  QS 
set for each individually 

2 pharmaceutical substances: Carbamazepine and Sulfamethoxazole  
All nrMs with individual GW QS of 0.1 µg/l 

Option 2: Addition to Annex I with GW QS set 
for “total” and/or “sum of” 

PFAS (sum of 24 named substances) 

Option 3: Addition to Annex II 

1 substance: Primidone  

Digitalisation, administrative streamlining and better risk management 

Option  1:  Provide  guidance  and  advice 
on monitoring  

Option  2:  Establish/amend  obligatory 
monitoring practices 

Option  3:  Harmonise  reporting  and 
classification 

Option 4: Legislative and administrative 
aspects 

b 

c 

a 

b 

c 

a 

b 

a 

b 

c 

Improve  existing  EBM  guidelines 
groups/mixtures of pollutants by using EBMs. . 

to 

improve  monitoring  of 

Develop  a  harmonised  measurement  standard  and  guidance  for 
microplastics in water as a basis for MS reporting and a future listing 
under EQSD and GWD. 

Include an obligation in the EQSD to use EBMs to monitor estrogens. 

Establish an obligatory Groundwater Watch List analogous to that of 
surface  waters  and  drinking  water  and  provide  guidance  on  the 
monitoring of the listed substances. 

Improve the monitoring and review cycle of the Surface Water Watch 
List so that there is more time to process the data before revising the 
list. 

Establish automated data delivery mechanism to ensure easy access at 
short  intervals  to  monitoring/status  data  to  streamline  and  reduce 
efforts  associated  with  current  reporting,  and  to  allow  access  to  raw 
monitoring data. 

Introduce  a  repository  of  environmental  quality  standards  for  the 
RBSPs  as  an  Annex  to  the  EQSD,  and  incorporate  RBSPs  into  the 
assessment of surface waters’ chemical status. 

Use EQSD instead of  WFD to define the list of Priority Substances, 
and  update  the  lists  of  SW  and  GW  pollutants  by  Comitology  or 
delegated acts. 
Change  the  status  of  Aldrin,  Dieldrin,  Endrin,  Isodrin,  DDT, 
Tetrachloroethylene  and  Trichloroethylene  from  ‘other  pollutants’  to 
that of Priority Substances. 
Change 
lead, 
octylphenol  ethoxylates  and  pentachlorophenol  to  that  of  Priority 
Hazardous Substances. 

the  status  of  1,2  dichloroethane,  fluoranthene, 

EN 

  EN 

 
 
 
8.2  8.2 

Overall magnitude of impacts 

The proposed policy package ensures that legislative changes remain proportionate, i.e. that 
societal  and  environmental  benefits  are  larger  than  economic  costs  incurred  and  that  the 
issues are best addressed at EU level. An overview of direct and indirect costs and benefits 
associated with the options is provided in Annex 3. 

As  set  out  in  the  introduction  to  section  6  it  is  not  possible,  in  this  impact  assessment,  to 
identify the isolated cost and benefit of listing substances since this will depend on measures 
chosen  by  MS  and  on  distance  to  target  in  the  concerned  water  bodies.  Moreover,  water 
legislation  works  in  sync  with  other  legislation  (waste  water  treatment,  source  control, 
international  requirements,  etc).  Figures  mentioned  are  therefore  often  related  to  estimated 
costs / benefits from groups of substances with similar characteristics or effect.  

For surface water, significant direct adjustment costs are expected for instance from the fact 
of adding ibuprofen, glyphosate, PFAS, Bisphenol-A and Silver to the PS list, as well as from 
the  amended  EQS  of  PAHs,  mercury  and  nickel.  In  relation  to  groundwater,  the  most 
significant  costs  are  expected  for  PFAS,  associated  with  the  restriction  of  use  (e.g.  in  fire-
fighting  foams  -  up  to  €390  million/year  per  substitute  use)  and  the  management  of 
contaminated bio-solids (up to  €755 million/year for incineration and €201 million/year for 
landfilling  at  EU  level).  The  cumulative  costs  of  the  preferred  digitalisation,  administrative 
streamlining  and  better  risk  management  options  are  of  an  administrative  nature,  initially 
materialising at EU level and generally low (below €1 million), with the possible exception 
of the automated data delivery mechanism.  

It  is  worth  noting  that  costs  cannot  be  attributed  solely  to  this  initiative,  due  to  inevitable 
interactions  and  synergies  with  many  other  EU  policies  tackling  the  same  substances.  The 
costs of pollution are mostly internalised through the IED and the UWWTD, the future ban 
on all PFAS except in essential uses, the implementation of the microplastics initiatives and 
others. For example, the revision of the UWWTD will boost the upgrade of many UWWTPs, 
and  introduce  extended  producer  responsibility  (EPR)  to  cover  the  costs,  which  will 
significantly  reduce  the  load  of  micropollutants  (like  pharmaceuticals  and  microplastics) 
entering surface and groundwaters. 

The proposed initiative will contribute to the benefits of water policy primarily by reducing 
concentrations of acutely toxic and/or persistent chemicals in surface and groundwater. It will 
also improve the value of the aquatic ecosystems and of the services they deliver. However, 
the valuation of these benefits is challenging. First,  this is because it is difficult to attribute 
benefits to specific measures. Many measures are multifunctional and have multiple benefits 
that contribute to the objectives of several policies. A second challenge is that the evaluation 
of benefits requires taking account of various non-quantifiable and location-specific factors, 
which  limits  the  potential  for  aggregation  and  accurate  monetisation  (this  is  the  case  in 
particular for ecosystem services). 

Nevertheless,  this  impact  assessment  concludes  that  overall  benefits  for  society  outweigh 
costs considerably, based on reduced impacts on the environment, human health, pollinators 
and agriculture, as well as avoided costs of water treatment. For example, annual healthcare 

EN 

  EN 

 
 
 
costs  related  to  endocrine  disruptors’  exposure  are  estimated  to  be  €163  billion,  whereas 
hypertension brought about by background PFAS exposure contributes to an estimated €10.7-
35 billion of annual health costs. The annual health benefits from lowering the risks of PFAS 
exposure are estimated to be at least €52-84 billion in the EEA countries. The annual avoided 
costs from not using reverse osmosis to remove PFAS from DW are estimated to be at least 
€9.13  billion.  Not  having  to  use  reverse  osmosis  would  also  lower  by  20%  the  amount  of 
water  extraction  needed  to  produce  drinking  water.  In  addition,  the  annual  costs  associated 
with treating BPA-containing leachate from landfills are estimated at around €103.7 million 
(assuming  25-year  lifetime),  whilst  the  costs  of  end-of-pipe  removal  of  microplastics  from 
waste water are estimated to be between €0.76-3.14 billion per year. Regulating background 
levels  of  these  chemicals  in  surface  and  groundwater  bodies  is  important  to  drive  down 
emissions,  hence  avoiding  or  significantly  reducing  these  costs.  When  assessing  the  annual 
health benefits from the health and environmental effects of nanosilver79 the possible role of 
silver in antimicrobial resistance is a relevant issue and is therefore included. 

These costs and benefits should be understood as the joint result of all policy actions by EU 
and Member States that address the concerned pollutants, and should therefore not be seen as 
the result of this initiative alone.  

The  preferred  policy  package  will  result  in  water  quality  improvements  contributing  to  the 
achievement  of  the  main  objective  of  this  review,  in  line  with  the  Zero  Pollution  and 
Biodiversity targets. As water quality issues (especially those caused by emerging pollutants) 
have  a  clear  cross-border  dimension,  they  need  to  be  addressed  at  EU  level  to  ensure  a 
uniform level of protection for EU citizens and ecosystems. Considerations of proportionality 
have been embedded into the legislative review so that decisions are guided by the presence 
(or absence) of an EU-wide risk. Where no such risk was identified, flexibility was left  for 
MS to set their own TVs. 

8.3  8.3 

One In, One Out 

In the context of the ‘one in, one out’ approach to which the Commission committed, it is 
important to pay specific attention to the costs and implications to business, especially small 
and  medium  sized  enterprises.  Costs  to  business,  including  the  agriculture  sector  related  to 
this  initiative  include:  (i)  administrative  costs;  (ii)  costs  related  to  fertiliser  and  pesticide 
management,  adjusted  feed  techniques  and  sampling,  and  waste  water  treatment;  (iii)  taxes 
and fees for the cost recovery of water services and activities with a significant impact on the 
environment;  and  (iv)  in  certain  cases,  costs  of  substitution.  Costs  on  business  and 
administration  will  be  felt  more  upstream  due  to  the  need  to  limit  emissions  during 
production or find substitutes for certain substances. Benefits may be felt rather by business 
downstream,  such  as  the  waste  water  treatment  sector  and  the  drinking  water  producers,  as 
well as water users such as farmers and building sector.  

Administrative costs cannot  be assessed at  the level  of businesses, since  MS will take very 
different  measures  to  comply,  considering  the  characteristics  of  the  water  body  and  the 
distance to target of the substances proposed for listing. Administrative expenses at EU level, 

79 Based on scientific opinions of the Scientific Committee on Emerging and Newly  Identified Health Risks (SCENIHR) on ‘Nanosilver: 
safety,  health  and  environmental  effects  and 
(https://health.ec.europa.eu/system/files/2016-
in  antimicrobial 
11/scenihr_o_039_0.pdf) from 2014 and SCCS (2018) opinions 

resistance’ 

role 

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in  particular  those  linked  to  the  monitoring,  reporting  and  administrative  simplification 
options,  are  specified  in  section  6.  Those  costs  range  from  €  1.9  to  2.3  million  for  the 
guidances  (effect  based  methods),  methodology  for  microplastics,  repository  of  RBSPs  and 
groundwater  watchlist  analysis,  of  which  €1  million  is  annually  recurring.  Administrative 
expenses at MS level associated with monitoring pollution are overall expected to increase, 
due  to  the  increased  number  and  different  nature  (like  microplastics  and  groundwater)  of 
substances  covered  by  the  legislation.  Cumulative  costs  are  estimated  between  €9  and  15.1 
million annually across the EU-27 (thus estimated at around 0.33 million to €0.55 million per 
year per MS). Both the European Environment Agency and the European Chemicals Agency 
will be tasked to carry out tasks on the water quality data access and the risk assessment of 
pollutants respectively, leading to annually recurring costs in the form of additional staff. 

8.4  8.4 

REFIT  

In line with the FC of 2019 and with the more holistic Monitoring Framework put in place by 
the 8th Environmental Action Programme, several elements of the existing Directives will be 
clarified and simplified in the legislative proposal on the basis this IA. This concerns notably 
the  requirements  related  to  reporting  and  data  sharing.  An  improved  collection  of  digital 
information  at  EU  level  which  allows  improved  understanding  of  pollutants  in  EU  waters 
(and so better targeting of measures), is likely to reduce the administrative burden of MS in 
the medium-long term.  In addition, through  digitalisation the comparability of MS data can 
be more closely aligned, ultimately increasing the transparency of data by publishing them on 
an online, centralised platform. This would also be beneficial for increased compliance of MS 
with provisions of the EU INSPIRE Directive, e.g. by using the INSPIRE Geoportal for this 
purpose. Digitalisation also helps to act independently of reporting timeframes, thus making 
data available more often and closer to real time. This would be beneficial for MS authorities, 
to demonstrate progress at national scale, and better empower civil society too. 

The revised Directives will introduce monitoring obligations for the newly listed substances 
while  removing  the  obligations  related  to  deselected  substances.  The  extent  to  which  the 
monitoring obligations trigger follow-up actions to reduce the emissions of those substances 
is limited to water bodies that are not in good status already (currently 59% of surface waters 
(11) (97)). In these cases, MS are obliged to take additional measures to ensure their surface 
water bodies achieve good chemical status. 

The Impact Assessment has differentiated this picture by assessing the expected ‘distance to 
target’ according to the type of pollutants (see Chapter 0). This revealed that for 13 of the 24 
substances or substance groups included in the preferred policy package as additions and for 
10 of the 15 substances or substance groups for which a change in EQS values is proposed, 
the expected distance to target is small to medium. Consequently, for these substances only 
limited or no additional measures are expected. 

A  relatively  large  distance  to  target  is  expected  only  for  10  of  24  (groups  of)  substances 
proposed  for  addition,  namely  PFAS,  four  pyrethroid 
insecticides  (Deltamethrin, 
Esfenvalerate;  Permethrin;  Bifenthrin),  Glyphosate  (herbicide),  Bisphenol-A  (industrial 
chemical),  Silver,  and  three  pharmaceuticals  (Carbamazepine,  Diclofenac,  Ethinylestradiol 
(EE2)).  The  same  is  also  expected  for  Mercury  and  the  flame-retardants  Polybrominated 
diphenyl ethers (PBDEs) for which a change in EQS values is proposed. For Mercury it needs 

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to  be  noted  that  this  is  a  ubiquitous  substance  which  is  already  causing  failure  to  achieve 
good  status  in  a  large  number  of  water  bodies,  so  a  revision  of  its  EQS  will  likely  not 
deteriorate the compliance situation significantly. 

9 

9  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?  

9.1  9.1 

Indicators of success 

The following success indicators were identified for the general objectives of this initiative to 
help compare the merits of the policy options and facilitate monitoring and evaluation. 

1.  Increase the protection of EU citizens and natural ecosystems  

  Declining concentrations of PS / PHS and ultimately achieving good chemical status 

for all EU surface waters, groundwaters and coastal waters. 

  An agreed EU measuring and monitoring method for microplastics in place by 2025 
  A more effective surface and groundwater watchlist mechanism (e.g. introduction of 

an obligatory GW WL mechanism by 2025) 
2.  Increase effectiveness and reduce administrative burden  

Introducing automated data delivery mechanisms for reporting water monitoring data 

 
  Using delegating acts for future revisions of the list of water pollutants  

These  indicators  will  support,  and  feed  into  the  integrated  monitoring  of  pollution  that  has 
been created by the Commission’s Zero Pollution Action Plan. 

9.2  9.2 

Monitoring and evaluation under the existing EU water quality legislation 

The existing WFD has a 6-yearly reporting cycle. In every cycle, MS report on the state of 
water in each river basin to the Commission, through the EEA. The EEA utilises this data to 
produce  a  State  of  Water  report.  The  monitoring  results  for  individual  PS/  PHS  feed  into 
chemical  status  assessments  (pass/fail)  per  WB.  The  Commission  uses  the  information  to 
assess the RBMPs and as a basis to assess compliance with the legislation. MS are required to 
report  the  specific  measures  they  have  taken  to  reduce  pressures  on  water  quality.  As  such 
success can be heterogeneous between different WBs. This heterogeneity learns that success 
factors also  relate to  measures in  other policy  areas. Measures to  address mercury levels  in 
surface  water  largely  depend  on  measures  to  tackle  Hg-emissions  from  the  combustion  of 
coal in large combustion plants, and pesticide emissions relate to DSUP measures. 

The  monitoring  and  reporting  obligations  under  the  WFD  will  remain the  key  indicators  to 
track  progress  against  the  objectives  of  this  revision.  For  surface  and  groundwater,  the 
timeliness,  and  the  completeness  of  reporting,  broken  down  by  MS,  pressure  source  and 
pollutants,  will  be  the  main  tools  to  evaluate  and  continuously  monitor  progress.  However, 
more frequent periodic (and obligatory) reporting and sharing of information by MS will be 
introduced as a result of the preferred policy package (e.g. by the mandatory GW WL). 

Currently,  data  reach  the  public  domain  with  considerable  delays.  For  example,  the  2018 
EEA State of Water report is based on 2012-2014 data and is, at the time of writing, the most 
up  to  date  information  publicly  available  at  EU  level.  While  acknowledging  that  an 
assessment of good status (ecological or chemical) is dependent on many different data put 
together,  better  uptake  of  modern  monitoring  and  digital  reporting  would  allow  generating 

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those  overviews  with  a  higher  frequency  than  every  6  years,  feeding  into  the  8th  EAP 
Monitoring Framework and the bi-yearly Zero Pollution Monitoring and Outlook Reports. It 
should also  be possible to  produce data on individual  quality  elements. This  is  in  line with 
digitalisation, administrative streamlining and better risk management options 4 (a repository 
for  sharing  best  practices 
their 
implementation) and 5 (an automated data delivery mechanism to ensure shorter intervals of 
monitoring, while streamlining reporting). 

regarding  available  monitoring 

techniques  and 

9.3  9.3 

Joint monitoring and evaluation 

In addition to the monitoring established under the WFD and the improvements proposed in 
this initiative, monitoring of water pollutants in EU laws that address pollution is crucial. In 
particular,  the  monitoring  provisions  included  in  the  revised  Industrial  Emissions  Portal 
(formerly: E-PRTR), UWWTD and other relevant legislation will be used to assess the policy 
effectiveness. Currently, the E-PRTR does not require reporting of PFAS emissionsHowever, 
PFAS is one category of substances that is envisaged to be added to the Industrial Emissions 
Portal Regulation based on the Commission proposal for revision. Automated links with the 
most recent lists of water polluting substances under this initiative are envisaged.  

This  initiative is  related to  many other work strands  under the ZPAP  which are ongoing or 
only  starting  to  deliver  results.  By  2025  the  Commission  will  take  stock  of  the  degree  of 
implementation of the ZPAP action plan, building on the second Zero Pollution Monitoring 
and Outlook Report. The water quality monitoring in the MS will help evaluate the success of 
the  present  initiative,  which  will  realistically  only  start  to  become  visible  after  2027. 
Combining the output and outcome indicators of those pieces of legislation with the impact 
indicators set by assessing “good chemicals status” will give a measure of whether the health 
and ecosystem benefits have been achieved or where there are gaps in implementation.  

Proper monitoring and reporting is key to ensure compliance with the Directive and to allow 
EU and MS to adjust policies in case these appear not to deliver the desired effects. In order 
for the legislative changes to become operational and effective, compliance at MS level must 
be  secured.  An  important  part  of  compliance  assurance  will  be  done  through  sectoral 
legislation  (IED,  UWWTD,  Sustainable  Use  of  Pesticides,  REACH,  Mercury  Regulation, 
etc.)  setting  requirements  for  polluters,  but  also  through  the  Environmental  Liability 
Directive  and  Environmental  Crime  Directive  which  are  currently  under  revision.  The 
existing  WFD  contains  several  provisions  that,  in  combination  with  the  above-mentioned 
legislation,  lay  down  a  comprehensive  compliance  assurance  mechanism.  The  more 
continuous availability of monitoring and status data (a combined effect of policy options 2a, 
2b,  5  and  6)  both  to  the  European  Commission  and  the  general  public  will  increase  the 
overall enforceability of the legislation. The creation of a mandatory groundwater watch list 
(Option 7) will lead to a more structured involvement of stakeholders in prioritising action on 
the most harmful substances, likely enhancing their interest in compliance. 

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EN 

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ANNEX 1: PROCEDURAL INFORMATION  

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The  preparation  of  this  impact  assessment  was  led  by  Unit  C1  Sustainable  Freshwater 
Management within DG Environment, with support from DG Joint Research Centre, Unit D2 
Water  and  Marine  Resources.  The  file  concerns  the  revision  of  the  lists  of  pollutants  and 
corresponding regulatory standards under the WFD, EQSD and GWD. These Directives were 
evaluated  according  to  Better  Regulation  guidelines.  The  Decide  planning  number  is 
PLAN/2020/8554 - Revision of lists of pollutants affecting surface and groundwaters. 

2.  ORGANISATION AND TIMING 

2.1.  COMMISSION INTERNAL PROCESS - INTER SERVICE STEERING GROUPS  

The  Inception  Impact  Assessment  Roadmap  (98)  was  published  on  23  October  2020  with 
feedback period closed on 20 November 2020. 

The inter-service steering group (ISSG) for the impact assessment is the same one as for the 
Evaluation. It is a shared group with other water and pollution related files: the revision of the 
UWWTD, the Evaluation of the SSD and the back-to-back Evaluation and impact assessment 
of the Bathing Water Directive. The ISSG includes members from the following DGs: AGRI 
(Agriculture),  CLIMA  (Climate  Action),  ENER  (Energy),  FISMA  (Financial  Stability, 
Financial  Services  and  Capital  Markets  Union),  GROW  (Internal  Market,  Industry, 
Entrepreneurship  and  SMEs),  HOME  (Migration  and  Home  Affairs),  JRC  (Joint  Research 
Centre),  JUST  (Justice  and  Consumers),  MARE  (Maritime  Affairs  and  Fisheries),  RTD 
(Research and Innovation), REGIO (Regional and Urban Policy), SANTE (Health and Food 
Safety),  SG  (Secretariat  General),  SJ  (Legal  Service),  TAXUD  (Taxation  and  Customs 
Union) as well as the EEA (European Environment Agency). 

Seven meetings of the ISSG were organised between October 2020 and September 2022, the 
final meeting being held on 22 September 2022. The ISSG has been consulted on all major 
deliverables  for  this  file,  including  the  inception  impact  assessment,  the  stakeholder 
consultation,  including  stakeholder  consultation  workshops,  open  public  consultation  and 
targeted experts survey and key deliverables for the support study prior to its submission to 
the Regulatory Scrutiny Board. The ISSG that was consulted during this process is identical 
to the one involved in the REFIT Evaluation of the Directives. 

3.  CONSULTATION OF THE RSB 

On 15 July 2021 an upstream meeting with the Regulatory Scrutiny Board (RSB) took place. 
The RSB provided several comments in relation to this file, centred on the following: 

  Need to prevent pollution at the source, enforceability and monitoring of the changes 
to  the  Priority  Substances  list  and  clarifications  on  the  applicability  of  the 
precautionary principle;  

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  Need to establish a Dynamic Baseline Scenario, allowing to account for implications 
of  existing  and  planned  EU  legislative  initiatives  (e.g.  Human  Pharmaceuticals 
legislation, Drinking Water Directive, UWWTD, etc.).  

The IA was submitted to the RSB on 25 May 2022 and discussed on 22 June. On 24 June the 
RSB issued its positive opinion with reservations. The points have been addressed as follows:   

RSB ‘What to improve’ 
the 
(1)  The  design  of  options  should  allow 
identification of impacts, separately for each option or 
their  combination.  The  options  and  their  presentation 
should  be  simplified,  and  purely  technical  elements 
moved  to  the  Annexes.  The  report  should  provide 
more  aggregated  and  more  relevant  options  and  sub-
options.  Options 
administrative 
linked 
simplification and burden reduction should be grouped 
together. 

to 

(2) The analysis of the impacts on SMEs and citizens 
should  be  further  developed.  The  report  should 
elaborate on the impacts on SMEs, including in terms 
of  the  compliance  costs  and  administrative  burden, 
and  present  the  results  of  the  application  of  the 
proportionate  SME  test.  The  impacts  on  consumers 
should  also  be  further  analysed  (indicatively,  in 
relation  to  pharmaceuticals,  personal  care  products, 
consumers’  health,  cost  of  water  services)  and  the 
evidence  should  be  clearly  presented 
the 
conclusions  reached.  The  report  should  be  more 
explicit on the implementation deficits in the problem 
analysis  and  examine  the  different  possible  impacts 
across  MS.  It  should  map  out  the  respective  efforts 
required from different MS to meet the targets set. 

for 

(3) The report should critically examine the validity of 
the  benefit  and  cost  estimates  presented  as  the 
examples of the potential impacts, provide more detail 
on  the  scope  and  methods  used  and  indicate  how 
relevant the examples are to this initiative.  
It  should  strengthen  a  summary  of  the  results  of  the 
cost benefit analysis, taking into account all qualitative 
and  quantitative  evidence  and  indicating  the  overall 
order  of  magnitude  of  the  expected  impacts  of  the 
preferred  option.  Given  the  link  with  many  existing 
and  ongoing  initiatives,  the  report  should  discuss  the 
relevance  and  attribution  of  costs  and  benefits  to  this 
initiative. Annex 3 should be simplified to integrate in 
a  concise  manner  the  qualitative  and  quantitative 
evidence.  The  analysis  should  reflect  any  changes  to 
the options’ structure. 

(4) The report should clarify the costs and cost savings 
in  scope  of  the  One  In,  One  Out  approach.  The 
dedicated  section  and  Annex  3  seem  incomplete.  All 
costs  and  benefits  related  to  the  One  In,  One  Out 
approach should be identified and clearly presented. 

How the comment has been addressed 
Presentation of the policy options has been simplified 
in  section  5  and  onwards.  In  particular  the  options 
aimed  at  monitoring,  reporting  and  administrative 
streamlining  have  been  aggregated  to  four  main 
options  with  sub-options.  The  link  with  the  overall 
objectives has been clarified, in particular in section 5. 

The  impacts  on  SMEs  has  been  further  developed 
throughout  the  text,  from  the  perspective  of  the 
different groups of pollutants. The SME test has been 
used  as  a  guidance  but  could  not  be  applied  in  full 
because  of  missing  data  and  the  context-specific 
nature of the measures to be taken by MS in response 
to the legislation.   

Information  on  impacts  on  consumers  for  several 
categories  of  products  (including  personal  care 
products) has been addressed, in sections 2 and 6.  

As  regards  efforts  required  from  MS,  Annex  4 
provides more information where the distance to target 
is  largest  and  Annex  11  indicates  for  each  substance 
which MS have measured exceedances at present. 
It  has  been  clarified  in  sections  6  and  8  how  the 
examples of benefits and costs need to be interpreted, 
to  avoid  the  impression  that  the  costs  and  benefits 
quoted  are  solely  linked  to  measures  following  from 
this initiative. 

Annex 5 shows the approximate effect of existing and 
future  policies  on  the  substances  proposed  as  part  of 
this initiative. 

The  paragraph  on  One  In,  One  Out  in  section  8  has 
been  supplemented  with  information  on  the  costs  of 
the  monitoring, 
administrative 
streamlining  options.  Relevant  information  has  also 
been included in Annex 3.  

reporting 

and 

(5)  The  report  should  systematically  integrate  the  Section  7  now  includes  a  summary  assessment  of 

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criteria  of  effectiveness,  efficiency  and  coherence  in 
the comparison of options. 

effectiveness, efficiency and coherence for the options 
and  sub-options, 
justification  for  a 
including  a 
particular score on these criteria. 

A large number of other improvements have been made as well, in reaction to more detailed 
RSB comments as well as other corrections deemed necessary. 

4.  EVIDENCE, SOURCES AND QUALITY 

To support the impact assessment, the European Commission awarded a contract to external 
experts. The revision of the lists of pollutants under EQSD, GWD and WFD was prepared by 
the Commission’s Joint Research Centre (JRC) which elaborated dossiers for each individual 
substance.  To  draft  the  scientific  dossiers  JRC  collected  data  from  available  EU  official 
reports (ECHA, RIVM, INERIS, UBA, OEKOTOXZENTRUM, etc.) and collections of data 
send by experts and stakeholders. In most cases such dossiers were prepared in consultation 
with working groups consisting of experts from MS and stakeholders, allowing each to bring 
their expertise to bear on the content of the dossier. In a next step, the Commission consulted 
stakeholders through the relevant CIS-working groups. Finally, the Scientific Committee on 
Health  and  Environmental  and  Emerging  Risks  (SCHEER)  expressed  an  independent 
scientific  opinion  on  the  proposed  EQSs  for  each  of  the  dossiers.  Preliminary  SCHEER 
opinions  for  substances  of  the  "Draft  Environmental  Quality  Standards  (EQS)  for  priority 
substances  under  the  WFD  and  GWD"  are  published  for  a  4-week  commenting  period. 
During this period comments were collected and considered, if relevant they were addressed 
directly by SCHEER in the final opinion. All substance dossiers both for new candidate PS 
and EQS revision substances were submitted to SCHEER for scientific opinion. Below is an 
overview of the progress of the work by the SCHEER.  

1.  Preliminary SCHEER opinions are available for the following substances: 

•  Nonylphenol, Glyphosate, Nickel, Fluoranthene. 

2.  Opinions being finalized (comments from public consultation period being processed): 

• 

Ibuprofen 

3.  Final SCHEER opinions are completed for the following substances: 

•  Pesticides 

(Nicosulfuron),  Pesticides-Pyrethroids 

(Bifenthrin,  Esfenvalerate, 
Permethrin,  Deltamethrin);  Pesticides-Neonicotoids  (Acetamiprid,  Clothidianidin, 
Thiamethoxam,  Thiacloprid,  Imidacloprid);  Macrolide  antibiotics  (Azithromycin, 
Clarithromycin,  Erythromycin);  Estrogenic  hormones  (17-Alpha-Ethinyl-Estradiol 
(EE2),  17-Beta-Estradiol  (EE2),  Estrone  (E1)),  Metals  (Silver),  Diclofenac,  PFAS, 
Cypermethrin,  Groundwater  (PFAS,  Pharmaceuticals  &  nrMs),  Carbamazepine, 
Chlorpyrifos, Bisphenol-A, Hexachlorobenzene, Diuron. 

4.  Pending SCHEER Opinions:  

•  For  the  following  dossiers  for  new  candidate  substances  the  SCHEER  has  not  yet 

published a preliminary option: Triclosan. 

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•  For  the  following  dossiers  for  existing  candidate  substances  for  a  revised  EQS  the 
SCHEER  has  not  yet  published  a  preliminary  option:  Mercury,  PAHs, 
Hexachlorobutadiene, Heptachlor, PBDEs, Dioxins, Tributyltin, Tetrachloromethane. 

For substances proposed for deselection: Alachlor, Simazine, Carbon tetrachloride there was 
no need for a SCHEER opinion. 

A summary of the stakeholder consultations that were carried out (Open Public Consultation 
and Expert Survey) is included in Annex 2 Stakeholder Consultation (Synopsis report). 

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ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)  

1. 

INTRODUCTION 

The Impact Assessment accompanying the revision of the lists of pollutants affecting surface 
and groundwaters and the corresponding regulatory standards in  the Environmental  Quality 
Standards,  Groundwater  and  WFD  was  subject  to  a  thorough  consultation  process  that 
included  a  variety  of  different  consultation  activities.  During  the  process,  the  Priority 
substances proposed for revision were consulted with stakeholder through the sub-groups of 
experts relevant to each substance and overall in the WG Chemicals, WG Groundwater and 
Strategic  Consultation  Groups.  Furthermore,  an  Open  Public  Consultation  has  been 
conducted, as well as a Targeted Experts Survey and two Stakeholder workshops. 

2.  CONSULTATION STRATEGY & ACTIVITIES 

2.1. 

Purpose of the online public consultation and targeted consultation 

Consultations  for  the  impact  assessment  of  the  possible  revision  of  the  lists  of  pollutants 
affecting  surface  and  groundwaters  and  the  corresponding  regulatory  standards  in  the 
Environmental  Quality  Standards,  Groundwater  and  WFD  were  conducted  with  the  aim  of 
gathering the opinion of the general public and experts. 

The  scope  of  the  consultations  primarily  concerned  three  key  water  policy  domains  in  the 
EU:  the  WFD,  the  EQSD  and  the  GWD.  The  WFD  aims  to  ensure  that  all  surface  and 
groundwater  bodies  (including  transitional  and  coastal  zones)  achieve  “good  status”.  For  a 
water body to be classified in overall good status, both the chemical status and the ecological 
or  (for  a  groundwater  body)  quantitative  status  must  be  at  least  good.  Regarding  chemical 
status  (the  focus  of  this  consultation)-  a  process  to  analyze  substances  which  pose  a 
significant EU-wide risk to the environment and require further action (Priority Substances) 
is  enshrined  in  the  WFD.  The  EQSD  establishes  standards  for  these  Priority  Substances- 
ensuring  that  MS  do  not  surpass  thresholds  which  pose  a  threat  to  the  environment  and 
human health. The GWD expands WFD requirements for groundwater quality and protection 
through  providing  a  list  of  relevant  pollutants  and  groundwater  quality  standards. 
Furthermore,  the  GWD  establishes  a  list  of  substances  which  MS  should  consider  when 
setting national threshold values for pollutants. 

The  key  objectives  of  the  consultation  process  were  (i)  to  confirm  the  scope  of  the  impact 
assessment  and  (ii)  to  collect  information  on  potential  impacts  of  proposed  options  and 
measures- particularly on potential costs and benefits. 

2.2.  Consultation strategy 

The  consultation  strategy  was  developed  at  the  start  of  the  study,  in  collaboration  with  the 
European Commission. The consultation methods and tools outlined in the strategy have been 
followed,  as  described  in  more  detail  in  the  following  sections.  Table  A2.1  presents  the 
stakeholder groups mapped to each consultation activity. 

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Table A2.1: Stakeholder groups consulted by each consultation approach 

Stakeholder type 

EU institutions 

General Public 

EU MS’ Authorities 

Third-country stakeholders 

Businesses and trade associations 

Non-governmental organisations 

International organisations 

Consultation approach 

Open 
Consultation 

Public 

Targeted  consultation 
survey 

Targeted 
meetings 

consultation 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

2.3.  Methods of stakeholder engagement 

The main consultation activities for the study were the following: 

  Feedback received on the Impact Assessment roadmap; 
  Open public consultation (OPC); 
  Targeted stakeholder engagement through a and expert survey; 
  Targeted stakeholder meetings (2 workshops and dedicated interviews). 

2.3.1.  Impact Assessment Roadmap 

The  European  Commission  published  the  roadmap  on  ‘Integrated  water  management  – 
revised lists of surface and groundwater pollutants’ (98) to offer the opportunity for interested 
parties to provide feedback on the scope of the Impact Assessment. The roadmap received 19 
pieces of feedback, which are synthesised in section 3.1 of this annex. 

2.3.2.  Open Public Consultation 

The  open  public  consultation  included  questions  tailored  to  examine  three  distinctive 
components which outlined potential measures to be analysed: 

  Protect  the  aquatic  environment  and  human  health  from  chemical  pollution  through 
achieving  good  surface  water  chemical  status  by  controlling  emissions  of  PS  and 
ceasing/phasing out emissions, discharges and losses of PHS; 

  Ensure a high and equal level of protection of groundwater resources including their 

connected or dependent ecosystems and their uses; 

  To  continuously  improve  knowledge  and  decision-making  on  sufficient,  correct, 

robust and transparent monitoring and reporting information. 

The questionnaire was  made available in  all EU languages and uploaded to  the  EU Survey 
tool. The consultation period started on 26th July 2021 and ended on 1st November 2021. The 
OPC received a total of 151 responses. An analysis of the feedback received is presented in 
section 3.2 of this report. A factual summary was published on the Commission’s Have Your 
Say pages (98).  

2.3.3.  Target stakeholder consultation - survey 

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An  online  survey  tailored  towards  stakeholders  with  a  detailed  technical  knowledge  of 
surface  water  and  groundwater  substances  and  current  EU  legislation  was  developed.  The 
survey targeted stakeholder groups including public authorities responsible for implementing 
and/or  enforcing  the  Directives,  industry  and  sectoral  associations  representing  companies 
concerned,  monitoring  organisations,  environmental  and  consumer  NGOs,  universities  and 
research  institutes,  and  any  other  organisations  interested  in  responding  to  the  survey.  The 
survey was made available between 27th July 2021 and 19th October 2021. 

The  survey  addressed  the  three  topic  areas:  surface  waters,  groundwaters  and  the 
digitalisation,  administrative  streamlining  and  better  risk  management  options.  The  policy 
options were based on: 

  Addition of substances and/or groups of substances to the list of Priority Substances 
(PS)  in  surface  waters  (Annex  X  to  the  WFD)  and  the  setting  of  corresponding 
Environmental Quality Standards (EQS) in the EQSD; 

  Possible amendment of EQS / deselection of existing PS from Annex X to the WFD 

and Annex I to the EQSD; 

  Designation of some PS as Priority Hazardous Substances (PHS) in Annex X to the 
WFD;  re-designation  of  the  eight  “other  pollutants”  in  Annex  I  of  the  EQSD: 
conversion to PS, deselection, or retention as ”other pollutants”; 

  Addition of substances to the lists of groundwater pollutants (Annexes I and II to the 

GWD), with corresponding quality standards in the case of Annex I; 

  A  set  of  complementary  options  aiming  to  encourage  the  use  of  new  monitoring 
methods  and  improve  current  monitoring  approaches,  improve  risk  assessment  and 
the translation into risk management, and enhance data management transparency and 
utilization. 

The targeted survey received a total of 124 responses. 

3.  METHODOLOGY AND TOOLS USED TO PROCESS THE DATA 

3.1.  Open Public Consultation (OPC) 

The approach taken included: 

  Respondents  were  asked  to  respond  to  stand-alone  open-ended  questions  in 

combination with elaborating their answers in open text fields. .  

  Based on the responses to questionnaire data graphics were created to summarise and 

present the outcomes.  

  Finally,  any  attachments,  links,  or  other  materials  submitted  by  stakeholders  were 

analysed and incorporated. 

3.2.  Targeted stakeholder consultation - survey 

The analysis steps were: 

  Questionnaire raw data was imported and cleaned in an Excel template.  
  Graphics were created to summarise and present the outcomes.  
  Respondents  were  asked  to  respond  to  stand-alone  open-ended  questions  in 

combination with elaborating their answers in open text fields.  

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  Finally,  any  attachments,  links,  or  other  materials  submitted  by  stakeholders  were 

analysed and incorporated. 

Due to the low number of responses and a general lack in EU wide representation it was not 
possible  to  interpret  Member  State  specific  response  patterns  in  the  obtained  answers.  As 
such,  the  analysis  focuses  on  a  general  overview  of  respondents’  opinions  regarding  the 
matter, without concluding broadscale national or sector specific positions/opinions. 

3.3.  Targeted stakeholder consultation - workshop and interviews 

Throughout  the  course  of  the  project,  two  thematic  workshops  were  held.  The  workshops 
focused on specific core subjects of interest, as highlighted in Table A2.2 below. 

Table A2.2: Workshops summary 

Workshop 

Topic 

Number 
participants 

of 

1: 21st May, 2021 

2: 18th March, 2022 

Primary  objective:  gather  feedback  from  stakeholders  on  the  policy 
options  presented.  The  workshop  was  split 
three  distinct 
components to align with the types of options considered in the Impact 
Assessment,  namely:  surface  waters,  groundwaters  and  digitalisation, 
administrative streamlining and better risk management options 

into 

Primary objective was to gather feedback on the elaborated set of policy 
options  and  the  cost-benefit  assessment.  The  workshop  was  split into  a 
groundwater  and  a  surface  water  session,  and  a  session  to  discuss  the 
digitalisation,  administrative  streamlining  and  better  risk  management 
options. 

247 
participants 
registered. 

250 
participants 
registered 

3.3.1.  Workshop 1 

The  workshop  was  split  into  three  distinct  components  to  align  with  the  types  of  options 
considered  for 
impact  assessment,  namely:  surface  waters,  groundwaters  and 
digitalisation, administrative streamlining and better risk management options. 

the 

For surface water, four topic areas of options formed the basis of the discussion: addition of 
candidate  substances  to  the  PS  list;  amendment  of  EQS  for  existing  PS;  designation  of  the 
eight “other pollutants” (included in Annex I of the EQSD) as PS; and deselection of existing 
PS which no longer present an EU-wide risk. 

For groundwater, three topic areas of options would form the basis of the discussion within 
the group: adding PFAS substances to Annex I or II of the GWD; adding pharmaceuticals to 
Annex  I  or  II  of  the  GWD;  and,  adding  (potentially)  harmful  degradation  products  from 
pesticides (nrMs) to Annex I or II of the GWD. 

Finally,  the  digitalisation,  administrative  streamlining  and  better  risk  management  option 
segment  of  the  workshop  focussed  on  measures  identified  in  the  FC  of  the  WFD  and 
Daughter  Directives  (10).  The  digitalisation,  administrative  streamlining  and  better  risk 
management  measures  session  of  the  workshop  focussed  on  three  topics  that  aimed  to 
maximize  the  (cost)  effectiveness  of  procedures,  namely:  monitoring  approaches;  risk 
assessment and the translation into risk management; and data management. 

3.3.2.  Workshop 2 

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The second workshop took place on 18 March 2022, when the work both  on the substance 
dossiers and the impact assessment background study had advance considerably. The meeting 
was used to present the results of the stakeholder consultation activities so far, in particular 
the  expert  survey  and  open  public  consultation.  The  lionshare  of  the  meeting  was  however 
devoted to the review of the first results of the assessment of environment / social / economic 
costs and benefits of the options developed. To this end, a separate session was organized on 
surface  water  options,  groundwater  options  and  the  range  of  digitalisation,  administrative 
streamlining  and  better  risk  management  options.  Participants  received  a  background 
document  containing  the  core  results  of  the  assessment  and  an  extensive  powerpoint 
presentation. 

4.  SUMMARY OF RESULTS OF THE STAKEHOLDER CONSULTATION 

The key findings overarching all consultation activities can be summarized as follows: 

  Stakeholders noted concerns about  contaminants of emerging concern,  their impacts 
and  how  these  are  being  addressed.  PFAS,  microplastics  and  pharmaceuticals  stood 
out  as  concerning  substances  that  require  attention  in  both  surface  waters  and 
groundwaters. 

 

In surface waters, stakeholders did not provide a clear preference across consultation 
activities  as  to  whether  specific  substances  should  be  added  as  groups  (rather  than 
separate  entries),  except  for  PFAS.  Overall,  stakeholders  were  uncertain,  or  had  no 
opinion  on  this,  given  the  varying  potencies  of  specific  substances  within  broad 
groups,  the  threat  of  losing  the  granularity  over  specific  substance  risks,  or  the 
required modes of action on substances. 

  For  groundwater,  results  across  consultation  activities  were  coherent  and  indicated 
that  PFAS  should  be  added  to  GWD  Annex  I  with  a  standard  0.10  ug/l.  Also, 
pharmaceuticals  (Carbamaxepine  and  Sulfamethocazole)  should  be  added  as 
individual  substances  Annex  I.  Consultation  activities  indicated  that  stakeholders 
agree  that  metabolites  from  pesticides  should  be  added,  however  there  were 
conflicting  observations  regarding  whether  the  addition  should  be  to  Annex  I  or 
Annex II. 

  There was a strong recognition from stakeholders that upstream measures in the form 
of  the  precautionary  principle  and  the  application  of  polluter  pays  principles  are 
needed to be considered when addressing risks of contaminants of emerging concern. 

  Finally, stakeholders indicated that the revision of pollutants and their EQS’s need to 
be coherent with other directives (e.g. DWD, UWWTD and agricultural policies), and 
there must be improvements of data collection and transparency of monitored data. 

4.1. 

Impact Assessment Roadmap 

Feedback  on  the  Impact  Assessment  Roadmap  was  provided  by  19  stakeholders,  with  one 
document not  included in the analysis due to  duplication. 10 responses  were from  business 
associations,  whereas  2  were  from  EU  citizens,  NGOs,  company/business  organization  and 
‘other’. One response was received from a public authority. The key themes in the feedback 
included: 

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  Stakeholders  noted  that  stronger  coherence  between  the  WFD  and  other  EU 
legislation is required- in particular with EQSD (n=2, other, public authority), GWD 
(n=2,  other,  public  authority),  DWD  (n=3,  Public  authority,  other,  business 
association),  agricultural  policy  (n=4,  other,  business  association,  company/business 
organization, public authority), and REACH (n=1, other); 

  Stakeholders also noted the need for stronger upstream prevention and control to force 

prevention at source (n=4, NGO, 3 Business associations); 

  More  focus  on  substances  of  emerging  concern  is  needed,  in  addition  regarding 
pollutant  mixtures 
(n=3,  NGO,  Company/business  organization,  Business 
association),  in  addition  to  pharmaceuticals,  (micro)  plastics  and  PFAS  (per  and 
polyfluoroalkyls) (n=1, other); 

  Local  conditions  should  be  considered  when  establishing  EQS  values-  particularly, 
Priority Substances should be carefully assessed to see if there is a risk to the EU as a 
whole, or only of local relevance (n=5, 4 Business associations, 1 company/business 
organisation); 

  A number of stakeholders reiterated the need to identifying new Priority Substances 

and setting their EQS based on sound science (n=2, Business associations); 

  Transparency-  2  stakeholders  noted  the  need  for  greater  transparency  relating  to 

monitoring data (NGO) and dossier outputs (Business association). 

5.  OPEN PUBLIC CONSULTATION 

Here  we  present  the  most  relevant  results  from  the  OPC,  identifying  the  percentage  of 
responses in relation to each answer.  

5.1.  Respondents’ profiles 

Although in total 151 respondents filled in the questionnaire during the consultation period, it 
should be noted that the number of responses to each specific question has varied throughout 
the survey. Due to the non-mandatory nature of most questions, it is typical that fewer than 
151 responses have been provided to certain questions. From the 151 respondents, Germany 
(n=40; 26%), Belgium (n=25; 17%) and France (n=19; 13%) were the primary countries of 
origin.  In  total,  from  the  151  respondents  144  (95%)  were  from  EU-27  countries.  The 
remaining  7  were  from  Morocco  (n=1),  Norway  (n=2),  Switzerland  (n=1),  and  the  United 
Kingdom  (n=3).  The  most  common  stakeholders  to  reply  (Figure  A2.1)  were  business 
associations  (n=34;  23%),  EU  citizens  (n=33;  22%)  and  companies/business  organisations 
(n=29;  19%).  Stakeholders  who  selected  the  ‘other’  option  (n=16;  11%)  and  provided  a 
response  included:  civil  society  organization  (n=1),  MS  competent  authority  (n=3),  water 
services and utility company (n=1), international organization (n=2).  

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Figure A2.1: Stakeholder types 

Figure  A2.2  provides  an  overview  of  the  scope  of  each  stakeholder  type.  As  shown,  the 
citizens,  NGOs,  Public  Authorities, 
majority 
Academics/research  institutions  and  consumer  organisations  had  a  national  scope.  The 
majority of company/business organisations had an international scope.  

associations,  EU 

business 

of 

Figure A2.2: Stakeholder scope 

In relation to organisation size, the majority of respondents stated they were from large (i.e. 
>250  employees)  (n=46;  40%),  followed  by  those  from  micro  (n=30;  26%),  small  (n=25, 
22%) and medium (n=15; 13%) organisations.  

Finally, stakeholders indicated their sector of activity (Figure A2.3). The highest number of 
responses  indicated  activity  in  the  water  industry  and/or  management  (n=30;  21%),  and 
biodiversity and/or environment (n=26; 18%). Stakeholders who responded ‘other’ included 
mining and extractive industries (n=4), education (n=1), paper industries (n=1).  

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Figure A2.3: Stakeholder sector of activity 

5.2. 

Presence of substances 

Stakeholders  were  asked  how  concerned  they  were  with  the  presence  of  pharmaceuticals, 
microplastics,  substances  from  household  items,  pesticides,  industrial  chemicals  and  metals 
in both surface and groundwaters. Stakeholders were asked to rate their concerns on a scale 
of  1  (not  at  all)  to  5  (very  much).  For  both  surface  waters  and  groundwaters,  stakeholders 
designated  a  minimum  average  score  of  3.5  (for  groundwater  microplastics)  for  the 
substances  listed,  indicating  that  stakeholders  are  concerned  about  the  presence  of  all 
substances listed. Figure A2.4 below outlines the average scores for each substance. 

Figure A2.4: Responses to the question: “How concerned are you about the presence of 
these  substances  in  European  surface  water  (L)  and  groundwater  (R)  bodies?  Please 
rate your concerns on a scale of 1 (not at all) to 5 (very much)” 

5.3.  Regulatory measures to combat water body pollution 

Stakeholders were asked which regulatory measures contributed to WB pollution, and to rate 
their contribution on a scale of 1 (not at all) to 5 (very much). The average rating for each of 
the  measures  listed  was  above  3.0,  indicating  that  stakeholders  harbored  at  least  some 
concern of their contribution to water pollution. As shown in Figure A2.5 below, “lack of the 

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use  of  ‘precautionary’  and  ‘polluter  pays’  principles…”,  “lack  of  investment/incentives  for 
emission  reduction”  and  “lack  of  incentives  to  take  control  measures  at  the  source  of 
pollution”  all  received  an  average  score  of  3.8,  whilst  the  last  measure  listed  received  the 
greatest number of ‘5’ responses (n=61, 41%). 

Figure A2.5: 
Responses to the 
question: 
“Regarding 
regulatory 
measures and 
their 
implementation, 
in your opinion, 
to what extent do 
the following 
issues contribute 
to surface water 
and groundwater 
pollution? Please 
rate each option 
below on a scale 
of 1 (not at all) to 
5 (very much)” 

5.4.  EU actions/strategies to address pollution 

Stakeholders  were  asked  to  outline  which  policy  actions/  strategies  could  more  effectively 
address  surface  and  ground-  water  pollution.  Three  options  were  presented,  where 
stakeholders could indicate on a scale of 1 (not at all) to 5 (very much) which options should 
be improved. As shown in Figure A2.6 below, option c ‘improve collection of data on new 
pollutants…’ received the highest average score of 4.2. Stakeholders elaborated in open text, 
stating  that  there  is  a  need  for  more  transparent,  publicly  accessible  data  (n=6)  to  assist  in 
making science-based decision making. 

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Figure  A2.6:  Responses  to  the  question:  What  in  your  opinion  should  the  European 
Commission  improve  to  ensure  its  policy  actions  /  strategies  address  more  effectively 
surface and groundwater pollution? Please rate each option below on a scale of 1 (not at 
all) to 5 (very much) 

Finally,  according  to  the  OPC  respondents,  the  following  issues  were  not  included  in  the 
OPC-questionnaire, but should be addressed by the European Commission:  

  Need to develop a shared list of priority and watch list substances across policies: water 
policy  (groundwater,  surface  water,  marine  MFSD),  CAP,  sewage  sludge,  Fertilising 
Products (FPR), REACH, IED.  

  Overall, a more strict and integrated system to reduce emissions of harmful substances 
should  be  implemented,  by  connecting  REACH,  IED,  UWWTD  and  WFD,  via 
restrictions of emissions & substances of very high concern (SVHC's). 

  Water  protection  must  be  pursued  according  to  the  precautionary  and  polluter  pays 
principles.  End-of-pipe  solutions  are  neither  a  holistic  nor  a  sustainable  solution; 
extended producer responsibility (EPR) must be applied to cover costs. 

  Addition of so-called ‘non-relevant’ metabolites (nrMs) of pesticides to Annex I of the 
GWD,  together  with  relevant  metabolites.  The  pesticides  total  value  should  include 
nrMs. 

  Data collection for additional pollutants should be driven at the EU level. 
  Need  to  enhance  the  protection  of  groundwater  as  an  ecosystem  (including  better 
protection  of  organisms  responsible  for  self-purification  of  groundwater)  in  line  with 
recital  20  of  GWD,  and  inclusion  of  non-material  indicators  like  biology  and 
temperature. 

6.  TARGETED STAKEHOLDER CONSULTATION - SURVEY 

6.1.  Respondents profiles 

All 124 respondents provided replies to the ‘About you’ section of the survey. As seen in the 
figure  below,  the  highest  number  of  respondents  came  from  Germany  (n=31).  This  was 
followed by Belgium (n=22), Czech Republic (n=9), and France (n=8). Thereafter, Member 
State representation was generally lower. Figure A2.7 shows all EU-27 represented countries. 
There  were  also  several  non-EU  respondents,  including  from  the  United  States  (n=1), 
Norway (n=1), Switzerland (n=4) and Turkey (n=1). 

As  a  follow-up,  respondents  indicated  the  country  where  their  organisation  is  located.  The 
trends seen in Figure A2.8 do not significantly deviate from Figure A2.8: the most significant 
number  of  respondents  identified  their  organisations  based  in  Germany  (n=33),  followed 
again by Belgium (n=25), Czech Republic (n=8), and France (n=8). Respondents could only 
choose EU27 countries as their organisation base or were given the opportunity to write the 
answer in. Three respondents noted that their organisation was based in Switzerland, and one 
in Turkey. 

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FigureA2.7: Responses to: Country of Origin 

Figure A2.8: Responses to: Which country are you or your organisation based? 

When  asked  about  the  scope  which  the  respondents  organizations  covered,  the  majority 
indicated  working  at  a  national  scale  (n=64).  A  similar  number  of  respondents  indicated 
working  at  regional  (n=26)  or  EU  wide  level  (n=20),  and  a  significant  number  (n=10)  also 
indicated  working  for  organisations  with  an  international  scope.  Five  respondents  indicated 
‘Other’  scope,  of  which  three  expressed  that  they  worked  at  regional  scales  (naming  the 
region of their Member State). 

Responses did not indicate a wide distribution of stakeholder groups. Most of the participants 
represented MS competent authorities (n=46), followed by business associations (n=31) and 
academic/research  institutions  (n=13)  (Figure  A2.9).  A  number  of  respondents  identified 
themselves  as  ‘Other’  (n=11).  Those  that  provided  details,  identified  themselves  as 
‘Candidate  country  competent  authority’  (n=1),  ‘Non-profit  association  of  expert 

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organisations’  (n=1),  ‘Competent  authority  for  water’  (n=1)  and  ‘Groundwater  Expert 
Consultant’ (n=1). 

Figure A2.9: Responses to: I am giving my contribution as… 

Finally, respondents were asked to indicate the sector they represent (Figure A2.10). Here the 
distribution of representation was wider, with biodiversity and/or environment and the water 
industry  sectors  having 
the  highest  representation  (n=34  and  n=33  respectively). 
Interestingly,  a  number  of  respondents  (n=20)  indicated  ‘Other’  sectors.  Two  respondents 
indicated  to  be  working  for  national  water  authorities,  three  indicated  working  in 
groundwater monitoring and protection, three indicated working in water and environmental 
monitoring of pollutants and hazardous substances, and one indicated working in petroleum 
refineries. The sectors of energy, investment  and finance, pharmaceuticals, plastics, textiles 
and urban planning had no respondents. 

Figure A2.10: Responses to: Please indicate the sector(s) you are active in: 

to  surface  water,  groundwater  and 
Respondents  had 
complementary  questionnaires.  They  could  choose  to  answer  as  many  as  they  felt  familiar 

the  opportunity 

to  respond 

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with. A total of 101 indicated an interest in answering surface water questions, with 65 and 
78 participants selecting groundwater and complementary questionnaires, respectively. Note 
that  this  does  not  represent  the  total  number  of  responses  received  per  question,  as 
respondents were not obliged to answer any questions. 

6.2. 

Surface water 

6.2.1.  Addition of candidate Priority Substances 

For  all  of  the  candidate  substances  listed,  stakeholders  indicated  a  preference  to  including 
them as Priority Substances (Figure A2.11). Regarding whether specific substances should be 
added  as  groups  (rather  than  separate  entries),  the  responses  did  not  present  such  a  clear 
preference  (Figure  A2.12).  Macrolide  antibiotics  (n=19;  31%)  and  PFAS  (n=34;  52%) 
received  a  greater  number  of  ‘yes’  responses  than  ‘no’-  indicating  a  preference  to  add 
substances  as  a  group  with  a  set  of  joint  EQS  values.  Conversely,  Neonicotinoids  (n=24; 
38%)  and  Pyrethroids  (n=23;  36%)  received  a  greater  proportion  of  ‘no’,  indicating  a 
preference not to group such substances. 

Figure  A2.11:  Responses  to:  Should  the  substances  in  the  table  below  be  added  as 
Priority Substance? 

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Figure A2.12: Responses to: Please indicate whether you think the substances should be 
added as groups. 

When  asked  to  estimate  the  significance  of  economic,  health,  social  and  environmental 
benefits / impacts resulting from the inclusion of new candidate PS, the respondents generally 
found all impacts to be positive (i.e. rated at minor, moderate or major benefit). Benefits from 
improved surface water quality, lower risk of damage to natural resources and benefits from 
improved  environment  and  human  health  protection  were  valued  most  (Figure  A2.13).  The 
impacts  of  new  candidate  substances  on  the  quality  of  process  water  for  agriculture  and 
industry  received  the  greatest  number  of  ‘no  benefit’  responses  (n=8;  16%).  Impacts 
regarding employment opportunities were identified as being largely unknown, indicated by 
the large share of ‘I do not know/no opinion’ responses (n=31; 57%). 

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Figure  A2.13:  Responses  to:  Can  you  please  provide  your  estimate  of  significance  of 
economic,  (human)  health  and  social,  as  well  as  environmental  benefits/  impacts 
resulting from the inclusion of new candidate priority substances? 

For the majority of benefits listed, respondents were unable to provide cumulative estimates 
of  their  potential  economic,  health,  social  or  environmental  impacts.  Lower  production  and 
maintenance costs through the availability of cleaner raw water received the fewest number 
of ‘I do not know/no opinion’ responses, where 7% (n=3) estimated costs above €10,000,000 
and 2% (n=1) at €501,000-€1,000,000.  

6.2.2.  Change of status of the “eight other pollutants” 

DDT received the greatest number of ‘fully added as a PS’ responses (n=15; 23%), followed 
by  Trichloroethylene  (n=6;  10%)  and  Tetrachloroethylene  (n=5;  8%).  Isodrin,  Endrin, 
Dieldrin and Carbon tetrachloride all received 38% of responses for them to be removed from 
EQSD entirely, whilst DDT received the greatest number of responses to retain it as a ‘other 
pollutant’ (n=18; 28%). 

6.2.3.  Revision of existing EQS 

Stakeholders  were  asked  whether  they  believed  the  Annual  Average  (AA),  Maximum 
Allowable Concentration (MAC), and/or biota EQS values are too high, too low, or assigned 
correctly to a selection of Priority Substances. Here, a summary of the responses (excluding 
‘I do not know/ no opinion’ answers) is presented. 

Regarding  AA  concentrations,  Chlorpyrifos  (n=11;  20%)  and  Diuron  (n=  6;  11%)  received 
the greatest number of ‘too high’ responses, whilst Nickel (n=14, 25%) received the greatest 
number  of  ‘correct’  responses.  PAHs  (based  on  Benzo[a]pyrene)  (n=14;  30%)  and 
Fluoranthene (n=12; 27%) received the greatest number of ‘too low’ responses. 

Regarding  MAC,  the  majority  of  responses  indicated  that  Chlorpyrifos  (n=15;  27%)  and 
Diuron  (n=14;  25%)  values  were  ‘too  high’,  EQS  values  for  MAC  are  ‘correct’  for  Nickel 
(n=13; 25%) and ‘too low’ for Heptachlor and Heptachlor epoxide (n=6; 12%). 

Finally, biota concentrations were regarded as ‘too high’ for PAHs (n=6; 12%), ‘correct’ for 
Hexachlorobenzene  (n=5;  10%),  Hexachlorobutadiene  (n=4;  9%),  Mercury  and 
its 
compounds  (n=5;  10%),  and  ‘too  low’  Brominated  diphenyl  ethers  (n=10;  20%)  by  the 
majority of respondents. 

6.2.4.  Deselection of existing Priority Substances 

Stakeholders were asked to comment on which existing PS no longer pose an EU-wide risk. 
Except  for  Hexachlorobenzene,  all  the  substances  identified  for  deselection  during  the 
technical  work80  received  a  greater  number  of  ‘yes’  (deselect)  than  ‘no’  (keep  as  PS) 
responses. Alachlor received the greatest number of ‘yes’ responses (n=34;  54%), followed 
by Chlorfenvinphos (n=32; 53%). 

80 Substances targeted for deselection at the time: Alachlor, Chlorfenvinphos, Simazine, Benzene, Hexachlorobenzene and 
Hexachlorobutadiene 

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For  all  substances  listed,  the  majority  of  responses  indicated  that  respondents  ‘don’t 
know/have  no  opinion’  regarding  the  economic  benefits  of  deselection.  All  substances 
received  a  greater  proportion  of  ‘yes’  responses  than  ‘no’,  with  Alachlor  (n=25;  45%), 
Chlorfenvinphos  (n=24;  44%)  and  Simazine  (n=22;  41%)  receiving  the  greatest  number  of 
responses indicating economic benefits of deselection. 

6.3.  Groundwater 

6.3.1.  Additions to GWD Annexes 

Stakeholders were asked to select which option for adding PFAS to the GWD annexes would 
be preferred. Option A (Add 10 PFAS with a ‘group of 10’ (i.e. ‘Sum of PFAS’) standard of 
0.10 µg/l to Annex I of the GWD (based on DWD recast)) received the greatest proportion of 
responses (n=17; 46%), followed by Option F (None of the above / Business as usual (BAU)) 
(n=9; 24%). Option B (Add 10 PFAS with a ‘group of 10’ standard (i.e. ‘Sum of PFAS’) to 
Annex  I  of  the  GWD  but  with  a  different  GW  QS  to  Option  A)  garnered  the  lowest 
preference by stakeholders (n=1; 3%). 

In relation to adding Carbamazepine and Sulfamethoxazole to the GWD annexes, Option A 
(Add  the  two  named  pharmaceuticals  to  Annex  I  with  the  following  indicative  GWQS: 
Carbamazepine  0.5  µg/l;  Sulfamethoxazole  0.1  µg/l)  received  the  greatest  number  of 
responses (n=10; 30%), followed by Option E (n=9; 27%). Option D (Add pharmaceuticals 
as a  group to  Annex  I,  but  with  a different  value for the  GWQS  to  Option  C) received the 
lowest number of responses (n=0). 

Finally,  responses  for  adding  harmful  breakdown  products  (metabolites)  from  pesticides 
(nrMs)  to  the  GWD  Annexes  indicated  that  Option  A  (Add  the  16  harmful  breakdown 
products (metabolites) from pesticides (nrMs) to Annex I with individual GWQS of 1 µg/l for 
each substance) (n=13; 37%) was the preferred option. 

6.3.2.  Benefits/impacts 

Stakeholders  were  asked  to  identify  which  economic,  (human)  health  and  social,  and 
environmental  impacts  related  to  groundwaters  provided  the  most  significant  benefits.  The 
results  are  shown  in  Figure  A2.14.  Stakeholders  identified  ‘benefits  from  improved  water 
quality’ and ‘benefits from improved environment and human health protection’ as providing 
the  greatest  positive  impacts  (n=12;  35%),  followed  by  ‘lower  production  and  maintenance 
costs through availability of cleaner raw water, reducing pre-treatment needs / avoided costs 
of  drinking  water  (pre)treatment  as  a  result  of  improved  quality  of  groundwaters  used  for 
drinking water abstraction’ (n=11; 32%). Very few monetised estimates could be provided by 
respondents. Those which were provided, estimated high costs above €10,000,000 related to 
lower  risk  of  damage  to  natural  resources  and  lower  production  and  maintenance  costs 
through  availability  of  cleaner  raw  water,  receiving  4%  (n=1)  and  12%  (n=3)  of  total 
responses respectively. 

EN 

  EN 

 
 
Figure  A2.14:  Responses  to:  Can  you  please  provide  your  estimate  of  significance  of 
economic, (human) health and social, as well as environmental benefits/ impacts? 

6.4.  Monitoring, reporting and administrative streamlining options 

6.4.1.  Guidance documents 

Respondents were asked to rank on a scale of 1 - not at all - to 5 - extensively used to inform 
decisions - which past guidance documents (of relevance to the legislation under the scope of 
the  Impact  Assessment)  have  been  used  in  their  MS.  Guidance  related  to  ‘risk  assessment’ 
were deemed the most extensively used (average score of 4.6), closely followed by ‘guidance 
on  reporting’,  ‘guidelines  on  water  quality  analytical  methods’  (4.3)  and  ‘Guidelines  on 
for  public  participation  and 
Environmental  Quality  Standards’ 
transparency’  received  the  lowest  average  score  of  3.2,  indicating  that  they  are  not 
extensively used to inform decisions.  

‘Guidelines 

(4.2). 

Stakeholders were also asked which additional guidance documents would be deemed useful 
(Figure A2.15). ‘Guidelines on the characterization on groups/mixtures of pollutants and their 
possible toxicity’ and ‘Guidelines on applying innovative methods in monitoring procedures’ 
received  the  highest  average  scores  and  highest  number  of  ‘very  useful’  responses  (n=25; 
53% and n=26; 55% respectively). 

EN 

  EN 

 
 
 
Figure A2.15: Responses to: In your opinion, how useful would the following additional 
guidance documents be? 

6.4.2.  Surface Water Watch List 

Respondents voted the increase in monitoring frequency of substances in the  Surface Water 
Watch  List  as  the  most  effective  method  for  improving  the  risk  response  and  management 
(average score of 3.2). However, the polarity of the responses received for this measure was 
also  significant.  In  total,  26%  (n=12)  voted  the  measure  as  non-effective  (rating  1)  and 
another  28%  (n=13)  rated  it  as  highly  effective  (rating  5).  Respondents  that  voted  the 
measures as highly effective represented mostly MS authorities (n=8) and academic research 
(n=2),  while  those  that  related  the  measures  as  non-effective  represented  a  mix  of  business 
associations (n=3), companies (n=2) and MS competent authorities (n=3). A similar polarity 
exists for the measure of increasing the frequency in which WL substances are incorporated 
as  Priority  Substances  (30%  rated  1,  30%  rated  5).  The  main  consensus  is  evident  for  the 
possible  increase  in  reporting  frequency  obligations,  for  which  half  the  respondents  very 
clearly indicated that they did not see such a measure improving the risk response. 

6.4.3.  Harmonisation of RBSP thresholds 

All  measures  presented  to  assist  in  the  harmonization  of  the  RBSP  thresholds  had  very 
similar  rating  scores  around  3.2.  The  highest  rated  (average  3.3)  was  to  provide  a 
recommended  range  for  thresholds  for  reference  RBSPs  under  the  EQSD,  while  the  lowest 
rated  (3.0)  was  the  guidance  on  monitoring  needs  for  RBSPs.  Generally,  all  measures  had 
very similar distributions in response ratings, indicating that there may be a combination of 
approaches  that  may  assist  in  achieving  the  desired  harmonization  rather  than  just  one 
specific measure. 

6.4.4.  Data management 

Stakeholders were asked to rate (on a scale of 1 (not at all) to 5 (very much)) measures aimed 
at  achieving  data  management,  transparency  and  utilization  were  important  from  their 

EN 

  EN 

 
 
 
perspective. ‘Standardise data collection and reporting methods to improve comparability of 
data’  was  noted  as  the  measure  with  the  highest  average  rating  of  4.1,  closely  followed  by 
‘Optimise the coordination of data-sharing practices with other policy sectors’ (average rating 
of 4.0). 

6.5.  Targeted stakeholder consultation - workshops 

Here  we  present  the  most  relevant  results  from  the  two  targeted  workshops.  The  primary 
objective  of  the  workshops  was  to  inform  stakeholders  of  a  set  of  proposed  policy  options 
and  gather  their  inputs  relating  to  these  options.  The  first  sessions  of  both  workshops  split 
participants based on their expertise relating to surface waters and groundwaters. The second 
session of the day  reconvened  all participants  to  discuss measures  relating to  digitalisation, 
administrative streamlining and better risk management options. The key outcomes of these 
distinctive sessions are presented in turn below. 

6.5.1.  Surface water session 

The first topic area theme ascertained which candidate substances stakeholders would like to 
see  added  to  the  PS  list  as  separate  entries,  or  added  as  groups  of  substances.  Estrogenic 
hormones  (n=56;  62%),  PFAS  (n=61;  73%)  and  neonicotinoids  (n=40;  52%)  all  received  a 
majority of votes by stakeholders indicating a preference to  add as groups. The majority of 
participants noted that antibiotics should be added as individual substances (n=38; 46%). The 
second topic area sought stakeholder views on amendments to EQS for existing PS and other 
pollutants. Stakeholders noted that EQS for PBDEs (n=27; 41%), mercury (n=22; 33%) and 
heptachlor (n=19; 29%) in particular, should be reviewed. The final topic area looked at the 
potential of deselecting existing PS. Stakeholders here showed a preference to deselecting all 
the  listed  substances  (Alachlor,  Chlorfenvinphos,  Simazine,  Benzene,  Hexachlorobenzene 
and Hexachlorobutadiene) (n=28; 55%). 

6.5.2.  Groundwater session 

Topic  area  one  of  the  session  discussed  adding  PFAS  substances  to  Annex  I  or  II  of  the 
GWD.  Stakeholders  showed  preference  to  adding  PFAS  to  Annex  II  (to  allow  MS  to  deal 
with  local  conditions)  (n=22;  42%).  Participants  notes  that  if  PFAS  quality  standards  were 
listed under Annex I, standards should be established at 0.10 µg/l (n=30; 52%). The second 
topic area asked stakeholders for their views on adding pharmaceuticals to Annex I or II of 
the  GWD-  with  67%  (n=39)  of  participants  showing  preference  to  add  these  as  individual 
substances.  Finally,  topic  area  three  focused  on  the  addition  of  pollutants  consisting  of 
degradation products from pesticides (nrMs) to Annex I or II of the GWD. The majority of 
participants stated a preference to add nRMs to Annex II (n=29; 56%).  

In  targeted  stakeholder  feedback  industry  stakeholders  indicated  that  a  GWQS  for  the  16 
nrMs  of  9  µg/l  could  be  calculated  using  a  Threshold  of  Toxicological  Concern  approach 
(99), whereas other stakeholders noted that the EFSA methodology explicitly states that this 
approach should not be used for substances for which EU food/feed legislation requires the 
submission  of toxicity data or when sufficient data are available for a  risk assessment.  The 
position  from  the  non-industry  stakeholder  was  that  Europe  wide  legislation  is  needed  to 
ensure  that  the  levels  of  nrMs  reduced  in  groundwater  and  that  more  sensitive  biota  in 

EN 

  EN 

 
 
groundwater  ecosystems  were  protected.  MS  and  representatives  from  the  drinking  water 
industry  states  that  there  is  widespread  detection  of  nrMs  in  groundwater  and  that  this 
situation needs to be addressed, while noting that the GWD requires that inputs of hazardous 
substances need to be limited in their entry into groundwater, and nrMs fall within this group. 
Consequently, further regulation of the entry of nrMs to groundwater is needed to deliver on 
this requirement. 

6.5.3.  Session on monitoring, reporting and administrative streamlining options 

This  session  centred  on  three  topics  that  aimed  to  maximize  the  (cost)  effectiveness  of 
procedures,  namely:  monitoring  approaches;  risk  assessment  and  the  translation  into  risk 
management;  and  data  management.  Regarding  monitoring  approaches,  stakeholders 
provided  contrasting  views  on  guidelines  to  alternative  monitoring  methods  -  noting  that 
innovative  approaches  (such  as  effect-based  monitoring)  could  improve  freshwater  quality 
yet  may  result  in  a  greater  monitoring  burden  to  actors.  In  the  topic  area  two  discussions, 
stakeholders noted that deriving harmonized EQS values for RBSPs were challenging due to 
changes in values from knowledge development and a lack of current harmonised approaches 
between MS. Finally, on data management stakeholders noted that guidelines to standardise 
data collection and reporting formats could be beneficial. 

EN 

  EN 

 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? PRACTICAL IMPLICATIONS OF THE INITIATIVE 

1.  SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Option  

Description   Amount  

Comments  

Direct benefits  

Improved 
surface water 
quality 

Additions: total benefits not quantified for EU27, but: 

- 

- 

- 

- 

- 

- 

- 

- 

- 
- 

Avoided/reduced environmental impacts and potential toxic effects on aquatic species. E.g. 
Carbamazepine (impacts on fertility and reproduction);ibuprofen potential toxic effects for some 
aquatic species including fertility effects ; Nicosulfuron has aquatic toxicity and concerns over 
carcinogenicity as a secondary poisoning. Diclofenac potential toxic effects on avian populations 
via surface water species. Estrone E1, 17- Beta estradiol (E2), Ethinyl estradiol (EE2) are 
associated with chronic ecosystem level impacts from exposure to hormones and EDC. PFAS has a 
widespread and very long-lasting environmental effects while Bisphenol A as an endocrine causes 
disrupting chemical for aquatic organisms. Triclosan is toxic for aquatic organisms particularly 
larvae and fish eggs. Acetamiprid, Clothianidin, Imidacloprid, Thiacloprid, Thiamethoxam 
Bifenthrin, Deltamethrin Esfenvalerate and Permethrin are associated with toxic aquatic effects 
against invertebrates, arthropods, and crustaceans with wider environmental concerns for terrestrial 
pollinators. Glyphosate is associated with harm to aquatic environments given the very high usage 
rates and risks for loss to water. 
Avoided/reduced human health impacts via reduced exposure through drinking water, from 
specific exposure to Neonicotinoids, EDC  and (potential) carcinogenic effects. E.g. Annual costs 
related to endocrine disruptors exposure were estimated to be €163 billion (above €22 billion with 
a 95% probability and above €196 billion with a 25% probability) (84).. Protection against AMR 
has clear societal benefits and avoided costs to healthcare from protection against the development 
of AMR : estimated AMR costs in EU €1.5 billion per year in healthcare costs and productivity 
losses81 (64) (101) (102). 
The long term benefit of adding antimicrobials and silver onto the lists is limiting antimicrobial 
resistance, allowing current and future antimicrobials to retain their positive effect on patients.  
Assuming that between 1-5% UWWTPs would have to deploy reverse osmosis, costs for EU 
taxpayers would range between €2,184,600 and €109,230,000.  
Benefits /avoided costs of reducing AMR from antibiotics in relation to infections from multi-drug 
resistant bacteria are estimated to add up to a total of €41 billion (2014 data). 
The EU benefits / avoided costs of removing silver to reduce the risk for AMR and other risks are 
estimated to range between €20 to €41 billion (2014 data). 
Avoided/reduced impacts on pollinators and agriculture. E.g. across Europe, crop pollination by 
insects accounted for approximately €14.6 billion annually (103). 
Avoided costs of water treatment for drinking water, agriculture and industry E.g. in 2015, 
approximately €0.5 billion was spent annually to remove pesticides in wastewater treatment plants 
(WWTP) in Europe (104). 
Economic benefits for aquaculture from improved food quality  
Innovation for development of alternative chemicals and technologies (e.g. Bisphenol A) 

Amendments: total benefits not quantified for EU27, but: 

- 

- 

- 

- 
- 

Updated EQS based on new science and re-appraisal of risk would provide more appropriate 
protections (all substances)  
Improved protections for human health particularly in relation of POP substances, issues around 
bioaccumulation (dioxins and furans, chlorpyrifos, hexachlorobutadiene, HBCDD), EDC (diuron, 
chlorpyrifos), exposure to chronic pollutants (mercury, nickel). E.g. chlorpyrifos and PBDE as 
endocrine disruptors were associated with attention deficit hyperactivity disorder (ADHD) and 
with other cognitive deficiencies. The productivity loss caused by these disorders is estimated to be 
€124 billion annually in EU. Additionally, prenatal exposure to chlorpyrifos across the EU would 
cost an additional €21.4 billion in social costs. The neurotoxicity of chlorpyrifos is estimated to be 
70 to 100% according to the epidemiological and toxicological evidence, which corresponds to a 
social cost of €46.8 billion and €195 billion annually in the EU (100). It was also estimated that the 
cognitive deficits caused by chlorpyrifos and methylmercury would cost the EU €177 billion and 
€9.89 billion, respectively 
Reduced environmental concentrations, improved environmental protections for ecosystem 
services (cypermethrin, nonylphenols, PAHs)  
Avoided health costs for aquaculture (cypermethrin, tributyltin, mercury, nickel) 
Cost savings and efficiencies: the proposed EQS is less stringent for heptachlor/heptachlor oxide, 
hexachlorobenzene, PBDEs and fluoranthene, meaning resources can be reallocated and costs 
saved from measures no longer needed. 

81 Based on an exchange rate of 1 EUR = 1.09 USD 

116 

 
 
 
 
                                                           
I. Overview of Benefits (total for all provisions) – Preferred Option  

Description   Amount  

Comments  

Improved 
groundwater 
quality 

Other eight pollutants: total benefits not quantified for EU27, but:  

- 

- 

Three of the four cyclodiene pesticides (aldrin, dieldrin, endrin;,isodrin is an isomer of aldrin) are 
listed as POPs under the Stockholm Convention and have been banned in the EU for many years. 
The rate of EQS exceedance suggests environmental risk is low, and benefits of continued 
monitoring may be limited. However, monitoring data are needed anyway under the POPs 
Regulation and could inform decontamination measures. 
DDT is also a recognised POP. Use in EU has long since ceased and rate of EQS exceedance is 
extremely low. Maintaining the monitoring time-series would support the tracking of DDT in the 
environment, and link with monitoring of, e.g. imported foods. 

While tetrachloroethylene and trichloroethylene are still in use, and health concerns well founded, the 
monitoring data shows exceedances in only 6 and 3 surface water bodies out of 97,000 suggesting a very low 
environmental risk at present. However, these substances are still of concern in groundwater and drinking 
water, and in marine waters. 
Deselection: total benefits not quantified for EU27, but 

  Deselection of substances that no longer represent an EU-wide risk could free up resources for 
reallocation by Competent Authorities to the monitoring and/or management of emerging 
pollutants, including watch-list substances and the new priority substances. 
The pesticides alachlor, simazine and chlorfenvinphos are clearly hazardous but no longer 
approved for use; the risk of exposure is very low and would be expected to remain so. 

 

PFAS: total benefits not quantified for EU27, but 

 

Lower risk of (irreversible) damage to natural resources such as groundwater and connected 
surface waters and ecosystems (i.e. reduced impact on sensitive water bodies such as wetlands and 
rivers, and fish);  

  Avoided illness / death through low level exposure through drinking water / food to PFAS: 

estimated the annual health expenditure due to kidney cancer €12.7 to €41.4 million in the EEA 
countries; hypertension in the EEA countries estimated at €10.7 to 35 billion per year (based on 
207.8 million population); 
Improved availability of clean raw groundwater for abstraction and lower production and 
maintenance costs (for drinking water, irrigation, livestock watering) 

 

  Benefits to sectors requiring a high quality of groundwater such as bottled water and other water 

uses (angling, swimming, etc).  

  Avoided costs of (pre)treatment as a result of improved quality for potable water and process water 
for drinking water supply, agriculture and industry (GAC treatment costs € millions per site) in the 
case of source control and pathway disruption measures 

  Reduced energy costs and related process costs for wastewater treatment to tackle PFAS (in the 

case of source control and pathway disruption measures) 
 
Increased knowledge and understanding of the risks of PFAS posed to the water environment. 
  Consistent approach to data collection at EU level and improved knowledge (more data collected) 

on the impact of  
PFAS. 

Pharmaceuticals: total benefits not quantified for EU27, but 

  Reduced pollution of groundwater and connected aquatic ecosystems with reduced impact on 

 

sensitive habitats.  
Increased reuse and recovery of pharmaceutical-free materials (e.g. use of sludge, treated 
wastewater).  

  Reduction in AMR likely to be small (mainly covered by baseline measures) - Reduction in AMR 

 

 

 

through control of anti-biotic use (costs avoided of €1.5 billion to the EU) 
The long term benefit of adding antimicrobials onto the lists is limiting antimicrobial resistance, 
allowing current and future antimicrobilal to retain their positive effect on patients. 
Small increase in well-being from reduced risk of chronic ingestion in drinking water / improved 
ecosystem health.  
Positive impact on shellfish and fisheries where groundwater inputs to rivers and estuaries is 
significant 

  Reduced energy, carbon emissions and chemicals use associated with reduced treatment of 

 

drinking water (in the case of source control and pathway disruption measures) 
Improved efficiency - specific risks to groundwater are investigated and dealt with locally rather 
than through EU wide schemes which may be too high level to be effective 

  Consistent approach to data collection at EU level and improved knowledge (more data collected) 

on the impact of these two pharmaceuticals.  

nrMs: total benefits not quantified for EU27, but 

  Reduced risk of damage to natural resources such as groundwater and connected ecosystems  
  Benefits to sectors requiring a high quality of groundwater such as bottled water or aquaculture 

and other water uses (angling, swimming, etc.).  
Increased availability of clean raw groundwater for abstraction (for drinking water, irrigation, 

 

117 

 
 
 
 
I. Overview of Benefits (total for all provisions) – Preferred Option  

Description   Amount  

livestock watering) 

Comments  

  Avoided costs of (pre)treatment as a result of improved quality for potable water and process water 

for agriculture and industry 
Increased ecosystems services from groundwater biota not impacted by nrMs and cocktail effects 

 
  Climate change impacts through reduced energy use (e.g. due to changes to wastewater and 

 

drinking water treatment processes) (in the case of source control and pathway disruption 
measures).   
Increased knowledge and understanding of the risks of metabolites of pesticides posed to the water 
environment. 
plus reduced impacts on groundwater biota  

 
  Consistent approach to data collection at EU level and improved knowledge (more data collected) 

 
 

 

 

on nrMs in groundwater leading to better understanding of risks. 
Improved knowledge and better data for use during pesticide parent authorisation process. 
The main costs in relation to the reduction of concentration levels of pesticides in surface- and 
groundwater are expected to be covered by the implementation of the revised legislation on the 
sustainable use of pesticides directive (SUPD). According to that evaluation, costs related to 
training, inspections, Integrated Pest Management (IPM) will mainly fall on the professional users 
of pesticides, in particular farmers, who on the other hand have little or no direct economic benefit 
from implementing SUPD provisions, except for the reduced expenses on (expensive pesticides). 
The SUPD evaluation also showed that since 2009 there have been no remarkable drops in 
pesticide sales, or losses in terms of forgone sales. 
In the Netherlands, the costs associated with the treatment of water from pesticides and their 
transformation products corresponds to approximately 18 million EUR per year, which 
corresponds to around 1 million per million inhabitants. Extrapolated to the EU this corresponds to 
510 million EUR per year in treatment costs. If, in line with the targets of the F2F strategy, 
pesticide use is decreased by 50%, treatment costs would be expected to decrease correspondingly 
and by 205 million/year. In Wallonia, Belgium, the additional costs to consumers passed on by 
water treatment utilities due to pesticide pollution are currently around EUR 0.2 to 0.4 per m³, 
primarily caused by the costs for activated carbon filters. These costs to consumers would likely 
also decrease by 50% : On average, 144 litres of water per person per day is supplied to 
households in Europe , corresponding to 52m3 per year. Costs savings for consumers would thus 
be around EUR 5-10 per person/year. 
Economic value of pollinating insects to crop production in the EU is at least €3.7 billion per year. 
It is clear that pesticides (and in particular the neonicotinoids) are very toxic and persistent and 
contribute to the loss of honeybees.  

  Bumblebees that were fed the neonicotinoids at the same level found in treated rape plants and 
found that these colonies were about 10% smaller than those not exposed to the insecticide  
  Assuming that between 10% or 50% of the economic losses from pollinator decline are attributed 
to the toxicity of pesticides, this results in mean annual benefits from €370 million to 1.85 billion. 

Indirect benefits  
Monitoring, 
reporting and 
administrative 
streamlining 
options 

Option 1 (Guidelines on the monitoring of groups/mixtures of pollutants): not quantified for EU27, but 
the guidance document itself has limited impact, however a provision for monitoring estrogens with EBM 
could have substantial positive impacts. 

Option 2b (An obligatory Groundwater Watch List): not quantified for EU27, but positive impacts due to 
better decision-making processes regarding substances posing risks and better comparability of data. 

Option 3d (Repository of standards of EQSs for the RBSPs): not quantified for EU27, but positive impact 
through harmonization of EU-wide standards allowing more effective measures. Positive impacts for social 
well-being and health, providing equal standard of water resource across EU. 

Option 4a (Flexible adaptation to scientific progress and knowledge by updating the lists of pollutants 
and their EQS (under both EQSD and GWD) by delegated acts): not quantified for EU27, but positive 
impact due to quicker actions to address new substances. Positive impacts as innovation and research will 
lead to possible employment opportunities. 

Administrative cost savings related to the ‘one in, one out’ approach*  
(direct/indirect)   Deselection of existing PS: €3.8 million - €11.7 million per year (monitoring of 5 substances).  

118 

 
 
 
 
 
 
 
  
 
II. Overview of costs – Preferred option  

 Cost type 

Citizens / 
Consumers  

Businesses  

Administrations  

One-off   Recurrent

One-off  

Recurrent  

One-off   Recurrent  

Surfac
e 
water   

Direct 
adjustm
ent 
costs  

Not 
applicabl
e - €0 

Not 
applicabl
e - €0 

Not 
quantifie
d 

Not 
quantified  

Additions: Not quantified for EU27, but: 

Significant costs to ensure compliance with proposed EQS for 
Ethinyl estradiol (EE2), Ibuprofen, Clothianidin, Imidacloprid, 
Thiamethoxam, Bifenthrin, Deltamethrin, Esfenvalerate, 
Permethrin, Glyphosate, Triclosan, PFAS and Bisphenol A 
implementing a range of source control, pathway disruption, 
targeted end of pipe treatment measures. E.g. the cost of a take-
back scheme for unused pharmaceuticals in France is €10 
million. The 2022 Annex XV restriction report for the proposed 
restriction of PFASs in firefighting foams estimates that the ban 
is estimated to cost society €6.8 billion over a 30-year period or 
€390 million per year (26). Costs of pathway disruption 
measures (e.g. buffer strips) is €472 million per year for 
pharmaceuticals; for pesticides these range from €162 million 
for clothianidin and imidacloprid to €285 million for glyphosate. 
Wastewater treatment range is €10- €32 per population 
equivalent, per annum (technology dependent). 

Moderate/Small costs to ensure compliance for Estrone E1, 17- 
Beta estradiol (E2), Diclofenac, Carbamazepine, Azithromycin, 
Clarithromycin, Erythromycin, Acetamiprid, Thiacloprid, 
Nicosulfuron due to small distance to target, availability of 
source control and pathway disruption measures and/or positive 
impact of forthcoming revision of the UWWTD on quaternary 
end of pipe treatment. E.g. costs of pathway disruption measures 
(e.g. buffer strips) for pesticides range from €1.6 million for 
acetamiprid to €12.8 million for nicosulfuron. Wastewater 
treatment cost range is €10- €20 per population equivalent, per 
annum (technology dependent). 

Amendments:  
Not quantified for EU27, but: 

Significant costs to ensure compliance for Cypermethrin, 
Chlorpyrifos, Diuron, PAHs, Mercury, Nickel implementing a 
range of source control, pathway disruption, targeted end of pipe 
treatment measures. E.g. the restriction proposal which would 
ensure that granules or mulches (in particular from end-of-life 
tyres) are not placed on the market for use or used as infill 
material in synthetic turf pitches or similar applications if they 
contain more than 20 mg/kg in total of the eight indicator-PAHs 
would cost €45m (105) over a 10-year period. Costs of 
additional controls and treatment for farmed animal use of 
cypermethrin are €27.6 m82. Wastewater treatment (Mercury, 
Nickel, PAH, Cypermethrin) - €1.17- €26.2 per population 
equivalent, per annum (technology dependent). 
Mine drainage (Mercury) - €100,000 -€10,000,000 per plant and 
€0.4 per dm3 operating costs. 

Moderate/Small costs to ensure compliance for Dioxins and 
furans, Hexachlorobutadiene, Nonyl Phenol, Tributyltin due to 
small distance to target and/or limited scope for additional 
measures (likely to be natural attenuation and baseline end of 
pipe treatment (under the revised UWWTD)). E.g. the costs of 
restricting nonylphenol (NP) and its ethoxylates (NPE) in 

82 Cost calculation is based on the average cost of dip pens and containment areas to allow drying €1,120 as a one-off cost multiplied by the 
number of sheep farms in Eurostat (24,600) rounded to three significant figures. 

119 

 
  
 
 
 
 
 
                                                           
II. Overview of costs – Preferred option  

 Cost type 

Citizens / 
Consumers  

Businesses  

Administrations  

One-off   Recurrent

One-off  

Recurrent  

One-off   Recurrent  

textiles was estimated to cost the EU €3.2m per annum for a 
reduction of 15 tonnes of NP/NPE released to surface water 
(105). 

No additional costs for Dicofol, Heptachlor/ Heptachlor oxide, 
Hexachlorobenzene, Fluoranthene, PBDEs. 

Other 8 pollutants: Not quantified, but minor additional 
compliance costs (extremely low current exceedances).  
 Not quantified 

Not quantified  

 Not quantified 

Not quantified  

 Not quantified 

Not quantified  

Surfac
e 
water   

Surfac
e 
water   

Surfac
e 
water   

Direct 
adminis
trative 
costs  
Direct 
regulato
ry fees 
and 
charges  
Direct 
enforce
ment 
costs  

Not 
applicabl
e - €0 

Not 
applicabl
e - €0 

Not 
applicabl
e - €0 

Not 
applicabl
e - €0 

Not 
applicabl
e - €0 

Not 
applicabl
e - €0 

 Not 
quantified 

Not quantified  

Not 
applicabl
e - €0 

Not applicable 
- €0 

Not 
quantified 

Additions:  
Not quantified 
for EU27 but 
additional 
analytical costs 
range from 
€11-100 per 
sample for all 
substances 
except for 
PFAS ( €250). 

Amendments:  
Not quantified, 
but 
amendments 
for 
Chlorpyrifos 
and Dioxins 
and furans 
could lead to 
additional 
analytical costs  

Other 8 
pollutants: Not 
quantified, but 
cyclodiene 
pesticides, 
DDT, 
tetrachloroethy
lene and 
trichloroethyle
ne have an 
EQS that 
warrants 
monitoring and 
analysis by 
MS. 

120 

 
  
 
 
 
 
Citizens / 
Consumers  

Businesses  

Administrations  

One-off   Recurrent

One-off  

Recurrent  

One-off   Recurrent  

 Not quantified 

Not quantified  

Not 
applicabl
e - €0 

Not applicable 
- €0 

II. Overview of costs – Preferred option  

 Cost type 

Indirect 
costs  

Surfac
e 
water   

- 

- 

- 

Groun
dwater

Direct 
adjustm
ent 
costs  

Additions:  
Not quantified but 
additions of new 
substances could lead 
to societal impacts 
from less use 
(contraceptive pill, 
HRT, hormone 
treatments) 
Similar /restricted 
use of Diclofenac, 
Carbamazepine, 
Ibuprofen and 
increased costs for 
other types of 
medicine (including 
prescription only 
medications) 
Possible food 
security issues if loss 
of use without 
chemical/non-
chemical alternatives 
in place (Bifenthrin, 
Deltamethrin 
Esfenvalerate, 
Permethrin) 
Societal impacts for 
domestic pet owners 
if use of 
Imidalcoprid is 
restricted  
Not 
applicabl
e - €0 

Not 
applicabl
- 
e - €0 

PFAS: Not quantified for EU27, but: 
Restriction of use: €6.8 billion over a 30-year period or €390 
million per year (26) per substitute use. 

-  Management of contaminated biosolids (water industry):  €201 

- 

- 

- 

million/yr (landfilling) to €503-€755 million/yr high temperature 
incineration of 10% of all biosolids 
Paper manufacturing: €77 million/yr (landfilling) to €192 -€288 
million/yr high temperature incineration of paper mill wastes 

- 

Pharmaceuticals: Not quantified for EU27, but: 
Returns program / Green Pharmacy initiatives in a small number 
of MS (<€1-10 million per MS) 

nrMs: Not quantified for EU27, but: 
Costs to pesticide sector through loss of approved substances, 
costs of product development and product substitution to the 
farming sector. 

- 

Not quantified  

PFAS: 
Not 
quantified 
for EU27, 
but: 
Contamin
ated soil 
remediati
on €5 
million - 
€760 
million  
Legacy 
pollution 
landfill 
sites –
€690,000 
up to €77 
million 
per site 

Groun
dwater

Direct 
administr
ative 
costs  

Not 
applicable 
- €0 

Not 
applicable 
- €0 

 Not quantified 

Not quantified  

 Not 
quantified 

Not quantified 
but no 
significant 
additional 
costs for risk / 
status 
assessments 

121 

 
  
   
 
 
  
Direct 
regulator
y fees 
and 
charges  
Direct 
enforcem
ent costs  

Not 
applicable 
- €0 

Not 
applicable 
- €0 

Not 
applicable 
- €0 

Not 
applicable 
- €0 

II. Overview of costs – Preferred option  

 Cost type 

Citizens / 
Consumers  

Businesses  

Administrations  

One-off   Recurrent

One-off  

Recurrent  

One-off   Recurrent  

 Not quantified 

Not quantified  

Not 
applicable 
- €0 

Not applicable 
- €0 

 Not quantified 

Not quantified  

Not 
quantified 

Not quantified but proposals could lead to: 

Pharmaceuticals: 

Not 
applicable 
- €0 

- 

additional costs associated with substitution of 
pharmaceuticals and availability of alternatives (product 
substitution viable for Sulfathemoxazole but unlikely for 
Carbamazepine) 

Restrictions on use impact on farming sector and crop 
yields. Substitute pesticides are available and can be 
cheaper or up to 100 times more costly that permitted 
parent pesticides 
Un-intentional impacts for example glyphosate is used 
to destroy cover crops, which are used to mitigate 
nutrients in run-off / leaching from agricultural fields 
over winter 
Increased data requirements could make gaining 
authorisation of new products more challenging. 

- 

- 

Indirect 
costs  

Not quantified but 
proposals could lead 
to: 
- 

nrMs:  
- 

Possible societal 
impacts from loss 
of use of 
pharmaceuticals - 
Restricting use 
could impact on 
health and well-
being of people 
and animals 
where 
alternatives have 
side effects / 
different efficacy. 

Not 
applicable 
- €0 

Not 
applicable 
- €0 

Direct 
adjustme
nt costs  

Digital
isation, 
admini
strativ
e 
stream
lining 
and 
better 
risk 
manag
ement 
option
s   

Not quantified for EU27, but: 

Option 2 (Guidelines on the monitoring of groups/ mixtures of 
pollutants): Costs due to monitoring of estrogen are low, but 
possible measure to be taken due to monitoring results may be 
substantial. 

Policy option 3 – Reporting and classification - sub-option (a): 
Establish an automated data delivery mechanism for the EQSD 
and the WFD. This option makes best use of the European 
Environment Agency’s (EEA) and IPBES’s DPSIR frameworks. 
Contributes to a more streamlined, simplified, modern, digital 
monitoring and reporting as well as uptake of new digital and 
earth observation technologies resulting in real-near time data 
flows Consequently, it will also contribute to a streamlined and 
effective (bi)annual presentation of monitoring results. 

Not 
quantified 
for EU27, 
but: 

Option 2 
(Guidelines 
on the 
monitoring 
of 
groups/mix
tures of 
pollutants): 
Limited 
cost to 
develop the 
guidance 
document. 

Option 8 (Repository of standards of EQSs for the RBSPs): 
agreeing on RBSPs EQSs would likely lead to substantial costs for 
MS for implementation of substantive measures where necessary. 

Additional 
analytical costs 
for EU27: 
PFAS: €45-48 
million 
Pharma: €2 
million  
nrMs: €4-5 
million  
Not applicable 
- €0 

Not quantified 
for EU27, but: 

Option 6 (An 
obligatory 
groundwater 
watchlist): 
Additional cost 
for monitoring 
and reporting 

Option 9 (Allowing flexible adaptation to scientific progress and 
knowledge by updating the lists of pollutants and their EQS 
(under both SWD and GWD) by way of delegated acts 

 Not 
quantified 

Not quantified  

Monit
oring, 
reporti
ng and 

Direct 
administr
ative 
costs  

Not 
applicable 
- €0 

Not 
applicable 
- €0 

122 

 
  
 
 
 
 
 
 
 
 
  
 
II. Overview of costs – Preferred option  

 Cost type 

admini
strativ
e 
stream
lining 
option
s 

Direct 
regulator
y fees 
and 
charges  
Direct 
enforcem
ent costs  

Not 
applicable 
- €0 

Not 
applicable 
- €0 

Not 
applicable 
- €0 

Not 
applicable 
- €0 

Citizens / 
Consumers  

Businesses  

Administrations  

One-off   Recurrent

One-off  

Recurrent  

One-off   Recurrent  

 Not quantified 

Not quantified  

NA 

NA  

 Not quantified 

Not quantified  

Mon 

Not quantified 
for EU27, but: 

Option 1 
(Guidelines on 
the monitoring 
of groups/ 
mixtures of 
pollutants): 
Minor 
monitoring 
costs of 
estrogens. 

Option 2b (An 
obligatory 
groundwater 
watchlist): 
Additional cost 
for monitoring 
and reporting. 

Option 3d 
(Repository of 
standards of 
EQSs for the 
RBSPs): 
substantial 
costs for MS 
for 
implementatio
n of 
monitoring 
(following the 
agreement on 
RBSPs EQSs). 
NA  

Indirect 
costs  

 Substitutio
n 
Prices 

 NA 

Costs related to the ‘one in, one out’ approach  

 NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

Total   

Direct 
adjustme
nt costs   
Indirect 
adjustme
nt costs  
Administ
rative 
costs (for 
offsetting
)  

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

123 

 
  
 
 
 
  
  
  
 
1.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS  

III. Overview of relevant Sustainable Development Goals (SDG) – Preferred Option(s) 

Relevant SDG 

Expected progress towards the Goal 

Comments 

Goal 6: Ensure access to water and sanitation for all 

SDG target 6.1: 
By 2030, achieve universal and equitable 
access to safe and affordable drinking 
water for all 

Decreased levels of pollution of the main sources of 
drinking water. By applying the most cost efficient 
solution (usually prevention / action at source) costs of 
drinking water should remain affordable.  

SDG target 6.3: 
By 2030, improve water quality by 
reducing pollution, eliminating dumping 
and minimizing release of hazardous 
chemicals and materials, halving the 
proportion of untreated wastewater and 
substantially increasing recycling and safe 
reuse globally 

The legislation will lead to an expanded and updated list 
of pollutants, where MS need to ensure compliance with 
for their groundwater and surface water. Limit values are 
set so as to minimise risk on health and environment. 
Water and sludge recycling rates are dependent on the 
degree of pollution. By focusing on upstream / 
preventive action recycling will be facilitated.  

This initiative will increase the 
quality both in terms of human 
health and environmental 
aspects of surface and 
groundwater, and will thus also 
increase the safety of the two 
by far largest sources for 
producing drinking water. 

This initiative will improve 
water quality by setting stricter 
environmental quality 
standards and bring more 
hazardous substances under 
control and thus contributes to 
minimising the release of 
hazardous substances into 
surface and groundwater. 

Indicator 6.3.2: Proportion of bodies of 
water with good ambient water quality 

More categories of pollutants, at stricter limit values will 
be set. By introducing more adequate methodologies, it 
will allow for more focused policy intervention, in the 
longer run leading to a larger number of water bodies in 
good quality.  

This legislation will further 
incentivise action against a 
larger range of pollutants, at 
stricter norms. In the longer 
run 

Goal 12: Ensure sustainable consumption and production patterns 

SDG Target 12.4: 
By 2020, achieve the environmentally 
sound management of chemicals and all 
wastes throughout their life cycle, and 
significantly reduce their release to air, 
water and soil in order to minimize their 
adverse impacts on human health and the 
environment 

More pollutants and groups of pollutants will be covered, 
at stricter limit values. This will require more integrated 
chemicals management, in particular leading to more 
action upstream / at source. In particular to facilitate 
circularity and avoid undue energy use e.g. for sludge 
management, preference will often go to upstream 
solutions.  

This initiative will allow a 
more adequate, future proofed 
management of chemicals in 
the aquatic environment. It will 
allow more effective and 
targeted interventions when 
risk to the environment and 
health is identified. 

Goal 14: Conserve and sustainably use the oceans, seas and marine resources  

SDG target 14.1  
By 2025, prevent and significantly reduce 
marine pollution of all kinds, in particular 
from land-based activities, including 
marine debris and nutrient pollution 

Reductions can be expected for pharmaceuticals, 
industrial chemicals, pesticides and – in the longer run – 
microplastics, combining both source and end of pipe 
measures. Ultimately less pollutants will be transported 
to the marine environment.  

124 

 
 
ANNEX 4: ANALYTICAL METHODS USED IN PREPARING THE IMPACT ASSESSMENT 

1.  Dynamic baseline 

A  dynamic  baseline  reflects  the  likely  changes  to  emissions  and  by-proxy  environmental 
concentrations  in  a  business-as-usual  /  do  nothing  scenario  covering  the  short-to-medium 
term  picture  until  2030.  External  drivers  that  may  affect  emissions  and  environmental 
concentrations can be policy or non-policy related, as described below. 

1.1. Policy drivers  

The  timing  of  changes  in  emissions  to  the  environment  depends  on  timing  or  focus  of 
legislation  or  strategies.  Therefore,  for  PFAS  which  are  banned  and  no  longer  used  for  a 
specific purposes (e.g. fire-fighting foams) the trend decreases sooner than for PFAS which 
exist in products such as textiles where they will continue to be released to the environment 
even  if  use  is  phased-out.  For  nrMs  with  a  banned  parent  compound,  their  formation  and 
release  to  the  environment  will  depend  on  the  rate  of  degradation  of  the  parent  compound 
which is a function of environmental factors such as temperature, sunlight, moisture content, 
presence  of  co-metabolites  and  micro-organisms  capable  of  breaking  down  the  parent 
compound. The decrease in emissions will be faster than for those whose parent compounds 
are not banned. 

Innovation and digitalisation 

The  implementation  of  the  INSPIRE  Directive  2007/2/EC  may  also  have  impacts  on 
monitoring  and  reporting.  The  Directive  lays  down  the  rules  establishing  the  infrastructure 
for spatial information in the European Union in support of Union environmental policies and 
policies or activities that may have an impact on the environment (Art. 1(1)). The aim is to 
deliver useful, standardised and high-quality data in order to formulate, implement, monitor 
and evaluate European, national and local policy. The Directive does not set requirements for 
the  collection  of  new  data,  or  for  reporting  to  the  Commission  but,  rather,  lays  down  a 
number  of  rights  and  obligations  regarding  the  sharing  of  spatial  data  sets.  Annex  I  to  the 
Directive  lists  34  data  themes  which  are  covered  under  INSPIRE,  including  data  that  is 
commonly reported under the Water  Information System for Europe (WISE). The set-up of 
INSPIRE  is  aimed  at  facilitating  data-harvesting  and  reaping  benefits  of  technological 
developments,  reducing  burdens  of  environmental  monitoring  and  reporting  while  enabling 
information to be collected and utilized. In addition to the Implementing Rules, non-binding 
Technical Guidance documents describe detailed implementation  aspects  and relations with 
existing  standards,  technologies,  and  practices.  As  such,  the  INSPIRE  Directive  not  only 
requires  MS  to  disclose  their  national  data  that  must  be  collected  on  the  bases  of  other 
environmental policy frameworks (including the WFD), but also sets a standard for reporting 
data  and  making  it  publicly  accessible.  The  INSPIRE  Directive  was  set  to  come  into  full 
force by 2021.  

In the context of the Chemicals Strategy for Sustainability, and building on the Information 
Platform  for  Chemical  Monitoring  (IPCheM),  the  Commission  is  looking  at  establishing  a 
data-harvesting  system  for  chemical  monitoring  and  toxicity  data.  This  could  introduce 
provisions for a harmonised approach to data harvesting across a range of chemicals-related 
policy sectors. 

125 

 
One caveat is that, as the policy landscape continues to evolve, there are likely to be further 
changes in decision making and implementation, making it hard to quantitatively predict the 
impacts of the dynamic baseline. 

1.2. Non-policy drivers 

Climate change 

Climate  change  is  leading  to  more  unpredictable  weather  events  with  greater  extremes 
including  both  increased  rainfall  (intensity)  and  increased  duration  and  frequency  of  dry 
seasons  and  droughts.  More  frequent  and  heavier  rainfalls  can  increase  urban  run-off  and 
storm water overflows from sewer systems, thus placing additional pollutant-load pressure on 
water bodies, whereas an increase in the duration and frequency of dry seasons and droughts 
can  result  in  reduced  dilution  of  pollutants  in  surface  waters.  Both  phenomena  can 
significantly  affect  the  status  of  water  bodies.  Dry  periods  often  translate  into  increased 
abstraction for many uses of both surface and groundwaters, which can put chemical status at 
risk. Furthermore, droughts can cause additional stress on freshwaters used as drinking water 
sources,  in  particular  groundwater  aquifers.  The  impacts  of  climate  change  can  thus  be 
expected to make existing pollution-related problems worse. 

Growth in urbanisation and ageing populations 

Trends in the current development of society are likely to have an impact on water resources, 
primarily  through  increased  pressures.  Two  particularly  important  social  developments  that 
may impact surface and groundwater resources are urbanisation and the aging of populations. 

Urbanisation is defined as the process by which natural or semi-natural land is converted into 
urban  uses.  The  urban  environment  is  largely  impervious  to  water,  resulting  in  the  water 
transport  having  to  occur  through  artificial  means  (e.g.  sewer  networks).  Due  to  the 
impermeability of urban areas, water retained and collected, often to reduce flood risk, can 
contain several pollutants from different sources, and therefore present a risk to water bodies 
when discharged. As a result, an increasing degree of urbanisation will have a direct impact 
on  the  quantity  of  contaminants  entering  the  environment.  Studies  have  projected  that 
between 2015 and 2030, built-up areas within the EU will grow to occupy 7% of EU territory 
and  by  2050  it  is  estimated  that  83.7%  of  the  EU  population  will  be  living  in  urban  areas 
(106). 

In addition, demographic changes (in relation to population size and age) may also have an 
impact  on  contaminant  release  and  therefore  increase  the  pressure  on  water  treatment 
facilities.  For  instance,  projected  population  trends  that  show  an  increase  in  the  share  of 
elderly  people,  relative  to  the  total  population,  may  have  an  impact  on  the  consumption  of 
pharmaceuticals  in  the  future.  The  consequent  release  of  pharmaceutical  compounds  into 
waste  water  collection  and  treatment  facilities  is  likely  to  increase  the  pressure  on  those 
facilities, as well as on the environment as pollutant loads increase. 

Innovation and digitalisation 

Innovation and digitalisation are key priorities for the water sector in order to align the sector 
with EU ambitions such as those set out in the European Green Deal. In the context of water 
management, the metering of water supply/consumption, and the monitoring and reporting of 
water  quality,  are  increasingly  modernising  by  automation  processes,  remote  sensing  and 
remote data transmission. For example, the fitting of waste water treatment plants with smart 

126 

 
remote  monitoring  technologies  that  allow  telemetric  can  reduce  operating  costs,  improve 
plant  lifetimes  and  facilitate  the  switching  of  plant  operations  depending  on  different 
conditions.  The  increased  use  of  multi-parameter  (fluid)  sensor  technologies  is  another 
example. Furthermore, technologies are evolving rapidly that could facilitate data processing 
and information sharing in the water sector. 

1.3. Results of the dynamic baseline exercise for surface and groundwater pollutants 

A qualitative analysis of the dynamic baseline for surface water is presented in Table A4.1, 
whereas substances proposed for listing in Annex I and Annex II of the GWD are covered in 
Table  A4.2.  The  tables  provide  an  overview  of  the  relevant  legislation  and  the  best 
understanding  of  how  it  is  evolving,  an  overview  of  how  this  evolution  may  impact  the 
emissions  of  candidate  and  existing  priority  substances  as  well  as  substances  on  the  List 
Facilitating Review of the GWD Annexes. Note that the dynamic baseline situation, in terms 
of production, use and emissions, is in most cases subject to significant uncertainty.  

127 

 
 
Urban 

Industrial 
Emissions 
(IED); 
Directive 
Strategic  Approach 
to  Pharmaceuticals 
in the Environment 
(PiE); 
Classification  and 
Labelling  of  EU 
Pharmaceutical 
Strategy; 
Wastewater 
Treatment 
Directive 
(UWWTD), 
but 
possibly not before 
2030,  Directive  on 
the 
Sustainable 
Use  of  Pesticides 
(DSUP), 
Classification, 
Labelling 
Packaging 
of 
substances 
mixtures 
Regulation 
IED; 
legislation 
(veterinary);  PiE; 
EU  Pharmaceutical 
Strategy; 
UWWTD;  Farm  to 
fork strategy (F2F). 

and 
(CLP) 
chemical 
and 

Pharma 

PiE;  EU 

IED; 
Pharmaceutical 
Strategy; UWWTD 

Table A4.1: Dynamic baseline for surface water pollutants 

Substance 

Main Uses 

Non-policy 
underlying 
drivers 

Policy 
(potentially) 
driving emission 
reduction 

Examples  of  specific 
/  actions 
initiatives 
emission 
for 
reduction 

Overall 
outcome 

Possible addition of priority (hazardous) substances 
Estrogenic 
substances  (E1, 
E2, EE2) 

population 
Aging 
with 
potential 
increase  in  use  of 
HRT.  
Aging 
decrease 
contraceptive pill. 

population 
of 

use 

Used 
as 
medication,  e.g. 
hormonal 
in 
birth 
control, 
menopausal 
hormone 
therapy, 
treatment 
hormone-
sensitive 
cancers. 

of 

Changes  under  UWWTD 
could have an impact, but 
to  be  widely 
unlikely 
implemented 
before 
2030. 

Some 
emissions 
minimisation
s 
(10-30%) 

Macrolide 
antibiotics 
(azithromycin; 
clarithromycin; 
erythromycin) 

Used  in  animal 
farming  and  as 
medication 
to 
treat 
various 
infections. 

Carbamazepine  Used 

Changes 
to  way 
antibiotics  are  used 
in farmed animals.  
Rate  of  human  use 
difficult to predict in 
future  years.  EU 
Population  is  largely 
static albeit aging. 
No 
underlying 
identified. 

specific 
drivers 

Diclofenac 

Ibuprofen 

as 
medication 
to 
treat  trigeminal 
neuralgia, 
diabetic 
neuropathy  and 
bipolar disorder. 
as 
Used 
to 
medication 
treat  mild 
to 
moderate  pain, 
and 
or 
signs 
symptoms 
of 
osteoarthritis  or 
rheumatoid 
arthritis. 
as 
Used 
to 
medication 
reduce 
fever 
and treat pain or 
inflammation 
caused by  many 
conditions  such 

for 

use 

of 
Pre-emptive 
antibiotics 
farmed 
animals  ceased  end  of 
2019.  
strategy 
Pharmaceutical 
specifically 
includes 
initiatives to address anti-
microbial resistance 
EU 
Strategy 
alternative medicines. 

pharmaceutical 
assess 
could 

Significant 
emissions 
reductions 
(30-50%) 

Some 
emissions 
reductions 
(10-30%) 

Some 
emissions 
reductions 
(10-30%) 

Aging 
population, 
potential  increase  in 
use,  depending  on 
national approaches. 

EU 

PiE; 
Pharmaceutical 
Strategy; UWWTD 

specific 

No 
identified. 

initiatives 

Aging 
population, 
potential  increase  in 
use,  depending  on 
national approaches. 

EU 

PiE ; 
Pharmaceutical 
Strategy; UWWTD 

specific 

No 
identified. 

initiatives 

change. 
10% 

No 
(+/- 
current 
emissions) 

128 

 
Substance 

Main Uses 

Non-policy 
underlying 
drivers 

Policy 
(potentially) 
driving emission 
reduction 

Examples  of  specific 
/  actions 
initiatives 
for 
emission 
reduction 

Overall 
outcome 

or 

as 
headache, 
toothache,  back 
pain, 
arthritis, 
menstrual 
cramps, 
minor injury. 
Used  to  control 
insect  pests  in 
agriculture 
(crops, 
vegetables, 
fruits), 
animal 
farming (e.g. for 
invertebrate 
pest  control  in 
fish farming). 

Neonicotinoids 
(Acetamiprid;  
Clothianidin; 
Imidacloprid; 
Thiacloprid; 
Thiamethoxam
) 

Pyrethroids 
(Bifenthrin; 
Deltamethrin; 
Esfenvalerate; 
Permethrin) 

Used  to  control 
insect  pests  in 
agriculture, 
public 
and 
farming. 

health 
animal 

Nicosulfuron 

as 

Used 
herbicide 
control weeds. 

an 
to 

Glyphosate 

as 

an 
Used 
herbicide 
to 
control  weeds 
and grasses. 

Some 
emissions 
reductions 
(10-30%) 

Some 
emissions 
reductions 
(10-30%) 

Some 
emissions 
reductions 
(10-30%) 

No 
change. 
(+/-  10%  of 
current 
emissions) 

GWD; 
Biocidal 

EQSD; 
DWD; 
Products 
Regulation  (BPR); 
Protection 
Plant 
Products 
Regulation 
(PPPR); 
Sustainable  Use  of 
Pesticides 
Directive (SUPD)83 

EQSD, 
GWD, 
DWD;  BPR;  F2F; 
PPPR; SUPD 

for 

F2F  could  be  important, 
but  the  point  was  made 
that the approvals for use 
as  a  pesticide  have  been 
four 
removed 
neonicotinoids,  and  strict 
controls  for  acetamiprid. 
Therefore,  difficult 
to 
further control use. 
for 
driver 
Primary 
emission  reduction  will 
be  PoMs  under  WFD 
with  synergistic  benefits 
to other pesticides. 
Acetamiprid, 
and 
clothianidin, 
all 
imidacloprid 
candidates 
for 
substitution  under  BPR 
which  should  aid  phase-
out. 
F2F sets targets to reduce 
the  use  of  pesticides 
which 
aid 
emissions.  

could 

are 

Under  BPR  Bifenthrin  is 
a 
for 
candidate 
substitution  which  aid  its 
phase-out. 

EQSD, 
DWD; 
SUPD 

GWD, 
PPPR; 

specific 

No 
identified. 

initiatives 

EQSD, 
DWD; 
SUPD 

GWD, 
PPPR; 

The 
of 
assessment 
glyphosate  is  ongoing,  at 
present 
continued 
authorisation  is  expected. 
directly 
not 
is 
It 
mentioned 
the  F2F 
in 
strategy,  and  based  on 
current  usage  rates  and 
EU  policy,  emissions  are 
assigned  to  the  category 
‘no change’. 

plant 
as 
Use 
protection  products 
(PPPs)  now  largely 
banned; 
however 
very  few  chemical 
alternatives, 
so 
emergency 
authorisations  have 
been  used.  Uses  as 
still 
biocides 
approved 
four 
out  of  five  neonics. 
Usage 
not 
expected  to  increase 
to 
significantly  up 
2030. 

rates 

for 

Approvals  in  place 
under  both  PPPR 
and 
but 
BPR, 
consistency  would 
need to be ensured in 
the  best  possible 
way.  Very 
limited 
choice  of  chemical 
alternatives. 
Use 
could increase in the 
future  for  a  variety 
of reasons. 
Difficult to predict; a 
range  of  chemical 
alternatives 
exist. 
Assume  usage  rates 
remain 
broadly 
stable. 
Current 
approval 
expires  December 
2022.  Based 
on 
communication  with 
Commission 
approval  is  likely  to 
be  extended  at  least 
12  months  while 
continues. 
review 
extension 
Further 
possible.  

rates 

Usage 
are 
already  high,  could 
continued 
assume 

83 Revision of SUPD is ongoing. 

129 

 
 
 
                                                           
Substance 

Main Uses 

Non-policy 
underlying 
drivers 

Policy 
(potentially) 
driving emission 
reduction 

Examples  of  specific 
/  actions 
initiatives 
for 
emission 
reduction 

Overall 
outcome 

Triclosan 

PFAS 

as 

an 

e.g. 

Used 
antibacterial 
and  antifungal 
agent  in  some 
consumer 
products, 
toothpaste, 
soaps, 
detergents,  toys, 
surgical 
cleaning 
treatments. Also 
added  to  other 
materials,  such 
to 
as 
textiles, 
them 
make 
to 
resistant 
bacteria. 
Used  in  stain- 
and 
water-
resistant  fabrics 
carpeting, 
and 
cleaning 
products, paints, 
and fire-fighting 
foams. 

Bisphenol A 

Used 
the 
in 
manufacture  of 
various  plastics, 
for 
including 

use 

lead 

rates  at  a  similar 
level.  Question  of 
whether  high  usage 
rates 
to 
and 
tolerance, 
greater 
of 
alternatives  or  co-
mixtures 
with 
glyphosate? 
Remaining  use  as  a 
limited 
in 
biocide 
range 
of 
applications. 
Candidate 
for 
substitution.  Expect 
future use to decline. 

The  PFAS  market 
through 
has  been 
successive 
step 
changes  as  EU  and 
global  policy  has 
intervened.  Expect 
further 
diversification,  and 
role 
of 
fluoropolymer  as  a 
replacement  for  at 
least 
non-
some 
polymeric 
applications.  Legacy 
issues  will 
from 
continued  pollution 
substitution 
from 
from  already 
and 
polluted  hot  spots 
will  remain.  Those 
will 
still  creating 
future  problems  for 
and 
surface 
groundwater 
concentrations  levels 
unaddressed. 
if 
Therefore, 
policy 
the 
actions  under 
WFD,  EQSD  and 
GWD  will  remain 
necessary. 
Some  restrictions  on 
Bisphenol  A  already 
in 
and 
place, 
substitution  from  the 

EQSD, 
DWD, 
Cosmetics 

GWD, 
BPR; 

Candidate for substitution 
under BPR. 

Some 
emissions 
reductions 
(10-30%) 

Restriction  on  the  use  of 
PFAS.  Development  of 
analytical standards under 
DWD. 

Significant 
emissions 
reductions 
(30-50%) 

EQSD; 
IED, 
DWD; 
GWD; 
REACH, 
Food 
contact  materials 
(FCM);  REACH; 
Waste 
legislation; 
Chemicals Strategy 
for  Sustainability 
(CSS); 
expect 
revised  UWWTD 
further 
to  have 
impacts, 
but 
possibly not before 
2030. 

IED; 
REACH; FCM 

DWD; 

New  standard  adopted 
under DWD, which could 
aid  emission 
reduction 
earlier in the life-cycle. 

No 
change. 
(+/-  10%  of 
current 
emissions) 

130 

 
Substance 

Main Uses 

Micro-plastics 

Silver 

shatterproof 
windows, 
eyewear,  water 
bottles, 
and 
epoxy 
resins 
that  coat  some 
metal food cans, 
bottle  tops,  and 
water 
supply 
pipes. 
Intentionally 
added to a range 
of 
products 
including 
fertilisers,  plant 
protection 
products, 
cosmetics, 
household  and 
industrial 
detergents, 
cleaning 
products,  paints 
and 
products 
used  in  the  oil 
gas 
and 
industry.  Also 
used  as  the  soft 
infill  material 
on  artificial  turf 
sports pitches. 

as 

and 

and 
as 
in 

Used  in  coins, 
silverware, 
jewellery, 
mirrors 
windows 
well 
various 
industrial 
electrical 
applications, 
medicine 
surgical 
equipment, 
wound 
dressings, 
ointments)  and 
even 
film 
photography. 

(in 

Policy 
(potentially) 
driving emission 
reduction 

Examples  of  specific 
/  actions 
initiatives 
for 
emission 
reduction 

Overall 
outcome 

UWWTD; 
REACH;  Waste 
legislation;  Marine 
Strategy 
Framework 
Directive  (MSFD), 
Plastics 
EU 
(incl. 
Strategy 
EU 
upcoming 
initiatives 
on 
micro-plastics), 
product 
design 
requirements  under 
the 
Ecodesign 
Directive, 
Sustainable 
Textiles  Strategy 
and 
other 
Sustainable 
Products  Initiative 
(SPI) actions.  

IED;  DWD;  BPR; 
Waste legislation 

given 

the 
However, 
complex  issues  at  play, 
expect 
impact. 
limited 
Assume  emissions  are 
largely unchanged. 

REACH restriction on the 
intentional  use  of  micro-
plastics. 
 EU  initiatives  on  micro-
plastics 
tackle 
will 
unintentional releases. 

Some 
emissions 
reductions 
(10-30%)  

Some 
emissions 
reductions 
(10-30%) 

due 
risks 

Biocides 
ECHA 
committee 
rejected 
approval  of  four  silver 
active 
containing 
substances85 
to 
for 
unacceptable 
human  health  when  used 
activated 
as  part  of 
carbon  water 
filters. 
Possibility for silver to be 
key 
selected 
performance 
indicator 
under IED BREF process. 

as 

Non-policy 
underlying 
drivers 

same  family  in  use. 
Many  of  the  issues 
for  emissions  may 
now  relate  to  legacy 
aspects 
(polycarbonate  and 
resins). 
epoxy 
Assume  usage  rates 
broadly stable. 

issues 

– 
Two 
intentional  use  of 
and 
micro-plastics 
secondary 
micro-
plastics  from  use  of 
plastic  more  widely. 
likely  for 
Controls 
intentional 
use, 
expect usage rates to 
decline by 2030. 
Legacy  issues84  will 
continued 
from 
pollution 
from 
continued  pollution 
and  from  loads  of 
already 
plastics 
the 
present 
in 
environment 
will 
remain.  Those  will 
still  creating  future 
problems  for  surface 
and 
groundwater 
concentrations  levels 
unaddressed. 
if 
Therefore, 
policy 
the 
actions  under 
WFD,  EQSD  and 
GWD  will  remain 
necessary 
issue  as 
Complex 
this 
is  a  naturally 
occurring  substance 
but  also  used 
in 
silver 
containing 
biocides  and  PCP. 
There  will  also  be 
legacy  issues  (e.g., 
mine 
drainage, 
landfill,  etc.).  Some 
usage  rates  can  be 
assumed 
be 
broadly  stable  while 
others like the use of 
silver 
anti-
as 
bacterial  agent  and 
in  a  wide  range  of 
is 
products 

to 

84 Plastics degrade slowly (often over hundreds to thousands of years) and absorb persistent organic pollutants. Consequently, microplastics are 
classified as PHS. Specific surface degradation rates (SSDR) are sued to extrapolate half-lives. Mean SSDRs for high density polyethylene (HDPE) in 
the marine and aquatic environments lead to estimated half-lives ranging from 58 years (bottles) to 1200 years (pipes) (125).  
85 https://echa.europa.eu/-/biocides-committee-proposes-not-to-approve-four-silver-containing-active-substances 

131 

 
 
                                                           
Substance 

Main Uses 

Non-policy 
underlying 
drivers 

increasing. Finally, it 
be 
also 
must 
considered 
that 
silver is the basis for 
important 
nanomaterials. 

Policy 
(potentially) 
driving emission 
reduction 

Examples  of  specific 
/  actions 
initiatives 
for 
emission 
reduction 

Overall 
outcome 

Possible amendment of existing priority (hazardous) substances 
Chlorpyrifos 

and 

Use  is  banned  in  the 
EU, 
recently 
nominated  as  a  POP 
under  the  Stockholm 
Convention. 

GWD; 

EQSD; 
DWD 
Persistent  Organic 
(POPs) 
Pollutants 
Regulation 

Already  banned  in  the 
EU. Nominated as a POP 
to 
Stockholm 
Convention in 2021. 

the 

Some 
emissions 
reductions 
(10-30%) 

Cypermethrin 

Dioxins 

Diuron 

by-
of 

e.g. 
of 

Past  use  as  an 
insecticide 
to 
control 
foliage 
soil-borne 
and 
insect pests on a 
variety  of  food 
and feed crops. 
Used 
as 
an 
to 
insecticide 
control  a  range 
in 
of 
pests 
arable 
and 
livestock 
farming,  homes 
gardens, 
and 
and 
in  public 
and  commercial 
buildings. 
Also  used  as  a 
medication 
to 
treat 
parasitic 
skin diseases. 
Mainly 
products 
industrial 
practices, 
production 
some 
chlorinated 
organic 
compounds, 
chlorine 
of 
bleaching 
pulp  and  paper. 
Also 
formed 
during 
combustion 
processes 
(including 
smoking). 
Past  use  as  a 
pre-emergence 
herbicide 
for 
general  weed 
control 
on 
noncroplands 
to 
also 
and 
control  weeds 
and algae in and 
around  water 
bodies  and  as  a 
of 
component 
marine 
anti-
fouling paints. 

EQSD; 
GWD; 
DWD; F2F; SUPD 

F2F  may  provide  some 
for 
impacts 
positive 
emission 
reduction  of 
pesticidal  use.  Biocidal 
use unaffected. 

Some 
emissions 
reductions 
(10-30%) 

IED; 
Regulation 

POPs 

specific 

No 
identified. 

initiatives 

change. 
No 
(+/-  10%  of 
current 
emissions) 

Approved  as  both  a 
PPP  and  biocide, 
with  approvals 
to 
2029 
2030 
and 
respectively.  Expect 
to 
usage 
increase  as  pressure 
on  other  pyrethroids 
drives substitution. 

rates 

are 

No  commercial  use. 
emission 
Major 
sources 
now 
largely under control 
(metals, incineration, 
power  generation). 
Emissions  in  the  EU 
now 
largely  static, 
and further reduction 
challenging. 

EQSD; 
DWD 

GWD; 

ended 
Approval 
2020. 
September 
Expect  all  remaining 
to 
stocks 
be 
exhausted 
in  near 
term. 

Use  ceased  recently,  but 
the  very  high  persistence 
in 
soil,  could  create 
legacy  issues  that  limit 
the emission reduction up 
to 2030. 

Some 
emissions 
reductions 
(10-30%) 

132 

 
Substance 

Main Uses 

Fluoranthene 

PAHs 

/ 

Heptachlor 
Heptachlor 
epoxide 

Hexachloro-
benzene 

Hexachloro-
butadiene 

Mercury 

Nickel  

a 

Used 
as 
fluorescent 
agent  for  non-
magnetic  metal 
surface 
inspection, 
synthesizing 
yellow  and  blue 
vat  dyes,  and 
manufacturing 
medicine. 

Occur  naturally 
in  coal,  crude 
oil, 
and 
gasoline. 
Released  during 
combustion 
processes 
(including 
smoking). 
Past  use  as  an 
insecticide 
to 
control  various 
insect pests, and 
for soil and seed 
treatment,  wood 
protection. 
Past  use  as  a 
fungicide 
for 
treatment, 
seed 
especially 
on 
wheat to control 
the 
fungal 
disease bunt. 
Used 
the 
in 
manufacture  of 
rubber 
compounds, 
in 
the  production 
of  lubricants,  as 
a 
for 
fluid 
gyroscopes, as a 
transfer 
heat 
in 
liquid,  and 
hydraulic fluids. 
Wide  range  of 
uses 
in 
e.g. 
thermometers, 
barometers, 
manometers, 
blood  pressure 
meters, 
float 
valves,  mercury 
switches, 
mercury  relays, 
fluorescent 
lamps  and  other 
devices. 
Used 
stainless 
and 

to  make 
steel 
other 

Non-policy 
underlying 
drivers 

PAH family member 
found  in  crude  oil 
and  distillates.  Used 
in 
some 
manufacturing 
processes  relating  to 
and 
dyes, 
oils, 
speciality  chemicals. 
specific 
No 
drivers 
underlying 
assume 
identified; 
use is stable. 
No  commercial  use. 
Formed  as  mixtures 
within 
fuels 
fossil 
and crude oil. 

Policy 
(potentially) 
driving emission 
reduction 
EQSD; 
DWD; REACH 

GWD; 

Examples  of  specific 
/  actions 
initiatives 
for 
emission 
reduction 
No 
identified. 

initiatives 

specific 

Overall 
outcome 

No 
change. 
(+/-  10%  of 
current 
emissions 

IED; EQSD 

Further 
emission 
reduction  under  IED  and 
EQSD. 

Some 
emissions 
reductions 
(10-30%) 

Banned in the EU 40 
years ago, but highly 
persistent. 

EQSD, 
Regulation 

POPs 

specific 

No 
identified. 

initiatives 

Banned in the EU 45 
years ago, but highly 
persistent. 

EQSD, 
Regulation 

POPs 

specific 

No 
identified. 

initiatives 

EQSD, 
Regulation 

POPs 

Not 
intentionally 
used in the EU since 
end  of  the  1980s. 
Possible 
of 
contamination 
imported  products. 
But 
to 
addition 
Stockholm 
Convention 
drive down use. 

will 

to  Stockholm 

Added 
Convention in 2017. 
However,  EU  use  ceased 
in 
emissions 
should  already  be  very 
low. 

1980s, 

No 
change. 
(+/-  10%  of 
current 
emissions) 

No 
change. 
(+/-  10%  of 
current 
emissions) 

No 
change. 
(+/-  10%  of 
current 
emissions 

occurring 
Natural 
substance. 
Wide 
range  of  uses  but 
significant steps over 
the  last  decade  to 
control emissions.  
No 
policy 
identified. 

specific  non-
drivers 

EQSD, 
GWD, 
DWD;  IED;  SSD; 
Restriction 
of 
Hazardous 
Substances (RoHS) 
Directive,  Mercury 
Regulation, 
Minamata 
Convention  

Significant 
emissions 
reductions 
(30-50%) 

for 
to 

Priority 
emission 
reduction 
support 
EQSD. 
Including  Key 
Indicator 
Performance 
under IED, controls under 
Mercury  Regulation,  and 
legislation. 
waste 
Reductions 
from  new 
for  Large 
provisions 
Combustion  Plans  and 
decarbonising industry. 

Similar  issues  as  for 
other 
metals, 
naturally  occurring 

EQSD; 
DWD; 
REACH 

GWD; 
IED; 

Possible  work  under  IED 
BREF process. 

Some 
emissions 
reductions 

133 

 
Substance 

Main Uses 

Nonylphenol 

PBDEs 

Tributyltin 

Dicofol 

Hexabromo-
cyclododecane 

for 

alloys, 
for 
plating,  foundry 
and batteries. 
Used 
industrial 
processes 
(e.g. 
for  washing and 
dying  of  yarns 
and fabrics) and 
in 
consumer 
laundry 
detergents, 
personal 
hygiene, 
automotive, 
latex paints, and 
lawn 
care 
products. 
Used  as  flame 
retardants 
in 
plastics, 
furniture, 
upholstery, 
electrical 
equipment, 
electronic 
devices,  textiles 
and 
other 
household 
products. 
Past  use  as  a 
biocide  in  anti-
paint 
fouling 
applied 
to 
commercial 
vessels, 
pleasure 
craft 
and  mariculture 
equipment. 
Past  and  some 
current  use  for 
ornamental 
plants and fruits 
Used  as  flame-
retardant  within 
insulation 
boarding, 
plastics, 
textiles 

and 

Non-policy 
underlying 
drivers 

substance. 
No 
specific  underlying 
drivers identified. 
Intentional  use  has 
ceased. 
Imported 
textiles  still  an  issue 
to 
likely 
and 
continue  to  be  the 
case in future. 

Policy 
(potentially) 
driving emission 
reduction 

Examples  of  specific 
/  actions 
initiatives 
for 
emission 
reduction 

Overall 
outcome 

(10-30%) 

EQSD; 
GWD; 
DWD;  REACH; 
but 
UWWTD, 
before 
unlikely 
2030 

UWWTD  revision  could 
tackle this issue;  
otherwise  EQSD  will  be 
the main driver. 

Some 
emissions 
reductions 
(10-30%) 

POP 

Low 
threshold 
planned to be reduced. 

content 
for  PBDEs 

Some 
emissions 
reductions 
(10-30%) 

EQSD would be the main 
driver 
emission 
reduction. 

for 

Some 
emissions 
reductions 
(10-30%) 

change. 
No 
(+/-  10%  of 
current 
emissions 
No 
change. 
(+/-  10%  of 
current 
emissions 

has 

Use 
largely 
ceased.  Primarily  a 
legacy  issue  for  in-
use 
and 
stock 
landfill. 

IED; 
POPs 
Regulation;  Waste 
legislation 

No  longer  used,  but 
diffuse  sources  exist 
from past use. 

containing 
Dicofol 
DDT  under  severe 
restriction in Europe 

GWD, 

EQSD, 
DWD, 
International 
Convention  on  the 
Control of Harmful 
Anti-fouling 
Systems  on  Ships 
(AFS)  (the  HAFS 
Convention) 
Stockholm 
Convention, EQSD 

Not  produced  or 
into 
imported 
Europe 

Stockholm 
Convention  Annex 
A EQSD 

134 

 
 
 
Table A4.2: Dynamic baseline for groundwater pollutants  

Substance 
Pharma-
ceuticals  

Legislation or strategy driving change 
Pharmaceutical legislation & strategy 
The  Veterinary  Medicinal  Products 
Directive 
2001/82/EC; 
Directive 
2001/83/EC  —  Community  code  relating 
to medicinal products for human use 
EC pharmaceutical strategic approach 
Various guidelines on Environmental Risk 
Assessment for pharmaceuticals 

Industrial emissions Directive (IED) 

EQSD 

PFAS  

GWD  

REACH Regulation 

(POPs) 

Persistent  Organic  Pollutants 
Regulations 
Food  Contact  Materials  Regulation  (EC) 
Commission 
No 
Regulation (EU) No 10/2011  
Industrial Emissions Directive (IED) 

1935/2004; 

and 

Overall outcome 
+ from drive to reduce anti-microbial resistance in the 
environment  which 
reduces  use  as  veterinary 
medicines 

0 Environmental risk assessment process  may be too 
weak  to  have  an  impact  on  wider  groundwater 
limited  change  from  EU 
pollution  meaning  a 
pharmaceuticals strategy 
+  at  manufacturing  sites  for  pharmaceuticals  and 
future  expansion  of  scope  to  include  intensive  cattle 
farming  
+  Carbamazepine,  Erythromycin  and  Clarithromycin 
under consideration as PS 

++ for PFAS based on prevent and limit requirements 
and TVs. 
+  relevant  PFAS  (HFPO-DA  (better  known  as 
GenX86)  has  replaced  PFOA  as  processing  aid  for 
producing  fluoropolymers  and  PFBS)  for  future 
manufacturing 
+  for  relevant  PFAS  (PFOS  has  already  been 
restricted in the EU for more than 10 years) 
+  for  PFAS  (PFOA,  PFECA  and  ADONA)  not 
permitted  for  use  in  food  contact  materials.  EFSA 
threshold for PFAS TWI of 4.4 ng/kg) 
+ at manufacturing sites for PFAS 

Drinking Water Directive (DWD) recast 

++ in the long term  

EQSD 

nrMs 
pesticides  

of 

GWD  

Regulation  No  1107/2009  concerning  the 
placing of plant protection products on the 
market  

for  community  action 

Directive  2009/128/EC,  establishing  a 
framework 
to 
achieve  the  sustainable  use  of  pesticides 
(SUPD) 
Biocidal Products Regulation 
Stockholm Convention 

+ in long term for GWBs connected to SWBs. PFOS 
is  already  a  Priority  Substance  with  an  EQS  of 
0.00065 µg/l. 
++  based  on  measures  to  address  pesticides  through 
Annex I and Annex II listing and TVs  
++ for nrMs with banned parent compounds.  

++  where  permitted  parent  compound  is  reviewed  in 
light nrMs in groundwater  
+  for  nrMs  with  reduction  in  use  of  parent  product. 
SUPD  supports  the  Farm  to  Fork  initiative,  which 
aims  to  reduce  hazardous  pesticide  use  by  50%  by 
2030.  
+ for Tolylfluanid and Dichlofluanid 
+ for nrMs derived from POPs parent compounds  

Drinking Water Directive (DWD) recast  

+ for nrMs  

MS drinking water standards  
EQSD 

+ for nrMs  
+ in long term for GWBs connected to SWBs.  
Glyphosate (nrM parent) is under consideration as PS 

86  In  2019,  GenX  was  identified  as  a  Substance  of  Very  High  Concern  (SVHC):  https://echa.europa.eu/registry-of-svhc-intentions/-
/dislist/details/0b0236e1832708a2 

135 

 
 
 
                                                           
2.  Distance to target 

As explained in the main text of the SWD (in particular section 6.1.1), the distance to target 
cannot be determined for each Member State vis-à-vis each substance or group of substances 
under consideration because the monitoring data underpinning such measurement are either 
anonymised, incomplete or both. For the candidate priority substances, data from the surface 
water watch list is obtained from the JRC in an anonymised format, in which data reported by 
individual MS are separate but the counties are not named (e.g. it is clear which data belong 
to Country 1, but no indication of which MS it is). In the case of existing PS, data to inform 
the distance to target assessment is largely obtained from the WFD reporting, where reporting 
measured  concentrations  is  voluntary,  leading  to  a  fragmented  dataset.  In  the  case  of 
emerging groundwater pollutants, the voluntary nature of monitoring under the Groundwater 
Watch List limits the amount of data available. In addition, the measurements are reported in 
concentration  ranges  (e.g.  <LOQ,  ≥LOQ-0.05  µg/L,  0.05-0.1  µg/L  etc.),  therefore  it  is  not 
possible to know exact concentrations (22). 

Considering the above, it was necessary to adapt the distance to target methodology keeping 
in  mind  the  specific  data  availability  for  new  PS,  existing  PS  and  LFR  substances.  The 
sections  below  explain  the  approaches  taken  to  assess  the  scale  and  magnitude  of  the  gap 
between the current concentrations in surface and groundwater and the new quality standards 
considered for each pollutant. 

2.1. Substances for addition to PS list 

Criteria shown in Table A4.3 were developed to assess the ‘distance to target’ for candidate 
priority substances (PS). They allow for a pathway 1 (data -rich) or a pathway 2 (data -poor) 
assessment, depending on the number of MS (MS) reporting data. The criteria evaluate two 
metrics: the scale of the problem (i.e. how wide-spread geographically are exceedances of the 
proposed EQS, and, in the case of pathway 2, the temporal spread (i.e. how frequently do we 
see  exceedances  occur  consistently  year  on  year?),  and  the  magnitude  of  the  problem  (i.e. 
how large are the exceedances above the EQS?). Substances within each pathway are listed in 
Table  A4.4  below.  It  is  worth  to  note  that  the  uncertainty  in  the  results  for  substances 
assessed  under  pathway  2  will  be  bigger  than  for  those  under  pathway  1.  For  the  available 
monitoring data see Table A11.1 in Annex 11. 

Table A4.3: Criteria used to assess the size of the gap in EQS compliance 

Size of gap 

Decision tree pt 1. Monitoring data exists for ≥14 MS 
(assumed to include EU27+NO). Use these criteria. 

Decision  tree  pt  2.  Monitoring  data  exists  for  ≤14  MS 
(assumed to include EU27+NO). Use these criteria. 

Small 

Medium 

Large 

Scale: Predicted exceedances in ≤33% of MS based on 
the monitoring data available. 

Magnitude:  Based  on  AA  &  MAC  exceedances 
compared to predicted EQS + scale of non-detects as a 
measure  of  how  widespread  the  problem  is  nationally 
and how significant the scale of the exceedances. 

Scale: Predicted exceedances in ≥33% but ≤66% of MS 
based on monitoring data available. 

Magnitude:  Based  on  AA  &  MAC  exceedances 
compared to predicted EQS + scale of non-detects as a 
measure  of  how  widespread  the  problem  is  nationally 
and how significant the scale of the exceedances. 

Predicted  exceedance  is  infrequent  over  the  temporal  trend 
demonstrating  a  ‘patchy’  picture.  Additionally,  there  are  a 
high  level  of  non-detects  in  the  sample  set  (>50%),  and 
scale of the exceedance for any one year for AA or MAC is 
≤50% of the predicted threshold. (i.e. maximum AA /MAC 
is 1.5 x the EQS). 

Predicted  exceedances  occur  consistently  year  on  year 
across  the  temporal  trend  for  available  monitoring  data. 
Volume of non-detects in the sample is below 30%, scale of 
the  exceedance  for  AA  and/or  MAC  is  up  to  30%  for  all 
years. 

Scale: Predicted exceedances in ≥66% of MS based on 
monitoring data available. 

Magnitude:  Based  on  AA  &  MAC  exceedances 

Predicted  exceedances  occur  consistently  year  on  year 
across  the  temporal  trend  for  available  monitoring  data. 
Volume of non-detects in the sample is below 30%, scale of 
the  exceedance  for  AA  and/or  MAC  is  above  50%  for  all 

136 

 
 
 
compared to predicted EQS + scale of non-detects as a 
measure  of  how  widespread  the  problem  is  nationally 
and how significant the scale of the exceedances. 

years. (i.e. maximum AA/MAC is 1.5 x EQS for all years). 

Table A4.4: Data-rich and data-poor candidate priority substances 

Pathway 1 (data rich) 

Estrone (E1) 

17-Beta estradiol (E2) 

Ethinyl estradiol (EE2) 

Diclofenac 

Azithromycin 

Clarithromycin 

Erythromycin 

Carbamazepine 

Acetamiprid 

Clothianidin 

Imidacloprid 

Thiacloprid 

Thiamethoxam 

Bisphenol A 

of  MS 

providing 
No. 
monitoring  data  (last  10 
years) 

Pathway 2 (data poor) 

of  MS 

providing 
No. 
monitoring  data  (last  10 
years) 

Ibuprofen 

Nicosulfuron 

Bifenthrin 

Deltamethrin 

Permethrin 

Esfenvalerate 

Glyphosate 

Triclosan 

PFAS 

Silver 

8 

7 

2 

4 

5 

4 

13 

10 

6 

9 

26 

24 

18 

26 

24 

25 

25 

15 

22 

22 

25 

24 

21 

15 

The methodology followed a 2-stage process. For each substance, the screening criteria were 
used to rank the substance in a category defining the distance to target (i.e. compliance with 
the new EQS). This defines the distance to target as ‘large’, ‘medium’, or ‘small’. Then, the 
dynamic baseline was applied to assess whether the scale and magnitude of the exceedances 
would  be  altered  by  expected  changes  or  effects  in  other  policy  areas  and  mean  that  some 
substances need to be re-assigned. The completion of this process did identify a small number 
of substances, where as a result of emission reduction under the dynamic baseline the size of 
the gap could  be expected to  shrink in  the coming  years, meaning that substances could  be 
demoted to a lower group. No substances were identified against the dynamic baseline where 
they needed to be promoted up a group in terms of the size of the gap increasing. 

Table A4.5: Summary of the distance to target assessment for candidate priority substances  

Substance 
category 

Substance 

Current Distance to Target87 

Scale 
%  of  MS  with 
exceedances 
against  total  no.  of 
MS 
providing 
monitoring data 

Magnitude 
%  of  MS  with 
mean  monitored 
concentration 
>30% 
recommended 
EQS  

of 

Expected 
change 
Baseline) 

emission 
(Dynamic 

Overall 
expected 
Distance 
Target 

to 

Estrogenic 
hormones 
(pharmaceuticals) 

Macrolide 

Estrone (E1) 

Azithromycin 

17 
alpha-
ethinylestradiol (EE2) 

Large (83%) 

Large (94%) 

17 beta-estradiol (E2)  Medium (54%) 

Medium (58%) 

Some  reduction  (10% 
- ≤30%) 

Relatively 
large 

Medium 

Medium 

Medium (65%) 

Large (69%) 

Medium (54%) 

Medium (54%) 

Significant 

reduction  Medium 

87 Based on data from JRC substance dossiers submitted to the SCHEER, supplemented by data from JRC  

137 

 
 
 
 
                                                           
 
Small 

Small 

Relatively 
large 

Relatively 
large 

Medium 

Medium 

Small 

Small 

Small 

Small 

Relatively 
large 

Relatively 
large 

Relatively 
large 

Relatively 
large 

Relatively 
large 

Medium  

Substance 
category 

Substance 

Current Distance to Target87 

Scale 
%  of  MS  with 
exceedances 
against  total  no.  of 
providing 
MS 
monitoring data 

Magnitude 
%  of  MS  with 
mean  monitored 
concentration 
>30% 
recommended 
EQS  

of 

Expected 
change 
Baseline) 

emission 
(Dynamic 

Overall 
expected 
Distance 
Target 

to 

antibiotics 
(pharmaceuticals) 

Clarithromycin 

Small (16%) 

Small (32%) 

(30% - ≤50%) 

Erythromycin 

Small (4%) 

Small (4%) 

Diclofenac 

Large (80%) 

Large (84%) 

Some  reduction  (10% 
- ≤30%) 

Other 
pharmaceuticals 

Carbamazepine 

Large (100%) 

Large (100%) 

Ibuprofen 

Small (26%) 

Medium (40%) 

Triclosan 

Large 
(100%) 
(very  small  data-
set) 

Medium (40%) 

No change (≤10%) 

Neonicotinoid 
pesticides 

Acetamiprid 

Medium (36%) 

Medium (36%) 

Clothianidin 

Medium88 
to small (12%) 

(41%) 

Small (18%) 

Imidacloprid 

Medium (64%) 

Large (72%) 

Thiacloprid 

Medium 
to Small (29%) 

(58%)89 

Small (29%) 

Thiamethoxam 

Small (14%) 

Small (19%) 

Bifenthrin 

Large (100%) (very small data-set) 

Some  reduction  (10% 
- ≤30%) 

Medium 

Pyrethroid 
pesticides 

Deltamethrin 

Large (100%) (very small data-set) 

Esfenvalerate 

Large (100%) (very small data-set) 

Some  reduction  (10% 
- ≤30%) 

Permethrin 

Large (100%) (very small data-set) 

Glyphosate 

Large (92%) 

Large (92%) 

No change (≤10%) 

Nicosulfuron 

Large  (71%)90  to 
Medium (40%) 

Medium (40%) 

Some  reduction  (10% 
- ≤30%) 

PFAS  

Large (100%) (very small data-set) 

Bisphenol A 

Large (100%) (very small data-set) 

Significant 
(30% - ≤50%) 

reduction 

Relatively 
large 

Some  reduction  (10% 
- ≤30%) 

Relatively 
large 

Other pesticides 

Industrial 
chemicals 

Metals 

Silver 

Large  (89%91)  to  medium  (40%)  (very 
small data-set)  

Some  reduction  (10% 
- ≤30%) 

Medium 

2.2. Substances considered for EQS amendment  

88 Data used for the scientific dossier on Clothianidin, jointly prepared by the JRC and the WG Chemicals, based on a data set of more than 
12000 samples from 22 Member States, showed exceedances corresponding to 41% of the samples 

89 Data used for the scientific dossier on Thiacloprid, jointly prepared by the JRC and the WG Chemicals, based on a data set of more than 
15000 samples from 24 Member States, showed exceedances corresponding to 58% of the samples 

90  Data  used  for  the  scientific  dossier  on  Nicosulfuron,  jointly  prepared  by  the  JRC  and  the  WG  Chemicals,  based  on  a  data  set  from 
Member States, showed exceedances corresponding to 71% of the samples 

91 Data used for the scientific dossier on Silver, jointly prepared by the JRC and the WG Chemicals, based on a data set of more than 11000 
samples from 24 Member States, showed exceedances corresponding to 89% of the samples. 

138 

 
 
 
 
                                                           
The  assessment  for  the  amended  EQS  has  largely  been  completed  using  a  combined 
quantitative  and  qualitative  approach.  Quantitative  monitoring  data  were  used  where 
available  and supplemented by  data from  the EEA dashboards providing  details  around the 
current rate of exceedances for named substances, based on number of water bodies and MS 
(noting that a total of 137,000 surface water bodies are identified in the EEA data). Data from 
the  EQS  dossiers  (where  available)  include  data  from  monitoring  samples  from  a  large 
number of Member States allowing the calculations of exceedance rates.  In  communication 
with the Joint Research Centre, a two-stage process has been followed. Firstly, the data from 
the EEA dashboard for the number of waterbodies with exceedance and number of MS states 
with an exceedance has been used to assess the magnitude and scale of the issue in order to 
assign an existing ‘size of the problem’ (see Table A11.2 in Annex 11).  

Then as a second step based on the proposed EQS (where available) and guidance from the 
JRC, an assessment has been made as to whether the size of the gap would be worse, better, 
or the same following amendment of the EQS. Combined with the expected changes due to 
dynamic baseline, an overall distance to target has been determined, as shown in Table A4.6. 

Table A4.6: Summary of the distance to target assessment for existing PS substances considered for EQS 
amendment  

Substance 
category 

Substance 

Chlorpyrifos 

Cypermethrin 

Current  Distance 
Target 92 

to 

Scale 

Magnitude 

Change 
in 
distance  to 
target  due 
to 
new 
EQS 

Medium 

Small 

Increase 

Expected  emission 
change  (Dynamic 
Baseline) 

Medium 
(assumed) 

Medium 
(assumed) 

Increase 

Some 
(10% - ≤30%) 

reduction 

Diuron 

Medium 

Small 

Increase 

Pesticides 

Heptachlor 
Heptachlor epoxide 

and 

Small 
(assumed) 

Small 
(assumed) 

Decrease 

Hexachlorobenzene  Medium 

Small 

Decrease 

Tributyltin 

Large 

Medium 

Increase 

No change (≤10%) 

Some 
(10% - ≤30%) 

reduction 

Medium 

Dioxins and furans 

Medium 
(assumed) 

Medium 
(assumed) 

Increase 

Fluoranthene 

Medium 

Medium  

Decrease 

No change (≤10%) 

Hexachlorobutadiene  Medium 

Medium 

Large 

Small 

Small 

Medium 

Increase 

Increase 

Increase 

Medium 

Large 

Increase 

Large 

Large 

Increase 

Some 
(10% - ≤30%) 

reduction 

Significant 
reduction  (30%  - 
≤50%) 

Industrial 
 chemicals 

Metals 

Nonylphenol  

PAHs  

PBDEs  

Mercury 

Nickel 

Large 

Medium 

Increase 

Some 
(10% - ≤30%) 

reduction 

Relatively 
large 

to 

Overall 
expected 
Distance 
Target 

Medium 

Medium 

Medium 

Small 

Small 

Medium 

Small 

Small 

Small 

Medium 

Relatively 
large 

Relatively 
large 

2.3. Role of the ‘One-Out-All-Out’ approach 

92 Based on data from JRC substance dossiers submitted to the SCHEER 

139 

 
 
 
 
 
                                                           
Despite the observation that the estimated ‘gap size’ for an individual pollutant can vary from 
relatively large, medium or small, this is only a rough and indicative approach with a wide 
range of limitations. The ‘one-out-all-out’ (OOAO) principle that is embedded in the WFD, 
means that a WB can only achieve good status if this status is achieved for all pollutants. In 
other  words,  if  the  water  does  not  achieve  good  status  for  one  or  more  of  the  existing 
pollutants included in the assessment of the chemical  status,  the addition of a new PS does 
not  make  a  difference.  The  current  list  of  PS  under  the  EQSD  contains  53  priority 
(hazardous)  substances.  So  only  if  a  WB  achieves  good  status  for  all  those  53  pollutants, 
which is the case only for 38% of all WBs, the addition of a single new PS/PHS could make a 
difference between pass / fail. Thus, in the theoretical situation where 100% of the WBs in all 
MS  would  fail  to  achieve  good  status  based  on  this  single  pollutant,  the  maximum 
contribution  to  the  chance  for  a  WB  to  fail  to  achieve  good  status  could  be  1.9%  (1/53  * 
100%), based on a significant exceedance of the EQS for this new PS/PHS. To estimate the 
likely indicative contribution of adding a single substance to the PS list, the maximum 1.9% 
must  first  be  multiplied  by  38%  (the  no.  of  WBs  currently  achieving  good  status)  and 
subsequently  also  with  the  average  of  the  size  of  the  predicted  exceedances  (16.5%  for  the 
‘small’ category; 49.5% for the ‘medium’ category; and 83% for the ‘large’ category). This 
would  result  in  the  following  maximum  contribution  to  the  chance  to  fail  for  a  single 
substance added: 

  Small: 1.9% *16.5% *38%= 0.14% indicative contribution per substance  
  Medium: 1.9% *49.5% *38% = 0.36% indicative contribution per substance  
  Large: 1.9% *83% *38% = 0.59% indicative contribution per substance  

Multiplying the obtained values with the number of polluting substances under each distance 
to  target  category  mentioned  in  Tables  A4.5  and  A4.7  results  in  the  overall  cumulative 
contribution  of  the  new  and  revised  EQSs  to  the  chance  to  fail  to  achieve  good  status  of 
14.44%: 

  Small:  13  (no.  of  new  and  existing  substances  in  small  category)  *0.14%  =  1.82% 

indicative estimation of the additional contribution to failure to reach good status 

  Medium: 12 (no. of new and existing substances in medium category) *0.36% = 4.32% 

indicative estimation of the additional contribution to the gap size 

  Large:  13  (no.  of  new  and  existing  substances  in  large  category)  *0.59%  =  7.67% 

indicative estimation of the additional contribution to the gap size 

Although  this  estimate  cannot  be  directly  translated  into  the  efforts  required  by  each 
individual  Member  State,  it  provides  a  good  indication  of  the  ‘worst-case’  additional  good 
chemical  status  failures.  In  more  concrete  terms,  this  means  that  there  is  a  14.44%  chance 
exceedances of the new and amended EQSs cause failure to achieve good chemical status in 
any surface water body. 

Microplastics are excluded from these calculations at this stage since they can only be added 
to 
the  development  and 
implementation of the proposed harmonised EU methodology, have become available.  

list  after  monitoring  results,  obtained  following 

the  PS 

2.4. Groundwater 

The  lack  a  Europe-wide  risk  assessment  based  on  monitoring  data  for  the  LFR  pollutants 
means  that  an  estimation  of  the  likely  current  day  status  of  GWBs  in  relation  to  PFAS, 
pharmaceuticals  and  nrMs  is  needed  to  understand  how  the  problem  would  evolve.  To 
estimate  the  proportion  of  the  circa  13,746  GWBs  reported  on  by  the  EU27  which  are 

140 

 
 
 
potentially at risk of being at poor status due to these pollutants, the following assumptions 
were made:  

  The majority of MS will set a TVs based on the current day Drinking Water Standard 
(DWS) as this is  the most  commonly used criteria for TV setting. Although there are 
EQS  for  PFAS  (PFOA  and  PFOS),  pharmaceuticals  and  pesticide  metabolites,  this  is 
less likely to be used unless the GWB supports an aquatic ecosystem. 

  The most likely used chemical status test would be the General Chemical Assessment 
(GCA)93  test  (the  remaining  tests  are  not  relevant  or  would  need  more  detailed 
datasets).  

Criteria  shown  in  Table  A4.7  were  developed  to  assess  the  ‘distance  to  target’  for 
groundwater  options.  The  emissions,  pathways  and  detection  in  groundwater  were  used  to 
estimate  the  scale  of  pollution  and  whether  this  would  trigger  a  failure  of  the  General 
Chemical  Assessment  (GCA)  test.  Estimates  were  benchmarked  by  comparison  to  the 
number of GWBs at risk for substances with similar emissions, pathways and environmental 
fate which are listed in the GWD Annexes or lead to poor status of GWBs. 

Table A4.7: Criteria for the distance to target assessment for groundwater options  

Size of gap 

Criteria for scale of distance to target 

Small 

Medium 

Large 

Scale: Predicted GWB failure in ≤33% of MS reporting data (based on baseline impact and 
difference between GWQS and use of DWS) 

Magnitude: Extrapolation of GW WL results – 0-33% of monitoring points in the GW WL 
exceed the GWQS (or DWS if option is for an Annex II listing) 

Scale:  Predicted  exceedances  33%  to  66% of  MS  reporting  data (based  on  baseline  impact 
and difference between GWQS and current day use of DWS) 

Magnitude:  Extrapolation  of  GW  WL  results  –  where  33-66%  of  monitoring  points  in  the 
GW WL would exceed the GWQS (or DWS if option is for an Annex II listing) 

Scale:  Predicted  exceedances  in  over  66%  of  MS  reporting  data  (based  on  baseline  impact 
and difference between GWQS and current day use of DWS) 

Magnitude: Extrapolation of GW WL results – where 66% to 100% monitoring points in the 
GW WL would exceed the GWQS (or DWS if option is for an Annex II listing) 

Note that the likely time for changes in observed pollutant levels in groundwater is strongly 
controlled by the lag (residence) time in aquifers. Most shallow, rapid recharge aquifers have 
a residence time of between 10-30 years (e.g. gravel aquifers linked to river systems), whilst 
deeper, thicker, more consolidated aquifers can have residence times of 10 to 100 years. For 
some  of  the  LFR  substances  which  are  already  banned  or  whose  use  is  restricted  (PFOA, 
PFOS and the parent products of some nrMs), concentrations may already start decreasing in 
groundwater,  whilst  for  others  like  pharmaceuticals  they  are  increasing.  To  avoid  further 
deterioration  of  the  quality  and  to  reduce  the  level  of  purification  treatment  required  in  the 
production of drinking water, setting quality standards remains essential. 

93 The general chemical assessment (GCA) identifies significant pollution and requires that the pollutant(s) must be present at sufficient 
number of monitoring points to indicate either that the entire GWB is at risk (average concentrations exceed GWQS or TV) or that a 
significant proportion of the GWB is at risk (defined in CIS Guidance 18 as 20% or more of the area of a GWB).  

141 

 
 
 
 
 
                                                           
Table A4.8: Summary of the distance to target assessment for groundwater options  

Current Distance to Target 

Substance 
group 

Policy Option 

Scale 
%  of  reporting 
MS 
with 
predicted 
exceedances 

Magnitude 
% 
monitoring 
points 
predicted 
exceedances 

of 

with 

Options included in the main report 

Option  1  (Annex  I  -  list  of 
24  with  PFOA-equivalent 
4.4 ng/l GW QS) 

Option 2 (Annex I - sum of 
all at 0.5 µg/l GW QS) 

PFAS 

(Annex 

- 
Option  3 
assuming  TVs  set  using 
DWS) 

II 

I 

(Annex 

Option  1 
- 
Carbamazepine  at  0.1  µg/l, 
Sulfamethoxazole  at  0.5 
µg/l GW QS) 

Large (90%) 

Large (68%) 

Large (70%) 

Large (75%) 

Medium 
(35%) 

Large 
(2.5%)* 

(37% 
12.5%, 

Small 
and 
respectively) 

(8% 
0.43%, 

Small 
and 
respectively) 

Pharma-
ceuticals 

Option  2  (Annex  I  -  group 
at 0.5 µg/l) 

Medium 
(47%) 

Medium 
(50%) 

Option 3 (Annex II - group, 
considering 
Primidone; 
assuming  TVs  set  using 
DWS) 

Option  1  (Annex  I  -    all 
individually at 0.1 µg/l GW 
QS) 

Option  2  (Annex  I  -  group 
of all at 10 µg/l GW QS) 

(Annex 

Option  3 
- 
assuming  TVs  set  using 
DWS) 

II 

Small (17%) 

Small (1%) 

Large (93%) 

Medium 
(59%) 

Large (87%) 

Small (6%) 

Medium 
(40%) 

Small (2%)* 

Non-relevant 
metabolites  of 
pesticides 
(nrMs) 

Other options considered 

PFAS 

nrMs 

List  of  10  PFAS  identified 
by  the  GW  WL  in  Annex  I 
at 0.1 µg/l GW QS 

Large (70%) 

Large (75%) 

List  of  16  nrMs  identified 
by the GW WL individually 
at 1 µg/l GW QS 

List  of  16  nrMs  identified 
by the GW WL individually 
at 0.1 µg/l GW QS 

Large (80%) 

Small (29%) 

Large (93%) 

Medium 
(59%) 

*Magnitude is represented by % of groundwater bodies failing based on proxy substance. 

2.4.1.  PFAS  

European emissions 

Impact  of  change 
in  emissions  & 
aquifer lag time 

Overall 
expected 
Distance 
Target 

to 

- 

≤50% 
30% 
reduction  due 
to 
dynamic  baseline, 
but long aquifer lag 
times limit short- & 
medium-term 
impact. 

Large 

Large 

Large 

- 

10% 
reduction  due 
dynamic baseline 

≤30% 
to 

- 

10% 
reduction  due 
dynamic baseline 

≤30% 
to 

- 

≤50% 
30% 
reduction  due 
to 
dynamic  baseline, 
but long aquifer lag 
times limit short- & 
medium-term 
impact. 

- 

10% 
reduction  due 
dynamic baseline 

≤30% 
to 

Small 

Medium 

Small 

Large 

Medium 

Medium 

Large 

Medium 

Large 

PFAS are manufactured in a small number of locations in Europe and although they will be 
present at these manufacturing sites, their specific manufacture in the EU is restricted through 
the  Stockholm  Convention  on  persistent  organic  pollutants  (POPs).  As  concern  has  risen 
around  human  health  impacts,  the  use  of  some  PFAS  compounds  has  been  restricted  or 

142 

 
 
 
 
banned.  POPs Regulation (2019/1021/EU) implements the Stockholm Convention on POPs 
and  bans/restricts  the  manufacturing,  marketing  and  use  of  POPs  in  the  EU  (applicable  to 
PFOS,  PFOA,  PFHxS).  PFOS  and  PFOA  are  listed  under  Annex  A  (full  ban)  and  so  are 
restricted  globally  and  PFHxS  has  also  been  approved  for  listing  under  Annex  A.  Several 
PFAS (incl. PFOA, PFECA and ADONA) are not permitted for use in food contact materials 
under  the  Food  Contact  Materials  Legislation  (EC1935/2004)  and  Commission  Regulation 
(10/2011)  on  plastic  materials  and  articles  intended  to  come  into  contact  with  food. 
Therefore, the production or import within the EU of several PFAS on the LFR is currently 
restricted or banned. However, as PFAS are persistent they will continue to be in circulation 
in  products  and  further  releases  to  the  environment  will  take  place  and  the  main  source  is 
likely  to  already  be  in  the  environment.  PFAS  will  also  be  present  within  many 
environmental media where they can migrate into groundwater within recharge.  

Pathways to groundwater 

The widespread use of PFAS in domestic and industrial settings leads to entry to groundwater 
via many pathways including:  

  direct  emissions  to  ground  (biosolid  (including  anaerobic  digestate)  and  paper  / 
industrial  process  sludge  spreading  to  agricultural  land,  landfill  disposal,  sewage 
effluent discharges to ground);  

  diffuse  emissions  from  use  of  PFAS  products  (ski  wax,  personal  care  products, 
waterproof  clothing,  food  packaging  etc.)  and  aerial  deposition  of  particulates 
leaching to groundwater;  

  unintended emissions (fire-fighting foams, industrial use such as in chrome plating); 

and 
leakage from surface water (wastewater effluent discharges or aerial deposition).   

 

To date large scale groundwater pollution requiring remediation has been identified as due to 
the  use  of  fire-fighting  foams  at  airfields  and  fire  training  stations,  and  from  landfill  waste 
from industries using PFAS.  

Emissions via soils have been shown to lead to shorter chain PFAS reaching groundwater as 
longer  chain  substances  are  absorbed  by  soil  particles  until  the  absorption  capacity  is 
exhausted, after which also the longer chain substances will reach groundwater. This leads to 
longer lag-times for detection in groundwater and means that it is a matter of time until PFAS 
substances that are already found in  surface water will appear in  groundwater through both 
natural and artificial aquifer recharge. The persistent nature of PFAS and long residence time 
in some aquifers means that they are key groundwater pollutants already, or likely to become 
key groundwater pollutants in the future. 

Predicted current day risk and GWB status  

To  estimate  the  number  of  GWBs  potentially  at  risk  of  being  at  poor  status  due  to  PFAS 
pollution  it  was  assumed  that  the  majority  of  MS  would  set  a  TV  for  PFAS  based  on  the 
current day DWS (i.e. sum of 20 PFAS with a limit of 0.1 µg/l). 

For  PFAS  the  there  is  no  direct  comparison  with  the  existing  Annex  I  substances  or  the 
minimum list of substances listed in Annex II of the GWD. The only substances which may 
behave  in  a  similar  manner  are  the  chlorinated  solvents  (tetra-  and  trichloroethene)  in  that 
they are persistent and mobile organic pollutants. However, the main sources for chlorinated 
solvents  in  groundwater  are  leaks  and  spills  at  industrial  sites  and  dry  cleaners,  rather  than 

143 

 
 
 
 
chronic emissions through sewage disposal  or airfields. Additionally, the diffuse sources  of 
PFAS  (land  spreading,  aerial  deposition)  will  not  be  matched.  Therefore,  PFAS  pollution 
could  follow  patterns  similar  to  these  chlorinated  solvents  but  may  be  as  widespread  as 
pesticide pollution (land spreading of man-made chemicals) due to the wide range of source 
terms and pathways to groundwater. 

Based on the large number of sources, pathways to groundwater, plus known persistence and 
the  reported  detection  by  40%  of  MS  at  around  25%  of  monitoring  points  (for  PFOA) 
provided for the GW WL, it is likely that PFAS will lead to a number of failures of the GCA 
test. An estimate of the likely number could sit close to the impact of pesticides, i.e. 2.5% of 
GWBs with 38%. However, this assumes that all MS would set TVs for PFAS under Annex 
II,  and  therefore  under  the  current  GWD,  the  picture  for  PFAS  could  be  closer  to  that  for 
Tetrachloroethylene (0.9% GWBs at poor status and 35% of MS reporting a problem). 

Table A4.9: Benchmarking for PFAS GWB current day risk and status. 

leading 
Substance 
to  RBC2  GWB 
failure 

GWBs 
failing (No.) 

MS 
reporting 
failures (No.) 

Characteristics of pollutant 

Relevance to PFAS 

Emissions: widespread agricultural 
use  and  human  wastewater,  and  is 
naturally occurring (organic matter 
breakdown).  
Pathway: persistent 
GWQS  –  human  health  based 
(relatively  high  compared  to  man-
made chemicals) 

in 
in 

used 

Emissions:  widely 
agriculture  sector  but  also 
amenity use 
Pathway:  some  legacy  pesticides 
permitted 
persistent, 
can 
substances 
low 
typically  have 
persistence  in  soils  but  once  in 
groundwater can persist.  

be 

the  past 

Emissions: An industrial chemical, 
widely  used 
for 
in 
engineering / manufacturing works 
/  dry  cleaning,  typically  linked  to 
point sources 
Pathway:  persistent 
groundwater systems 

in  aerobic 

Nitrate 

8.2% (1137)  

96% (25)  

Pesticides 

Total 
(including 
metabolites) 

2.5% (341)  

38% (10)  

Tetrachloroethylene 
(PCE) 

0.9% (123) 

35% (9)  

2.4.2.  Pharmaceuticals  

European emissions 

due 
use 

Gives  a  worst  case  for 
any  new  listed  substance 
current 
(based 
on 
to 
knowledge) 
widespread 
and 
persistent behaviour.  
PFAS  likely  to  have  a 
lower  impact  on  GWBs 
due  to  relatively  smaller 
area of emissions.  

of 
scale 
Similar 
/  group  of 
emissions 
chemicals 
but  with 
different  characteristics 
and 
to 
pathways 
groundwater.  

due 

to 
Relevance 
industrial 
source,  but 
PCE  does  not  have  as 
many  pathways  to  the 
environment  as  it  is  not 
in 
expected 
to 
domestic  wastewater 
/ 
sludge.  

be 

Carbamazepine  is  an  anticonvulsant  medication  used  primarily  in  the  treatment  of  epilepsy 
and neuropathic pain caused by diabetes/condition called trigeminal neuralia. It may also be 
used to treat bipolar disorder.  There are several suppliers /manufacturers and exporters in the 
EU  including  in  Germany,  Poland  and  Portugal.   The  route  of  administration  appears  to  be 
oral only in the form of tablets and by prescription only. It is also less used as a veterinary 
medicine to treat seizures (epilepsy), chronic pain (primarily nerve pain), to treat aggression, 
to treat head shaking in horses although its use has decreased94. The number of people with 
epilepsy  in  the  EU  (6  million95)  is  likely  to  far  outweigh  the  number  of  horses  with 

94 Carbamazepine | VCA Animal Hospitals (vcahospitals.com) 
95 euro_report.pdf (who.int) 

144 

 
 
 
                                                           
headshaking (circa 5 million tame horses in the EU of which 1% (107) are estimated to have 
photic head shaking symptoms i.e. 50,000 cases). Therefore the main emission route will be 
through human prescribed use.  

Sulfamethoxazole  is  an  antibiotic  used  to  treat  bacterial  infections  such  as  urinary  tract 
infections,  bronchitis,  and  prostatitis. As  a  veterinary  medicine  it  is  commonly  used  as  an 
antibiotic in combination as Sulfamethoxazole/Trimethoprim. It is used for cats, dogs, birds, 
reptiles,  and  small  mammals  to  treat  certain  infections  such  as  bladder  and  prostate 
infections,  Nocardia  infections,  or  parasitic  infections.  It  has  been  used  prophylactically  in 
livestock  to  prevent  infections  in  herds  and  subsequently  detected  in  manures  and  their 
anaerobic digestates which are spread to land, potentially resulting in increased antimicrobial 
resistance  of  soils  (108).  The  introduction  of  restrictions  in  2019  on  prophylactic  use  of 
veterinary  medicines  in  livestock  husbandry  is  likely  to  reduce  this  later source  term.    One 
manufacturer of sulfamethoxazole is identified in the EU (Italy).  

Pathways to groundwater 

The  European  Union  Strategic  Approach  to  Pharmaceuticals  in  the  Environment  identifies 
that the largest source of pharmaceuticals entering the environment is through their use. The 
main  pathways  to  groundwater  will  therefore  differ  depending  upon  whether  human  or 
veterinary use is involved. It also states that “the chemical and/or metabolic stability of some 
pharmaceuticals means that up to 90% of the active ingredient is excreted (or washed off) in 
its  original  form.  Wastewater  treatment  varies  in  its  ability  to  eliminate  pharmaceutical 
residues96,  depending  upon  the  substance  and  the  level  of  treatment;  in  some  cases, 
substantial amounts are removed, in others, only a small percentage; but even the best, most 
expensive, current treatments are not 100% effective. The release of veterinary medicines to 
the  environment  tends  to  come  from  untreated  diffuse  sources  such  as  the  spreading  of 
manure.” 

The  main  routes  for  all  pharmaceuticals  to  groundwater  are  through  sewage  effluent 
discharge (including excreted pharmaceuticals and unused products disposed of to the sewage 
system despite the existence of collection schemes) and spreading of animal  manure. Other 
pathways include: 

the discharge of effluent from manufacturing plants; 
the spreading of sewage sludge containing pharmaceuticals removed from waste water; 

 
 
  grazing livestock and spreading of manures / digestates to land; 
 
 
 

the treatment of pets with run-off from excreta or washed off topical applications; 
improper disposal into landfill of unused pharmaceuticals and contaminated waste; 
recharge from surface water containing pharmaceuticals from wastewater discharge. 

Predicted current day risk and GWB status 

Pharmaceutical  pathways  to  groundwater  are  mainly  limited  to  wastewater  streams  and  the 
spreading  of  animal  manures  and  biosolids  derived  from  the  wastewater  treatment  regime.  
Depending  on  their  individual  properties,  these  substances  may  preferentially  partition  into 
the  solid  or  liquid  phases  (i.e.  be  retained  in  sewage  sludge  and  biosolids  or  the  effluent 
(109)).  The  pathway  from  land  spreading  of  biosolids  and  manures  is  likely  to  provide  a 

96 Metabolites (conversion products) may have lower biological activity (see case studies in http://ec.europa.eu/health/human-
use/environment-medicines/index_en.htm) but may, e.g. if conjugated, be converted back to the parent pharmaceutical during sewage 
treatment, or have similar biological activity. 

145 

 
 
 
 
                                                           
diffuse source of pollution to groundwater, whilst wastewater discharges to ground or surface 
water  are  more  likely  to  provide  point  sources  of  pollution.  Following  the  benchmarking 
approach, pharmaceuticals could be compared to current day GWB status of parameters such 
as  boron,  ammonium  or  phosphate  which  are  indicators  or  sewage  and  listed  on  Annex  II, 
although  the  latter  two  will  have  a  number  of  other  sources  (Table  A4.10).  Based  on  this 
assessment  the  probable  number  of  GWBs  at  poor  status  and  MS  reporting  failures  due  to 
pharmaceuticals is likely to be low: probably less than 1% of GWBs and perhaps up to 10% 
of MS reporting a failure.  

Table A4.10 Benchmarking for GWB status due to pharmaceuticals 

Substance 
leading 
RBMP2 
GWB failure 

to 

GWBs 
failing 
(No.) 

MS 
reporting 
failures 
(No.) 

Ammonium 

1.9% 
(265) 

58% (15)  

Characteristics of pollutant 

Relevance to Pharmaceuticals 

of 

(latter  may 

Emissions: 
sewage, 
Indicator 
contaminated land and denitrification of 
natural 
nitrate 
background) 
Pathway:  rapidly  transformed  to nitrate 
in  aerobic  conditions  so  failure  of 
GWBs  suggests  large  source  term  or 
anaerobic conditions.   

be 

(100 

An 
indicator  of  sewage  and 
animal  manure  inputs,  but  has  a 
times). 
higher  DWS 
overstates 
Probably 
pharmaceutical 
as 
to  most 
linked 
is 
ammonium 
landfills, 
some 
to 
and 
contaminated land sites.   

status 

Boron  

0.12% 
(17)  

8% (2)   

Emissions:  naturally  occurring  but  also 
an indicator of domestic sewage  
Boron occurs naturally). 

An indicator of sewage but biased 
to  only  2  MS  and  has  a  much 
higher DWS 

Phosphate 

0.2% (33)  

19% (5) 

Emissions:  use  in  agricultural  and  high 
levels in wastewater discharges  
Pathway:  could  demonstrate  surface 
water pathway connection 

An indicator of sewage but biased 
to only 5 MS. No DWS.  

2.4.3.  Non-relevant metabolites of pesticides (nrMs) 

European emissions 

Non-relevant metabolites from pesticides (nrMs) are not manufactured products, forming in 
the water environment through degradation of a parent pesticide compound. The pathway to 
groundwater is depends on the use / release of the parent compound. The predominant parent 
compound  use  is  for  plant  protection  by  the  agricultural  sector  as  herbicides  or  fungicides, 
but may include amenity purposes and as a biocide. The parent compounds Tolylfluanid and 
Dichlofluanid  are  fungicides  that  are  registered  as  biocides.  N,N-Dimethylsulfamid  (DMS) 
and Chlortalonil-SA are also fungicides.  The majority of parent compounds are not approved 
for  use  in  the  EU.  Whilst  the  source  term  for  nrMs  is  most  likely  to  be  diffuse  from  the 
leaching of the parent product, point sources of nrMs will also occur  from leakages around 
pesticide  handling  areas  (equipment  washing)  and  accidental  spills  or  illegal  storage  of 
banned parent substances.   

The  SANCO  guidance  (45)  sets  out  a  five  step  process  for  assessment  of  the  relevance  of 
metabolites, ending with a refined risk assessment for substances in groundwater identified as 
nrMs.  The  guidance  is  designed  for  use  by  organisations  applying  for  authorisation  of 
substances  under  EC  1107/20997  (the  plant  protection  products  regulations)  and  building  a 
body  of  evidence  which  will  then  be  reviewed  by  rapporteur  MS  and  EFSA.  New 
authorisations of substances listed under EC 1107/209 are valid for 10 years, whilst renewed 

97 Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009 concerning the placing of plant 
protection products on the market and repealing Council Directives 79/117/EEC and 91/414/EEC.  

146 

 
 
 
                                                           
authorisations  can  be  granted  for  up  to  15  years.  The  review  of  authorised  substances  is 
expected  to  include  new  data  /  modelling.  For  the  parent  compounds  of  LFR  nrMs  not 
approved  for  use  in  the  EU  the  presence  of  their  metabolites  is  likely  to  be  related  to 
historical use leading to a legacy issue, although illegal use cannot be ruled out. Some of the 
parent  compounds  have  not  been  authorised  for  use  for  many  years,  such  as  atrazine, 
indicating the persistence of the nrM and / or the parent compound. 

Pathways to groundwater  

The main pathway to groundwater for nrMs is mainly the leaching from soils following use 
of parent pesticides and transport downwards in recharging water to groundwater either as the 
parent compound or as the metabolite.   

Predicted current day risk and GWB status 

Given the source of nrMs, the obvious worst case scenario for the likely current day impact 
on GWB status would be the number of GWB that fail due to pesticide pollution. As the TVs 
that would be set at the current day are unlikely to be lower than the pesticide GW QS (based 
on reported TVs  used by  MS for nrMs) the number of reported fails is  likely to  be smaller 
than for total pesticides or the individual parent substance (Table A4.11), especially as some 
failures for pesticides are likely to be for substances without nrMs on the LFR. The estimated 
impact on current day status is likely to be between 0.5% and 2% of GWBs with up to 40% 
of MS reporting a failure.  

Table A4.11: Benchmarking for GWB status due to nrMs of pesticides 

Substance 
leading 
RBC2 GWB failure 

to 

No. 
GWBs 
failing 

No.  MS 
reporti
ng 
failures 

Total 
(including metabolites) 

Pesticides 

2.5% 
(341)  

38% 
(10)  

Alachlor 

Alachlor ESA 

Alachlor OA 

Atrazine 

Chloridazon 

Deisopropyldeethylatraz
ine 

4% (1) 

0.5% (63) 

4% (1) 

4% (1) 

0.4% (55) 

27% (7) 

4% (1) 

0.1% (12) 

8% (2) 

Desethylatrazine 

0.5% (69) 

19% (5) 

Desisopropylatrazine 

Glyphosate 

8% (2) 

Metazachlor ESA 

0.4% (58) 

4% (1) 

Metolachlor 

0.1% (14) 

12% (3) 

Metolachlor ESA 

12% (3) 

3.  Cost-benefit analysis 

Characteristics of pollutant 

Relevance 
nrMs 

to 

Emissions:  widely  used  in  agriculture  sector  but 
also in amenity use. 
legacy  pesticides  can  be 
Pathway: 
persistent,  permitted  substances  typically  have 
low  persistence  in  soils  but  once  in  groundwater 
can persist.  

some 

the 

Includes 
parent 
so 
products 
could  provide 
worst case.   

Parent  products  or  relevant  metabolites  of  LFR 
nrMs. 

the 

and 

Includes 
parent 
products 
some 
metabolites  so 
could  provide 
reasonable 
a 
worst 
case 
impact. 

Since  the  options  do  not  specify  the  exact  measures  to  be  taken  to  attain  the  set  quality 
standard,  the  assessment  of  the  potential  costs  and  benefits  of  measures  themselves  (as 
compared with the costs and benefits of additional guidance or monitoring) can only be based 

147 

 
 
 
 
 
 
 
 
 
 
on the potential measures that might be taken at EU or MS level as a result of the proposal. In 
addition, realisation of some of the benefits would be in the long-term. Benefits to health are 
extremely difficult to quantify, being dependent on many factors in addition to exposure and 
intrinsic hazard of the substances themsleves. 

3.1. Identification of possible measures and impacted stakeholders 

Completion of this part of the impact assessment has utilised in part the steps outlined within 
the  Better  Regulation  Toolbox  #16.  This  involves  developing  a  (dynamic)  baseline  (for 
means  of  comparison),  compiling  a  wide  range  of  policy  options  (and  underlying  practical 
measures),  screening  of  policy  options  (e.g.  addition,  amendment)  and  associated  measures 
and  then  detailed  analysis  of  the  associated  impacts  of  the  screened  set.  On  that  basis  the 
following steps have been undertaken. 

Step 1 – Measures identification  

The  first  step  in  the  process  was  to  identify  all  possible  measures  associated  with  different 
policy  options  (addition,  amendment).  This  was  treated  as  a  ‘blue  skies’  approach  with  no 
measure  excluded  from  the  assessment.  For  each  substance  (included  under  additions  and 
amendments)  based  on  the  profile  developed  (including  manufacture,  use,  and  pathway  to 
environment)  all  possible  measures  were  identified  that  could  intervene  at  all  stages  of  the 
life-cycle  to  help  achieve  good  chemical  status.  The  measures  identified  included  technical 
options such as restrictions and bans on usage, other options to limit emissions of all groups 
of  substances  and/or  abatement  and  wastewater  treatment.  Additionally,  for  persistent 
chemicals  or chemicals  already  banned presenting legacy  issues, measures were considered 
that could be applied directly to the natural environment as a means of intervention to achieve 
good chemical status (e.g. contaminated site remediation).  

Step 2 – Screening  

Following  the  development  of  the  ‘long  list’  under  step  1  a  screening  round  was  applied, 
largely  using  expert  judgement,  but  again  drawing  upon  the  criteria  listed  under  the  Better 
Regulation  Toolbox  #16  (see  pp114  and  115  of  the  toolbox).  The  measures  were  assessed 
based  on  technical,  economic,  and  legal  feasibility,  and  societal  acceptance.  For  some 
substances a total ban might be highly effective, but if the economic costs and societal impact 
would be disproportionate, this would affect the suitability score of the option. In this process 
a number of options were screened out. This resulted in a shorter list of measures that could 
be practically employed to help achieving good chemical status. 

Step 3 – Identification of impacted sectors 

Based on the preceding steps, using the screened list of measures, the key sectors likely to be 
impacted by the costs of implementing the measures from step 2 were identified.  

Table  A4.12  provides  a  high-level  matrix  of  the  screened  measures  for  the  substances 
(grouped into pharmaceuticals, pesticides/biocides, industrial chemicals, and metals) side by 
side.  This  should  help  illustrate  where  the  same  measure  could  be  used  for  multiple 
substances in a complimentary fashion. Very broadly the measures identified can be grouped 
into one of four overarching categories: 

  Source  control.  This  means  intervention  at  the  point  of  manufacture  and/or  use.  It 
can  include  technical  measures  such  as  improved  abatement,  on-site  treatment,  or 

148 

 
 
 
other  forms  of  emission  control.  It  can  also  relate  to  policy  measures  such  as 
restrictions/bans, or encouragement for substitution to safer alternatives. 

  Pathway disruption. This category relates to barriers in the environment that prevent 
egress to surface water, which are largely covered by technical options such as buffer 
strips, constructed wetlands, amendment of combined sewer overflows (CSOs) etc. 

  End  of  pipe  options.  This  category  relates  to  treatment  at  the  waste  phase,  again, 
largely  using  technical  options  such  as  quaternary  technologies  for  wastewater 
treatment, and improved landfill leachate capture systems etc. 

  Monitoring  and  natural  attenuation.  The  final  category  relates  to  a  limited  set  of 
substances  with  long  lasting  legacy  impacts,  where  the  best  option  may  be  natural 
attenuation. This  is  on the basis that dredging is high cost  and can potentially make 
water concentrations worse. 

Table  A4.12:  Possible  policy  measures  to  identify  and  subsequently  limit  emissions  of  PS  and  PHS 
respectively to identify costs and benefits (the possible burden). 

Type 

Pharmaceuticals 

Pesticides 

Industrial Chemicals 

Industry 

Manufacture 

Manufacture 

Metals 

Mining 

Agriculture  -  farmyard 
animals/ 
meat 
producing  –  natural/ 
drug use 

Pesticides  -  Agriculture  - 
fruits  &  veg/  grains/ 
potatoes  and 
legumes/ 
professional greenhouses 

Manufacturing - Primary  Manufacture 

- 
smelting / remelting 

Agriculture  -  Equines  – 
natural/ drug use 

Pesticides  -  Agriculture  - 
Emergency authorisations 

Manufacturing 
carbonate 

-  Poly 

Power  generation  - 
coal 

Veterinary - domestic 

Hospital applications 

Wastewater 
works 

treatment 

Energy 
(incineration) 

from  waste 

Pesticides - Amenity uses 
(e.g.,  parks,  pavements, 
etc) 

Biocides  -  veterinary  - 
agricultural 
(e.g. 
sheep) 

uses 

Biocides  -  veterinary  - 
domestic  uses  (e.g.  cats 
and dogs) 

Biocides  –  professional  – 
outdoor/  indoor/  directly 
to timer applications 

Biocides  –  amateur  – 
outdoor/indoor/directly  to 
timer applications 

Manufacturing 
resins, 
polishes 

paints, 

-  epoxy 
and 

Manufacturing 

Fire-fighting 

Textiles, furniture 

Electronics 
soldering 

Adhesives 
sealants 

- 

and 

Biocidal  products  - 
solids 

Biocidal 
applications 
liquids 

- 

Textile  applications 
- incl. jewellery 

Wastewater 
works 

treatment 

Paper  and  cardboard  - 
food packaging 

Lubricants 
greases 

and 

Construction 

Automotive 

Pharmaceutical 
manufacture 

Wastewater 
treatment works 

Electronics - incl. cabling 

Personal care products 

Plant protection products 

Aviation 

Medical applications 

Water distribution - pipes 

Wastewater 
works 

treatment 

149 

 
 
 
 
 
   
 
  
Type 

Social 

Pharmaceuticals 

Pesticides 

Industrial Chemicals 

Metals 

Health impacts: 

Food related impacts: 

i)  quality  of  life  effects 
(loss of medication/ less 
effective medication) 

i) loss of crop yields 

ii) loss of life 

ii) food security issues 

Loss 
items/articles 

of 

Choice 
of 
items/articles 

consumer 

consumer 

Loss  of  consumer 
items/articles 

Choice of consumer 
items/articles 

Infrastructure  -  range  of 
issues 

iii) food pricing issues 

Petroleum 
safety - firefighting 

industry 

- 

Additional  pressures  on 
health services 

Infrastructure - timber 

Impacts  for  social  and 
health care where PFAS is 
used 

Pet care - health of pets 

Possible  impacts  for  food 
production 

Loss  of  worker  days  to 
other businesses 

Alternatives 
efficacy, 
env. Impact 

- 

cost, 
emissions, 

Infrastructure 
- 
adhesives,  sealants, 
lubricants, greases 

health 
Potential 
impacts from loss of 
biocidal 
applications 

Agri/horticultural 
impacts  -  loss  of 
biocidal 
applications 

Environment  Landfill 

Landfill 

Landfill 

Naturally occurring 

Legacy  sites  of  former 
manufacture 

Legacy  sites  of  former 
manufacture 

Current 
manufacture 

sites 

of 

Landfill 

Spray drift 

Diffuse from automotive 

Legacy 
of 
former manufacture 

sits 

Diffuse from construction 

Legacy 
already in water 

concentrations 

3.2. General cost considerations 

The majority of costs are economic, described below based on the relevant impacted actors, 
which would include: 

  To MS Competent  Authorities responsible for meeting the obligations set  out  in the 
EQSD (i.e., monitoring and analysis, reporting, development of PoMs, and overseeing 
implementation of PoMs) and GWD. 

  To  companies,  following  polluter  pays  principles  and  need  for  greater  emission 

control or substitution of substances. 

  To water company operators, assuming that managing some of the issues associated 
with PS/PHS, Annex I and Annex II substances will fall upon water companies to an 
extent (monitoring and analysis, reporting, treatment, etc.) 

  To users, this would include both  within industrial  and professional  settings. Again, 
this  could  follow  the  polluter  pays  principle,  as  well  as  transition  to  alternatives/ 
changes in process etc. 

  To consumers, assuming that there could also be the need to share the burden of costs 
associated with treatment with consumers (i.e. through water bills, willingness to pay, 
etc.) or through impacts associated with substitution (i.e. more expensive alternatives, 
more expensive food, loss of products from the market, etc.). 

3.3. Environmental benefits 

150 

 
 
 
 
   
  
  
   
  
   
  
 
The  most  significant  environmental  benefit  from  addition  of  candidate  substances  to  the 
EQSD list (under Option 1 (add individually), 2 (add as groups), 3 (amend existing PS/PHS), 
4  (change  in  status),  5  (deselect))  or  GWD  Annex  I  or  Annex  II  is  that  it  promotes  action 
across the EU, in particular bilateral co-operation for MS with shared rivers and water bodies 
(60% of EU waters are transboundary). The use of standardised EQS, GW QS or an approach 
to  derivation  of  quality  standards  at  EU-level  provides  a  foundation  for  MS  to  work 
collectively  towards  protection  of  the  aquatic  environment.  Which  would  mean  the  efforts 
deployed would be more effective and efficient at managing chemical risks than MS working 
in isolation. 

Building upon the point above, regular monitoring of additional PS substances (under Option 
1, 2, 3 and 4 in surface water and Annex I and II substances in groundwater) has the added 
benefit of increased knowledge of the extent of water pollution across the EU. This allows the 
assessment  of  the  effectiveness  of  the  measures  taken  under  the  WFD  and  other  sectoral 
legislation  to  limit  substance  emissions  and  trigger  action  if  measures  are  insufficent;  this 
benefit would not  be achieved under the other sectoral  legislation alone.  It  should be noted 
that  monitoring  of  the  substances  in  surface  water  option  3  and  4  already  occurs,  and  that 
EQS for them already exist, but that changes in the EQS for some of those substances could 
act  as  a  driver  for  continued  improvement  of  monitoring  and  analytical  standards  and 
approaches. For surface water Option 5 (deselection), data and knowledge would be lost on 
these substances if removed from the PS list.  

Measures employed to deal with new or amended PS and related EQS and with GWD Annex 
I  and  Annex  II  substances  and  to  further  limit  chemical  emissions  should  help  to  improve 
biodiversity  (even  beyond  the  immediate  aquatic  ecosystem)  and  thus  result  in  a  more 
resilient aquatic ecosystem, enhancing its capacity to deliver ecosystem services such as the 
processing of excess nutrients (Cardinale 2011). Indirectly, this will also translate into better 
human health protection through a cleaner aquatic environment and cleaner drinking water.  

Cleaner sediments should result in less potential for re-dissolution of pollutants in the water 
column and reduced uptake of harmful substances by plants and animals. 

3.4. Economic benefits 

The  EQSD  and  GWD  provide  a  mechanism  for  monitoring  and  managing  substances  that 
represent an EU-wide risk. The addition of substances to the PS list / Annex I list  provides a 
standardised level playing field with which to manage the issue. This is important for surface 
water    and  groundwater  bodies  that  cross  political  boundaries  and  provides  impetus  for 
neighbouring MS to tackle issues in a consolidated fashion, which has economic benefits for 
all parties. 

Where  a  given  substance/s  is  identified  as  a  PS,  or  Annex  I  or  Annex  II  substance    it 
promotes the need for innovative measures to address the issues presented. If the substance is 
presented  as  an  issue  at  EU-wide  scale,  there  are  potential  economic  benefits  for  MS 
authorities, water companies, chemical manufacturers and other relevant stakeholders to pool 
resources. This would equate to a cost saving compared to the same stakeholders working in 
isolation at national level.  

Cleaner  sediment  negating  the  need  for  remediation  or  dredging.  This  recognises  that  a 
number  of  the  candidate  substances  are  less  soluble  and  likely  to  concentrate  within 
suspended solids, and then within sediments and biota in the natural environment. 

151 

 
 
 
Promotion of advancements in treatment technologies and innovation within the EU to deal 
with new PS and Annex I / Annex II substances. 

3.5. Social and public health benefits 

The following social and public health benefits have been identified: 

  Additional  information  will  be  available  to  the  public  on  the  PS/PHS,  Annex  I  and 

Annex II substances and the quality of the aquatic environment; 

  Reduced  bioaccumulation  of  hazardous  chemicals  in  humans,  reduced  exposure 

(occupational and other) if less hazardous substitutes are used; 

  Potential  improvements  in  quality  of  fish  and  shellfish  from  commercial  fisheries, 
aquaculture  and  recreational  fishing  (which  would  confer  economic  benefits  in 
managing resources more sustainably). These improvements will also benefit the push 
for  a  significantly  increase  organic  aquaculture  sector,  and  the  use  of  less 
antimicrobials in the sector98, which is again supportive to public health and building 
a sustainable food system99. 
Improved amenity value of water bodies (tourism, angling, etc), and reduced exposure 
for humans using them for bathing, surfing and other water sports; 

 

  Cleaner  water  for  livestock  where  surface  water  or  groundwater  is  used  directly, 
resulting in reduced accumulation in meat and milk, hence reduced human exposure 
to  hazardous  substances,  likewise,  less  accumulation  in  meat,  surface  waters, 
groundwaters and and drinking water; 

  Reduced potential for accumulation of hazardous substances in crops when untreated 

water is used for irrigation. 

98 Strategic guidelines for a more sustainable and competitive EU aquaculture for the period 2021 to 2030” (COM(2021) 236 final 

99 Farmed seafood has a comparatively low-carbon footprint in comparison to (intensive) livestock farms. 

152 

 
 
 
 
 
                                                           
ANNEX 5: RELATIONS BETWEEN ONGOING INITIATIVES AND THE PRESENT INITIATIVE 

impact  on 
Expected 
this  policy 
initiative 
(specified per group of 
substances) 

impact 

Evaluation  of  the  SSD 
has been excluded from 
(dynamic 
the 
baseline)  assessment  as 
at the time of analysis it 
was  still  at  early  stages 
of  the  better  regulation 
process. 

used 
Pharmaceuticals 
in  animal  farming:  10-
30% 
emission 
reduction 
Pesticides: no impact 
nrMs: n/a 
Silver: no impact 
PFAS: 
emission reduction 
BPA:  10-30%  emission 
reduction 

10-30% 

no 

Pharmaceuticals: 
impact 
Pesticides: no impact 
nrMs: 10-30% emission 
reduction 
Silver: no impact 
PFAS: 
emission reduction 
BPA:  10-30%  emission 
reduction 

10-30% 

N/A 

Initiative 

description 

Brief 
initiative 

of 

the 

Potential  interactions  and  added  value  of 
the preferred option 

of 
Sewage 

Evaluation 
the 
Sludge 
Directive 

This  Directive  regulates  the  use 
in  agriculture  and 
of  sludge 
includes limit values (mainly for 
heavy  metals)  when  sewage 
sludge is used in agriculture. The 
is  under  evaluation 
Directive 
before  deciding  on  its  possible 
revision.  

Revised 
Industrial 
Emission 
Directive 

Industrial 

The 
Emission 
Directive  (IED)  regulates  water 
and  air  emissions  from  large 
industrial  facilities.  Commission 
proposal  adopted  on  6  April 
2022. 

Revised 
Drinking  Water 
Directive  

effects 

intended 

The  Drinking  Water  Directive 
(DWD)  concerns  the  quality  of 
water 
for  human 
consumption.  Its  objective  is  to 
from 
protect  human  health 
adverse 
any 
of 
contamination  of  water  intended 
for  human  consumption  by 
ensuring  that  it  is  wholesome 
and  clean.  The  revised  DWD 
was  formally  adopted  on  16 
December  2020  and  entered  in 
force on 12 January 2021. 

Marine Strategy 
Framework 
Directive 

The Marine Strategy Framework 
Directive (MFSD) obliges MS to 
achieve  Good  Ecological  Status 
in  all  marine  waters  by  2020.  It 
will  be  revised  (Commission 
Proposal planned for 2023). 

Measures aiming at better controlling pollution 
at  source  notably  for  non-domestic  pollution 
will  contribute  to  improve  the  quality  of  the 
sludge, making it more suitable for agriculture. 
Actions to better capture and treat storm water 
overflows  and  urban  runoff  are  expected  to 
allow  capturing  more  micro-plastics  and 
increase  their  presence  in  sludge.  Moving 
towards  energy  neutrality  will  only  happen  if 
more sludge is digested (production of biogas).  

The  revised  IED  will  contribute  to  better 
control  emissions  to  air  and  water  from  large 
industrial  facilities  notably  for  what  relates  to 
non-domestic pollution. The inclusion of cattle 
farming  under  the  scope  of  the  Directive  will 
result in limited to weakly positive impacts on 
water  quality.  Besides  nutrients, this  concerns 
also veterinary pharmaceuticals. Monitoring of 
substances on the PS list will help evaluate the 
effectiveness of measures introduced under the 
IED. 
Also  the  revision  of  the  lists  of  polluting 
substances  and  the  reporting  thresholds  under 
the  Industrial  Emissions  Portal  Regulation 
(IEPR,  former  E-PRTR),  will  include  new 
emerging  pollutants  like  PFAS,  which  will 
help to better assess the actual emissions in the 
future (provided the legislator does not change 
these elements) 

The recast DWD is particularly relevant to the 
GW WL and LFR because it sets out drinking 
water  standards  for  a  minimum  list  of  20 
PFAS  substances  and  commits  the  EC  to 
developing  an  analytical  methodology  for 
these substances by 2024.  
Measures aiming at better controlling pollution 
at  source  will  improve  quality  of  surface  and 
groundwater,  which  in  turn  contributes  to 
lower  costs  of  (pre)treatment  as  a  result  of 
improved quality for potable water and process 
water for drinking water supply. 

includes 

the  marine  and 

reducing 
in 

(through 
the 
The  MFSD  GES 
the  presence  of 
‘descriptors’) 
contaminants 
the  aquatic  environment, 
including  in  seafood.  Given  the  strong  links 
between 
freshwater 
environment,  a  reduction  of  contaminants  in 
either is mutually beneficial (e.g. for migrating 
fish  and  generally  in  waterbodies  connecting 
river  and  sea  like  estuaries).  Moreover,  the 
WFD and the MSFD overlap geographically as 
the regards the first nautical mile off the coast. 

the 

153 

 
 
 
 
Initiative 

description 

Brief 
initiative 

of 

the 

Potential  interactions  and  added  value  of 
the preferred option 

impact  on 
Expected 
this  policy 
initiative 
(specified per group of 
substances) 

Listing  of  substances,  especially  for  surface 
water,  will 
these 
reduction  of 
to 
substances in the linked marine waters. 

lead 

Revised  Urban 
Waste  Water 
Treatment 
Directive 

The UWWTD obliges collection 
and  treatment  of  waste  water 
agglomerations. 
from 
is 
currently 
revision 
under 
(adoption planned for July 2022) 

It 

for 

Proposal 
Nature 
Restoration 
Regulation 
(NRR) 

for  a  Nature 
The  proposal 
Restoration 
Regulation, 
scheduled  for  20  June  2022, 
aims  at  restoring  ecosystems  in 
the  EU, 
aquatic 
ecosystems.  

including 

for 

reporting 

The revised UWWTD is likely to bring a range 
of important improvements in the period up to 
2020.  The  better  management  of  storm  water 
overflow  should  reduce  plastic  pollution.  The 
increased  connection  of  UWWTPs  below 
2000pe  in  combination  with  lowering  the 
to  a  wastewater 
threshold 
treatment  to  1000  inhabitant  equivalent  and  a 
stricter  inspection  of  ‘individually  appropriate 
systems’ should reduce diffuse pollution of all 
types  and  their  monitoring.  Specifically,  to 
reduce  pollutants  ending  up 
in  effluents 
producer responsibility schemes will be set up 
and 
become 
mandatory  for  areas  at  risks  and  in  bigger 
agglomerations.  The  resulting  waste  water 
sludge will, as result, contain more pollutants. 

treatment  will 

advanced 

The  NRR  will  directly  contribute  to  increase 
the  green  areas  in  the  cities  and  therefore  the 
capacities  of  urban  soils  to  absorb  rainwater. 
In case heavy rains, less ‘clean’ rainwater will 
be  mixed  to  polluted  waters  in  the  urban 
collecting  systems  and  less  untreated  water 
will be sent to the environment. Outside cities, 
the  NRR  will  lead  to  more  natural  river  and 
lake  systems,  allowing  water  to  be  retained 
longer 
capacity  of 
ecosystems to purify water. The precise effects 
on  water  absorption  of  the  NRR  will  depend 
on  the  very  local  circumstances,  but  both 
legislations will act in a synergetic way.  

restoring 

and 

the 

Mercury 
Regulation 

The  2017  Mercury  Regulation 
prohibits  the  export  and  import 
of  mercury  containing  products 
and phases out its uses  

reduce 
The  Mercury  Regulation  will 
significantly  any  new  emission  of  mercury  to 
water.  However,  mercury  deposition  (eg  as  a 
result  of  burning  coal)  will  continue  and 
mercury  currently  in  the  aquatic  environment 
is extremely persistent. 

Ban  on  all  but 
the 
essential 
uses of PFAS 

The  Chemicals  Strategy 
for 
Sustainability  announced  a  ban 
on  all  but  the  essential  uses  of 
PFAS. Commission proposal for 
a  ban  on  placing  on  the  market 
of PFAS expected end of 2024. 

Depending on the final definition of ‘essential 
use’, this should over time significantly impact 
on  new  emissions  to  water.  Existing  products 
containing  PFAS  will  however  continue  to 
emit PFAS over the years to come. 

this 

includes 

Revised 
Directive 
assessed to lead to 44% 
reduction  of  toxic  load 
(which 
the 
substances  considered 
in 
initiative)  of 
which 64% are in areas 
of risk. 
the 
Revision 
been 
UWWTD 
the 
excluded 
impact 
(dynamic 
baseline)  assessment  as 
at the time of analysis it 
was  still  at  early  stages 
of  the  better  regulation 
process. 

of 
has 
from 

In the long term (2050) 
increased 
the  gradual 
of 
restoration 
will 
ecosystems 
increase 
the 
purification  capacity  of 
nature, leading to lower 
emissions  to  water  for 
all substances. 

Significant  impact  on 
new  emissions  except 
those deposited through 
the  air;  limited  impact 
mercury 
on 
given 
concentrations 
large 
legacy 
concentrations. 

legacy 
Significant 
pollution 
PFAS 
remains, new emissions 
will gradually decrease, 
depending on the scope 
of the PFAS ban. 

Regulation  on 
the  Sustainable 
Use  of  Plant 
Protection 
Products (SUR) 

A  proposal  for  a  Regulation  on 
the  Sustainable  Use  of  Plant 
Protection  Products  (SUR) 
is 
scheduled  for  adoption  by  the 
Commission on 20 June 2022. 

The SUR will introduce a binding target at EU 
level of 50% pesticide use and risk reduction, 
and  require  MS  to  set  nationally  appropriate 
binding targets. It will also prohibit the use of 
any  pesticide  in  urban  areas  and  vulnerable 
zones under nature legislation (eg Natura 2000 
sites)  and  water  legislation  (for  WFD  the 

Achieving 
the  50% 
reduction  will  only  be 
partially  the  result  of 
the SUR – other factors 
are  change  of  crops, 
nature 
protection, 
substitution.  The  SUR 

154 

 
 
 
 
Initiative 

description 

Brief 
initiative 

of 

the 

Potential  interactions  and  added  value  of 
the preferred option 

the  results  of 

in  urban  areas 

drinking  water  protection  zones).  Once 
implemented  this  should  significantly  reduce 
especially  pesticide  pollution  from  diffuse 
sources,  while 
it  will 
complement 
the  modified 
UWWTD. 
An  improved  digital  data  collection  on  use, 
quantities,  geographical 
and 
seasonal  pesticides  use,  under  the  envisaged 
of  Pesticides 
revised  Sustainable  Use 
Regulation,  would  provide  hugely  valuable 
input  for  an  improved  implementation  of 
legislation  like  the  WFD  and  the  EQSD,  as 
well as the EU Biodiversity Strategy 2020, the 
common  agricultural  policy  (CAP),  and  the 
Thematic Strategy on Soils. 

application 

Veterinary 
pharmaceuticals 
legislation 

The  Veterinary  Pharmaceutical 
legislation  regulates  the  placing 
on  the  market,  manufacturing, 
import, 
supply, 
export, 
distribution,  pharmacovigilance, 
control  and  use  of  veterinary 
medicinal products. 

of 

Revision 
Human 
Pharmaceuticals 
Legislation 

The  Human  Pharmaceuticals 
Legislation regulates the placing 
the  market  as  well  as 
on 
authorisation,  supervision  and 
phar-macovigilance of medicinal 
products 
human 
for 
consumption.  A  Proposal  for 
revision is scheduled for 2022.  

Initiative 
micro-plastics 

on 

to 

The  Micro-plastics  initiative  is 
reduce 
expected 
non-
intentional 
micro-plastics 
emissions  from  some  sources 
such  as  textiles  and  geotextiles, 
tyres,  plastic  pellets,  paints,  and 
detergent capsules. 

cause 

The  Veterinary  Pharmaceutical 
legislation 
requires  an  environmental  risk  assessment  to 
be  performed  to  assess  the  potential  harmful 
the  veterinary 
effects,  which 
the  use  of 
medicinal  product  may 
the 
to 
environment  and  to  identify  the  risk  of  such 
effects. The assessment shall also identify any 
precautionary  measures  which  may  be 
necessary  to  reduce  such  risk.  Relevant  to 
water,  a  guidance  on  the  environmental  risk 
assessment  of  medicinal  products  for  use  in 
including,  where  appropriate, 
aquaculture 
recommendations 
risk  management 
for 
measures  is  being  develop.  Once  ready,  this 
would promote a more prudent and responsible 
use of veterinary medicines. 

The  Human  Pharmaceuticals  Legislation 
requires  Environmental  Risks  Assessment 
(ERA) of pharmaceuticals to be placed on the 
EU  market.  However  such  ERA  are  not 
required  for  many  of  the  pharmaceuticals 
currently  on  the  market.  Requiring  ERA  may 
not  prevent  active  pharmaceutical  ingredients 
reaching  the  aquatic  environment;  they  would 
however  provide  national  authorities  with 
information  useful  to  manage  emissions  and 
impacts.  

With  the  planned  initiative  and  in  the  mid-
term,  lower  emissions  of  micro-plastics  from 
these sectors could be expected in urban waste 
waters. However even if all possible measures 
are  taken  to  reduce  emissions  at  source,  there 
will  always  be  residual  emissions.  Micro-
in  wastewater 
plastics  are  well  captured 
treatment  plants  (between  80%  up  to  99% 
when  tertiary  treatment  is  in  place).  The 

155 

impact  on 
Expected 
this  policy 
initiative 
(specified per group of 
substances) 

the 

alone will likely have a 
limited  negative  impact 
on the concentrations of 
pesticides in water. 
An 
data 
improved 
collection  on  pesticide 
use  at  farm  level  will 
improve 
data 
quality  on  pesticides 
which  will  not  only 
reduce  costs  related  to 
data  assessment  related 
to  setting  future  EQSs, 
but  also  speed  up  the 
of 
identification 
emerging  health  and 
environmental risks and 
the 
of 
revision 
standards  to  scientific 
progress. 

effect 

ERA and guidelines are 
expected  to  lead  to  a 
on 
limited 
emissions  of  relevant 
veterinary 
pharmaceuticals, 
particularly 
in 
areas. 

rural 

Very  limited  impact;  if 
any,  it  will  be  from 
increased 
pharmacovigilance 
stricter 
following 
application  of  ERA  for 
relevant 
human 
pharmaceuticals, 
particularly 
areas. 

in  urban 

Overall  EU  target  of 
30%  reduction  by  2030 
(cf  ZP  Action  Plan). 
Mix of  measures as  yet 
not  established  (impact 
assessment ongoing).  

 
 
 
 
Initiative 

description 

Brief 
initiative 

of 

the 

Potential  interactions  and  added  value  of 
the preferred option 

proposed  measures  under  the  UWWTD  will 
improve the abilities of capturing more micro-
plastics in the collecting and treatment system. 
The  proposed  monitoring  of  microplastics  in 
surface  water  will  be  complementary  to  this 
initiative.  

The  planned  initiative  support  the  efforts  to 
reduce  plastics  in  water  by  developing  a 
methodology  and  a  mechanism  to  monitor 
presence  of  microplastics 
the  aquatic 
environment. On the other way around, the EU 
plastics  strategy  and  its  related  actions  will 
drive  down  the  presence  of  such  plastics. 
Thus, 
initiatives  are  working 
two 
the 
complementarily.  

in 

The  push  for  product  circularity  under  the 
Ecodesign  Regulation  will  promote  reduction 
and/or phase-out of some hazardous chemicals 
which  currently  may  hinder  the  circularity 
potential  of  the  product.  This  will  reduce  the 
manufacturing and end-of-life releases of such 
substances  into  the  environment,  including 
water bodies. 

label 

verified 

of 
into  account 

The  new  EU  Ecolabel  criteria  for  cosmetics 
and  animal-care  products  (adopted  in  October 
2021),  offers  consumers  across  the  EU  the 
benefit  of  trusted  proof  for  genuine  green 
brands.  The  EU  Ecolabel  is  a  reliable  third 
party 
environmental 
the 
takes 
excellence,  which 
environmental impact of a product throughout 
its entire life-cycle, from the extraction of raw 
materials  to  final  disposal.  Consequently  the 
uptake of the EU ecolabel for this category of 
products  can  drive  down  emissions.  Today, 
three out of four care products sold in Europe 
display  an  environmental  claim  or  label,  and 
yet  many  of  these  claims  are  difficult  to 
understand or confusing for the consumer. 

EU  Strategy  for 
Plastics 
a 
Circular 
Economy 

in 

for 

Ecodesign 
Sustainable 
Products 
Regulation 

EU Ecolabel 

The EU Strategy for Plastics in a 
Circular  Economy 
proposes 
action  along  four  strands:  1) 
intentional 
to 
restrictions 
addition  of  microplastics 
to 
products via REACH, 2) actions 
on  unintentional 
release  of 
microplastics,  3)  measures  to 
reduce plastic pellet spillage and 
4)  use  of  UWWTD  to  capture 
and remove microplastics 

life 

The  proposal  aims  to  reduce  the 
cycle 
negative 
of 
environmental 
impacts 
products 
the 
and 
improve 
functioning  of 
internal 
the 
significantly 
market 
improving  product  circularity, 
energy  performance  and  other 
environmental 
sustainability 
aspects. 

via 

updated  EU  Ecolabel 
The 
criteria  now  applies 
to  all 
cosmetic  products,  as  defined 
EU  Cosmetic 
the 
under 
EU 
Regulation. 
Previous 
Ecolabel 
only 
requirements 
covered  a  limited  range  of  so-
called  ‘rinse-off’  products  such 
as  body  wash,  shampoo  and 
conditioner.  The  updated  rules 
include 
cosmetics 
‘leave-on’ 
such  as  creams,  oils,  skin-care 
lotions,  deodorants  and  anti-
perspirants,  sunscreens,  as  well 
as  hairstyling  and  make-up 
products. 
the  animal-care 
sector,  the  EU  Ecolabel  can  be 
awarded  to  rinse-off  products, 
such  as  soaps  and  shower 
preparations.  

In 

impact  on 
Expected 
this  policy 
initiative 
(specified per group of 
substances) 

Strategy  will  support 
action  to  achieve  the 
30%  reduction 
target 
for  microplastics  by 
2030 cf ZP Action Plan 

Longer  term  effect  on 
emissions  (in  use  and 
end-of-life) 
of 
industrial 
chemicals, 
including PFAS. 

Limited 
positive 
impact;  if  any,  but  an 
increased  uptake  could 
reduced emissions from 
(e.g. 
pharmaceuticals 
agents, 
conservation 
substances 
with 
endocrine 
disrupting 
effects,  microplastics 
and PFAS) contained in 
personal care products. 

EU  Strategy  for 
Data, 
the 
INSPIRE 
Directive, 
and 
the Directive on 
Public  Access 
to 
Environmental 

The  strategy  for  data  aims  at 
creating a single market for data 
that  will  boost  the  Europe’s 
global  competitiveness  and  data 
sovereignty.  Common  European 
data spaces will ensure that more 
data becomes available for use in 
the  economy  and  society,  while 
the  companies  and 
keeping 

emissions 

Water  related  data  could  complement  and  be 
referenced  with  publicly  available 
cross 
environmental  data  on 
from 
industrial  installations  covered  by  the  IEPR 
and  e.g.  help  monitor  the  effects  of  the 
implementation  of  new  Best  Available 
the  aquatic  environment 
Techniques  on 
surrounding  such 
installations.  This  also 
benefits  data  made  available  under  the  EU 

156 

as  data 
once 

positive 
Limited 
is 
impact; 
and 
collected 
reused  many 
times, 
thus  generating  clear 
synergies  and  reducing 
costs,  while  boosting 
innovation  in  the  data 
e.g. 
economy, 

like 

 
 
 
 
Initiative 

description 

Brief 
initiative 

of 

the 

Potential  interactions  and  added  value  of 
the preferred option 

impact  on 
Expected 
this  policy 
initiative 
(specified per group of 
substances) 

Information 

the 
individuals  who  generate 
data 
in  control.  Data  driven 
applications  will  among  others 
be  aimed  at  improving  health 
care,  create  safer  and  cleaner 
transport  systems,  generate  new 
products and services, reduce the 
costs  of  public  services  (by 
reusing  data  multiple times)  and 
and 
improve 
energy  efficiency.  As  part  of  its 
data  strategy  the  Commission 
has  proposed  a  Regulation  on 
European data governance. 

sustainability 

INSPIRE Directive 
Clear  synergies  exist  between  this  initiative, 
the  Zero  Pollution  Outlook, 
the 
Commission  proposal  for  a  Regulation  of  the 
Industrial  Emissions  Portal  (IEPR,  former  E-
PRTR),  the.  Especially,  data  collected  under 
policy  options  3,  4,  6  and  7  would  lead  to 
better  water  quality  data  in  shorter  than  the 
current 6-years intervals 

and 

to 

real 

time 

close 
environmental 
monitoring  data 
for 
authorities and citizens. 

The  EU  strategy  for  sustainable 
and  circular  textiles  addresses 
the  production  and  consumption 
of  textiles  and  aims  that  all 
textile  products  placed  on  the 
EU  market 
durable, 
repairable  and  recyclable,  to  a 
great  extent  made  of  recycled 
hazardous 
fibres, 
substances,  produced  in  respect 
of 
the 
rights 
environment. 

social 

free 

and 

are 

of 

Effect  on  microplastics 
industrial 
and 
chemicals 
including 
PFAS  used  in  textiles 
production 

The  Textile  Strategy  will  harmonise  EU 
Extended  Producer  Responsibility  rules  for 
textiles  and  economic  incentives  to  make 
products more sustainable. It will also address 
the  unintentional  release  of  micro-plastics 
from synthetic textiles. 

currently 

The  Environmental  Liability 
Directive, 
under 
revision, sets the EU framework 
for 
liability, 
including compensation. 

environmental 

The  Environmental  Liability  Directive  could 
lead to compensation for water damage caused 
by  pollution  (including  the  pollutants  to  be 
added  under 
IED 
installations or discharges to water in breach of 
WFD 

initiative) 

from 

this 

implemented 

If 
proposed, 
negative 
emissions 
abstractions. 

effect 

Textile Strategy 

Liability 
Directive 

Environmental 
Crime Directive 

Environmental 
currently 

Crime 
The 
Directive, 
under 
revision,  sets  the  framework  for 
environmental crime. 

The Environmental Crime Directive would, in 
situations  where  the  damage  is  the  result  of  a 
breach  and  intentional,  give  rise  to  criminal 
sanctions. 

Commission 
Communication 
‘Strategic 
guidelines  for  a 
more 
sustainable  and 
competitive  EU 
aquaculture  for 
the 
period  2021  to 
2030’ 

to 

by 

annex 

The 
this 
Communication  also  proposes 
the 
actions 
specific 
Commission,  the  EU  Member 
the  Aquaculture 
States  and 
Advisory  Council 
to  make 
progress  in  various  areas  to  the 
make 
the  aquaculture  sector 
more  sustainable  while  ensuring 
its 
The 
competitiveness. 
guidelines  reinforce  the  specific 
the 
from 
targets 
aquaculture 
Farm 
in 
to  Fork  Strategy, 
particular  the  reduction  of  sales 
of 
a 
significant  increase  in  organic 
aquaculture. 

antimicrobials 

and 

a 

guidance 

document 

In  the  process  of  implementation  of  the 
“Strategic  guidelines  for  a  more  sustainable 
and competitive EU aquaculture for the period 
2021  to  2030”,  the  Commission  plans  to 
develop 
on 
environmental  performance  in  the  aquaculture 
sector.  This  will  include,  among  other  issues, 
the  mapping of  good practices  for  the  “use  of 
chemicals and medicines” at governmental and 
the 
industry 
level. 
to 
Commission  highlighted 
develop  solutions 
the  use  of 
veterinary  products  and  other  substances  (e.g. 
anti-fouling  agents),  through,  for  example, 
appropriate husbandry practices. 

the  guidelines, 

the  necessity 

to  reduce 

In 

157 

as 
small 
on 
/ 

as 
small 
on 
/ 

implemented 

If 
proposed, 
negative 
emissions 
abstractions. 

effect 

implemented 

as 
small 
on 

a 
effect 

If 
foreseen 
positive 
emissions. 

 
 
 
 
impact  on 
Expected 
this  policy 
initiative 
(specified per group of 
substances) 

emissions 

Implementation  of  the 
Convention  will  drive 
down 
of 
POPs.  If  further  POPs 
are  added  in the  future, 
corresponding 
measures  will  have  to 
be  taken  by  EU  and 
MS. 

emissions 

Implementation  of  the 
Convention  will  drive 
down 
of 
mercury. If further uses 
/ 
regulated 
are 
prohibited  through  the 
Convention,  EU  /  MS 
will  have  to  implement 
this as well. 

in  water 

Monitoring  methods 
of 
and 
regulation 
plastics 
is 
relatively  new  area  and 
initiative  may 
this 
inspire  what  rules  are 
agreed 
the  global 
in 
instrument.  

Initiative 

description 

Brief 
initiative 

of 

the 

Potential  interactions  and  added  value  of 
the preferred option 

Stockholm 
Convention 
(POPs) 

The  Stockholm  Convention  on 
Persistent  Organic  Pollutants 
regulates 
either 
prohibiting their presence on the 
market  or  reducing  /  regulating 
their use. 

POPs 

by 

The EU and MS are a party to the Convention 
and have to implement its decisions in the EU 
/ MS 

Minamata 
Convention 

The  Minamata  Convention 
regulates  Mercury  mining, 
storage and use. 

The EU and MS are a party to the Convention 
and have to implement its decisions in the EU 
/ MS 

Global  Plastics 
Agreement 

The  UN  Environment  Assembly 
agreed, 
launch 
negotiations  towards  a  globally 
binding agreement on plastics 

in  2022, 

to 

While  still  many  years  before  such  an 
agreement  will  enter  into  force,  it  is  likely  to 
have  significant  impacts  on  what  plastics  stay 
on the market and in what quantities these will 
reach the environment 

158 

 
 
 
 
 
ANNEX  6:  TECHNICAL  PROCESS  FOR  THE  REVISION  OF  THE  LIST  OF  PRIORITY 
SUBSTANCES AND THEIR EQS IN SURFACE WATER 

1. 

Introduction 

The review of the list of priority substances (PS) in surface waters under the Water WFD 
considered which substances should be added to the list of PS, the environmental quality 
standards  (EQS)  that  should  be  set  for  them  in  the  EQS  Directive  (EQSD),  the 
deselection of existing PS, the revision of EQS for some others, and the designation of 
priority hazardous substances (PHS). PHS are a subset of PS that are identified as being 
“toxic,  persistent  and  liable  to  bio-accumulate,  and  other  substances  or  groups  of 
substances which give rise to an equivalent level of concern” (WFD article 2(29)). In this 
context,  the  substances  identified  by  the  following  processes  and  legislations  are 
relevant: Substances of Very High Concern (SVHC) under REACH, Persistent Organic 
Pollutants  (POPs)  under  the  Stockholm  Convention  and  substances  identified  as 
Persistent, Bio-accumulative and Toxic (PBTs) under Regulation (EEC) No.793/93. 

The prioritisation  exercise (to identify  new PS)  was based on the criteria set  out  in the 
WFD  Article  16(2),  and  the  derivation  of  EQS  followed  the  2018  Technical  Guidance 
Document for deriving EQS (53). Thresholds are usually set one substance at the time, 
except for cases where adding substances in groups (of substances with similar effects) 
has a clear added value. The multi-dimensionality of water pollutants and their effects is 
addressed  by  the  fact  that  for  each  substance,  where  possible,  EQSs  are  derived  for 
different  types  of  media  (inland  surface  waters,  other  surface  waters,  and  biota)  and 
different  concentrations/  multivariate  thresholds  (Annual  Average  (AA)  and  Maximum 
Allowable Concentration (MAC)). 

2.  Technical process underpinning the selection of substances 

The technical work for the review was led by the Joint Research Centre (JRC) and DG 
ENV,  in  close  cooperation  with  subgroups  of  experts  and  members  of  the  Working 
Group (WG) Chemicals under the Common Implementation Strategy (CIS) for the WFD. 
The  membership  of  WG  Chemicals  consists  of  Commission  DGs,  MS  and  stakeholder 
organisations  including  a  range  of  European  industry  associations,  NGOs  and 
intergovernmental organisations. The steps of the review process are described below. 

2.1. 

Preparatory phase  

During  this  phase  data  were  collected  (including  monitoring  and  hazard  data)  and  a 
prioritisation process for identifying candidate PS was carried out. Figure A6.1 illustrates 
the prioritisation process. 

Whether  a  compound  is  “discharged  in  significant  quantities”  is  commonly  decided 
based  on  the  substance’s  exposure  level,  referred  to  as  Predicted  Environmental 
Concentration  (PEC).  This  in  turn  is  compared  to  an  ecological  safety  threshold 
expressed  as  PNEC.  PEC/PNEC  risk  ratios  above  1  would  trigger  the  substance’s 
inclusion in the routine monitoring and the derivation of a legally-binding EQS. 

159 

 
 
 
 
 
Figure A6.1: Substance selection process for surface water 

Subsequently, 
individual  draft  substance  dossiers  for  prioritised  surface  water 
contaminants  were  prepared  by  subgroups  of  experts,  with  rapporteurs,  under  WG 
Chemicals,  and  consultants  contracted  by  the  Commission.  The  subgroups  included 
experts from MS, industry actors and NGOs alike. For the prioritised substances, EQSs 
were  derived  for  individual  substances  or  groups  of  substances  based  on  the 
aforementioned  2018  Technical  Guidance  for  deriving  EQS.  The  document  provides 
detailed  information  on  criteria  and  issues  to  be  considered.  Those  relevant  to  setting 
EQSs are mentioned below: 

  Data acquiring, evaluation, selection and quality assessment of data; 
  Risk assessments to be performed, and relations with (pesticide) risk assessments 

under other pieces of legislation; 

  Calculations, extrapolation and expression of QSs; 
  Deriving quality standards for water abstracted for drinking water; 
  Standards to protect water quality; 
  Derivation of standards protecting aquatic species and wildlife from  (secondary) 

poisoning; 

  Protection  of  humans  against  adverse  health  effects 

from  consuming 

contaminated fisheries;  

  Limitations in experimental data – use of non-testing approaches; 
  Calculation of QS for substances occurring in mixtures; 
 

Implementation of EQSs. 

160 

 
 
 
 
 
 
 
2.2.  Validation stage 

During this stage the draft dossiers for the candidate PS, in particular their draft EQSs, 
were reviewed/commented and validated by the MS (MS) and other members of the WG 
Chemicals, and were publicly available in CIRCABC. 

2.3. 

Independent review stage 

During  this  stage  independent  scientists  of  the  Scientific  Committee  on  Health, 
Environmental  and  Emerging  Risks  (SCHEER)  reviewed  the  EQS  in  the  substance 
dossiers and provided an independent scientific opinion on their appropriateness. 

2.4.  Commenting period on the SCHEER preliminary scientific opinions 

During  this  phase,  the  preliminary  SCHEER  opinions  on  the  EQS  derived  for  each 
candidate PS were published for commenting during 4 weeks, allowing all stakeholders 
to make additional/final comments, and in particular the submitter. These comments were 
collected,  discussed  and  addressed  when  relevant  by  the  SCHEER  to  inform  its  final 
scientific  opinions.  The  final  opinions  are  published  on  its  website100.  For  some 
substance dossiers, the SCHEER is still in the process of formulating preliminary or final 
opinions, and commenting periods on a few others are still ongoing. This means that the 
review is still in process and that some EQSs might need to be modified to take the final 
SCHEER opinions into account. 

2.5.  Outcome of the Prioritisation exercise 

The  prioritisation  exercise  resulted  in  24  possible  new  PS  for  surface  water,  including 
PFAS as a group. The candidate substances included in this revision process are shown 
below. 

Figure A6.2: Candidate substances for setting new EQSs for surface water. 

2.6. 

Input from Surface Water Watch List monitoring 

100 https://ec.europa.eu/health/scientific-committees/scientific-committee-health-environmental-and-emerging-risks-scheer/scheer-
opinions_en  

161 

 
 
 
 
 
                                                           
The obligation introduced into the EQSD in 2013 to establish a surface water watch list 
has  so  far  resulted  in  the  adoption  of  the  following  three  Commission  implementing 
decisions establishing a watch list of substances for Union-wide monitoring in the field 
of water policy (in chronological order): 2015/495/EU, 2018/840/EU and 2020/1161/EU. 
Monitoring  results  from  the  3rd  WL  are  not  yet  available,  but  the  data  collected  for 
substances  listed  in  the  first  two  Commission  implementing  decisions  have  resulted  in 
the  following  substances  now  being  proposed  for  inclusion  in  the  PS  list:  17-Alpha-
ethinylestradiol  (EE2);  17-Beta-estradiol  (E2);  Estrone  (E1);  Diclofenac;  Macrolide 
antibiotics; and Neonicotinoids (Imidacloprid, Thiacloprid, Thiamethoxam, Clothianidin, 
and Acetamiprid). 

3.  Designation of priority hazardous substances 

The  review  considered  whether  the  candidate  substances  are  SVHCs  and/or  POPs,  and 
thus whether they should be designated as PHS. For PHS, the aim is to completely phase 
out emissions to the aquatic environment. Also, if a substance/ RBSP is classified a PHS 
the risk is expected to be an EU-wide risk, whereas for PS the risk can be a non EU-wide 
risk. 

4.  Amendment of EQS for existing PS, and review of status 

The updated (2018) version of the Technical Guidance Document for Deriving EQS was 
applied to check and revise the EQS for all existing PS, also taking into account any new 
scientific findings. Based on this process, 15 substances were identified as candidates for 
EQS amendment, as summarised below. 

Consideration  was  also  given  to  changing  the  status  of  some  existing  PS,  with 
Octylphenols being a possible candidate for designation as a PHS. 

162 

 
 
 
 
 
Figure A6.3: PS for possible revision of existing EQS for surface water. 

5.  Deselection of existing PS 

The JRC drafted a document on criteria for the deselection of existing PS, and proposed a 
list  of  candidates  for  deselection.  The  final  version  took  into  account  comments  from 
members  of  the  WG  Chemicals  and  comments  submitted  by  stakeholders  through  the 
Impact Assessment consultation process. It is published in CIRCABC101. 

5.1.  Criteria for deselection 

As mentioned before, the potential deselection of  existing PS (excluding those recently 
added)  was  done  by  following  the  ‘deselection’  criteria  listed  in  the  document.  The 
agreed criteria for the deselection were extensively discussed with the experts. The JRC 
started drafting the first version of deselection criteria in 2016. Briefly the main criteria 
were:  i)  the  inclusion  of  only  banned  substances,  and  ii)  no  exceedance  in  more  than 
three MS based on monitoring data available at that time, covering the period 2006-2014. 

5.2. 

Substances proposed for deselection 

Application  of  the  criteria  resulted  in  the  proposed  deselection  of  the  following  PS: 
Alachlor, Chlorfenvinphos, Simazine, and Carbon-tetrachloride. 

101 https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/a953a59a-b899-4b8e-9815-
0fee9006239f/details 

163 

 
 
 
 
 
 
 
                                                           
ANNEX  7:  TECHNICAL  PROCESS  FOR  THE  REVISION  OF  THE  LISTS  OF  POLLUTANTS  IN 
GROUNDWATER 

1. 

Introduction 

Article 10 of Directive 2006/118/EC (review clause) requires the Commission to review 
Annexes  I  and  II  of  the  GWD  every  six  years.  The  last  review  led  to  amendment  of 
Annex II via Directive 2014/80/EU. Following this, the Commission introduced the first 
list  facilitating  the  review  of  Annexes  I  and  II  (LFR)  in  2014  and  published  its  results 
(22). This  LFR summarised the main output of the Voluntary Groundwater Watch  List 
process  described  in  the  Groundwater  Watch  List  Concept  &  Methodology.  In  2021, 
under the umbrella of the Working Group Groundwater (WG GW), the sub-group on the 
Voluntary GW Watch List was reactivated102. The membership of both the WG GW and 
GW  WL  sub-groups  consists  of  Commission  DGs,  MS  and  stakeholder  organisations 
including  a  range  of  European  industry  associations,  NGOs  and  intergovernmental 
organisations. 

Furthermore,  Article  3(5)  of  the  GWD  requires  MS  to  publish  information  on  the  TVs 
they  have  established  in  their  RBMPs.  The  2014  GWD  amendment  updated  these 
detailed reporting specifications. CIS Guidance Document No. 35 (110) further specifies 
how the reporting of TVs is to be operationalised (111). 

CIS Guidance Document No. 18 (112) provides recommendations and considerations for 
Member State administrations on how to set and use TVs. It explains the links between 
TVs and the ‘prevent or limit’ objective of GWD Article 6. The document also defines 
some  important  terminology,  the  scale  and  location  of  TV  application,  and  the  general 
methodology  for  establishing  them,  including  the  different  aspects  of  groundwater 
chemical status to consider. Finally, the Guidance Document elaborates how TVs fit into 
the  groundwater  chemical  status  assessment  process  using  the  five  pertinent  tests  for 
chemical groundwater status. 

2.  Technical process underpinning the selection of substances  

The technical work for the review was led by the subgroups of experts and members of 
the  Working  Group  (WG)  Groundwater  under  the  Common  Implementation  Strategy 
(CIS)  for  the  WFD.  The  steps  of  the  substance  prioritisation  process  are  described  in 
Figure A7.1 below. 

102 https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/a53f1d54-0cd9-4de6-b370-
2cbb14004986?p=1&n=10&sort=name_ASC 

164 

 
 
 
 
 
                                                           
Figure A7.1: Substance selection process for groundwater 

The  data  collection  was  primarily  focused  on  substances  causing  risk  and/or  failure  of 
good  chemical  status.  Data  were  collected  on  MS  level  only;  no  differentiation  into 
RBDs or GWBs was made. Depending on  availability, MS provided  GQA-TVs for 2nd 
RBMP (most values) or 3rd RBMP (some values). In total 20 MS submitted data for 100 
pollutants.  Of  these,  21  substances  reported  by  at  least  4  MS  were  selected  for  further 
assessment. Although only GQA-TVs are considered, there is still a wide range in TVs. 
Data provided for TVs, CVs (for drinking water and “other uses”) and NBLs as well as 
complementary  remarks  allowed  in  most  cases  for  explaining  the  wide  range.  It  turned 
out  that  wide  ranges  are  not  only  caused  by  particularly  high  NBLs,  but  also  by 
particularly low NBLs. Apart from NBLs also CVs for DW substantially account for the 
GQA-TVs  reported.  As  provision  of  CVs  was  incomplete,  not  all  TVs  could  be 
explained.  

The  substances  proposed  for  inclusion  in  the  LFR  by  GW  WL  group,  and  their 
corresponding quality standards were validated by the WG GW. By analogy with the SW 
process,  the  resulting  proposals  for  including  them  in  the  Annexes  to  the  GWD  were 
independently  reviewed  by  scientists  of  the  Scientific  Committee  on  Health  and 
Environmental  Emerging  Risks 
identified  were: 
pharmaceuticals, PFAS and degradation products of pesticides (often referred to as non-
relevant Metabolites (nrMs)), as outlined below. 

(SCHEER).  The  substances 

165 

 
 
 
 
 
Figure A7.2: Substances proposed for inclusion in the Annexes to the GWD. 

2.1. 

Input from Groundwater Watch List monitoring 

2.1.1.  PFAS 

PFAS  have  been  detected  in  groundwater  in  many  MS  103.  Data  reviewed  through  the 
GW WL  process  from  11  PC  included  only  around  30  reliably  reported  from  an  initial 
target list of 52 PFAS substances. Within this group, 10 PFAS substances met the criteria 
for inclusion on the LFR (present in more than 10 locations in more than 4 PC). A further 
three  PFAS  remain  on  the  GW  WL  because  insufficient  information  was  identified  to 
justify  their  inclusion  on  the  LFR.  Results  of  the  GW  WL  review  are  set  out  in  Table 
A7.1 and indicate the widespread nature of the PFAS detections. 

Table A7.1: PFAS detected in groundwater in more than 4 PC and at more than 10 sites 

Substance Name 

Acronym  CAS # 

No 
of 
PC 

No. of sites 
monitored 

No.  of  sites 
>LOQ 

% of sites 
>LOQ 

PC  with 
detections 

Status 

103 Voluntary Groundwater Watch List Process Study on Per- and Poly-fluoroalkyl substances (PFAS) – Monitoring Data Collection 
and Initial Analysis – Draft V.2.3 / 23 February 2020 

166 

 
 
 
 
 
                                                           
Substance Name 

Acronym  CAS # 

No 
of 
PC 

No. of sites 
monitored 

No.  of  sites 
>LOQ 

% of sites 
>LOQ 

PC  with 
detections 

Status 

Perfluorooctane 
Sulfonamide 

Perfluoroundecanoic 
Acid 

PFOSA 

754-91-6 

6 

1,715 

PFUnA 

307-55-1 

7 

2,598 

Perfluorododecanoic 
Acid 

PFDoA 

2058-94-
8 

7 

2,830 

22 

39 

62 

Perfluorodecanoic 
Acid 

Perfluorononanoic 
Acid 

Perfluorobutanoic 
Acid 

Perfluorobutane 
Sulfonate 

Perfluoropentanoic 
Acid 

Perfluoroheptanoic 
Acid 

Perfluorohexane 
Sulfonate 

Perfluorohexanoic 
Acid 

Perfluorooctane 
Sulfonate 

Perfluorooctanoic 
Acid 

PFDA 

335-76-2 

8 

2,945 

173 

PFNA 

375-95-1 

8 

3,752 

195 

PFBA 

375-22-4 

5 

1,189 

552 

PFBS 

375-73-5 

7 

2,209 

577 

PFPeA 

2706-90-
3 

7 

2,452 

701 

PFHpA 

375-85-9 

9 

4,224 

817 

PFHxS 

432-50-8 

8 

2,328 

873 

PFHxA 

307-24-4 

9 

4,662 

1,175 

25.2 

PFOS 

1763-23-
1 

11 

6,971 

1,435 

20.6 

PFOA 

335-67-1 

11 

6,429 

1,553 

24.2 

1.3 

1.5 

2.2 

5.9 

5.2 

46.4 

26.1 

28.6 

19.3 

37.5 

4 

6 

6 

7 

7 

5 

5 

7 

8 

7 

8 

11 

11 

GW 
WL 

GW 
WL 

GW 
WL 

LFR 

LFR 

LFR 

LFR 

LFR 

LFR 

LFR 

LFR 

LFR 

LFR 

2.1.2.  Pharmaceuticals 

The  two  pharmaceuticals  on  the  LFR  are  Carbamazepine  and  Sulfamethoxazole.  A 
further 9 substances were put on the GW WL so that more information could be collected 
on their distribution in groundwater. These were: Clopidol, Crotamiton, Amidozoic acid, 
Sulfadiazin, Primidone, Sotalol, Ibuprofen, Erythromycin and Clarithromycin. In 2022 at 
the WG GW meeting and the final stakeholder workshop of this project it was indicated 
that there was sufficient evidence available to support the inclusion of Primidone (a beta 
blocker)104 on the LFR. This was discussed at WG GW Plenary in March 2022 and also 
in  the  2nd  Stakeholder  Workshop  in  March  2022.  In  addition,  the  proposed  Option  3 
includes  adding  8  further  pharmaceuticals  from  the  GW  WL  to  Annex  II  for 
consideration by MS. 

For the GW WL process, 13 PC provided groundwater datasets for review. The review 
found  around  300  pharmaceutical  substances  have  been  monitored  by  PCs  but  only  a 
small number of these were detected in more than 4 countries. Only 2 pharmaceuticals, 
Sulfamethoxazole and Carbamazepine, were present in both 4 or more PC and at 10 or 
more sites in each of these countries and were put forward on the LFR.   

104 Primidone is a beta blocker / barbiturate medication used as an anticonvulsant or to treat partial and generalized seizures as well as 
essential tremors. It is available as a generic medication. In 2017, it was the 238th most commonly prescribed medication in the 
United States, with more than two million prescriptions. 

167 

 
 
 
 
 
                                                           
2.1.3.  Non-Relevant Metabolites (nrMs) of Pesticides105 

Through  the  GW  WL  process,  17  countries  provided  groundwater  data  on  the  nrM 
compounds  for  review.  The  data  indicate  that  nrMs  were  widely  detected  in  European 
groundwater above limits of quantification (LoQ). The nrM monitoring results show 16 
substances  were  detected  in  four  or  more  PC  and  at  10  or  more  sites  in  each  of  these 
countries (see Table A7.2). These substances fulfilled the criteria for addition to the LFR. 
From the assessment, WG GW concluded that there is enough evidence of a Europe-wide 
presence of nrMs in groundwater. Therefore, these 16 nrMs were put forward in a LFR 
and it was recommended that other nrMs are not added to the GW WL. 

Table A7.2: The 16 non-relevant metabolites on the List Facilitating Review of the GWD Annexes 

nRM substance 

CAS 

Parent 
Compound 

Use 

1 

Desphenylchloridazon 
(metabolite B)  

2  Methyl-desphenyl-chloridazon 

(Metabolite B1)  

6339-19-1 

Chloridazon 

Herbicide 

17254-80-7 

Chloridazon 

Herbicide 

3 

2,6-Dichlorbenzamid 
BAM, M01, AE C653711)  

(2,6-D, 

2008-58-4 

Dichlobenil 
Fluopicolide 

Herbicide 
Fungicide 

Status (EU pesticides 
database) 

Not 
(EC1107/2009) 

approved 

Not approved 
(EC1107/2009) 

approved 

Not 
(EC1107/2009) 
Approved 

4 

Aminomethylphosphonic acid 

1066-51-9 

Glyphosate 

Herbicide 

Approved 

5  Metazachlor-acid  (OXA)  (BH 

479-4)  

6  Metazachlor  ESA  Metazachlor-
8) 
SA 
(BH 
(Metazachlorsulfone 
acid, 
Metazachlorsulfonic acid (ESA) 

479- 

1231244-
60-2 

172960-62-
2 

Metazachlor 

Herbicide 

Approved 

Metazachlor 

Herbicide 

Approved 

7 

8 

9 

Atrazine-2-hydroxy  

2163-68-0 

Atrazine 

Herbicide 

N,N-Dimethylsulfamid (DMS)  

3984-14-3 

s-Metolachlor-acid, 
CGA 51202, CGA 351916)  

(OXA, 

152019-73-
3 

Tolylfluanid, 
Dichlofluanid 

Fungicide 

S-metolachlor 

Herbicide 

Not  approved  since 
2004 

Not  approved 
1107/2009) 

Not  Approved 
1107/2009) 

(EC 

(EC 

10  Chlorthalonil-SA  (R417888  or 
M12) 

VIS-01 
(Chlortalonilsulfone acid)  

/ 

11  Metolachlor-Ethanesulfonic 

acid (ESA, CGA 380168, CGA 
354743) 

Dimethenamid-ESA  

Flufenacet-sulfonic  acid  (ESA) 
201668-32-8 

Alachlor-t-sulfonic-acid (ESA)  

12 

13 

14 

15 

1418095-
02-9 

171118-09-
5 

205939-58-
8 

142363-53-
9 

Chlorothalonil 

Fungicide 

Not registered 

S-metolachlor 

Herbicide 

Not  Approved 
1107/2009) 

(EC 

Dimethenamid 

Herbicide 

Not approved 

Flufenacet 

Herbicide 

Approved 

Alachlor 

Herbicide 

Not approved 

S-Metolachlor  NOA  413173  or 
(Chlortalonilsulfone 
VIS-01 
acid) Metabolite  

1418095-
19-8 

Chlorothalonil 

S-metolachlor 

Herbicide 

Not registered 

Not  Approved 
1107/2009) 

(EC 

105 Desphenyl-chloridazon (Metabolite B); Methyl-desphenyl-chloridazon (Metabolite B1); 2,6-Dichlorbenzamid (2,6-D, BAM, M01, 
AE C653711); Aminomethylphosphonic acid (AMPA); Metazachlor-acid (OXA) (BH 479-4); Metazachlor ESA Metazachlor-SA 
(BH 479- 8) (Metazachlor-sulfonic acid (ESA); Atrazine-2-hydroxy; N,N-Dimethylsulfamid (DMS); s-Metolachlor-acid, (OXA, 
CGA 51202, CGA 351916); Chlorthalonil-SA (R417888 or VIS-01 / M12) (Chlorthalonil sulfonic acid); Metolachlor-sulfonic acid 
(ESA, CGA 380168, CGA 354743); Dimethenamid-ESA; Flufenacet-sulfonic acid (ESA) 201668-32-8; Alachlor-t-sulfonic-acid 
(ESA); S-Metolachlor NOA 413173 or VIS-01 (Chlortalonilsulfone acid) Metabolite; Dimethachlor CGA 369873 1418095-08-5. 

168 

 
 
 
 
 
 
 
 
                                                           
nRM substance 

CAS 

Parent 
Compound 

Use 

Status (EU pesticides 
database) 

16  Dimethachlor  CGA  369873 

1418095-08-5 

Dimethachlor 

Herbicide 

Approved 

3.  Derivation of groundwater quality standards 

3.1.  Annex I or Annex II? 

Under  the  GWD  substances  can  be  added  to  Annex  I  or  Annex  II.  Inclusion  of  a 
substance  in  Annex  I  needs  to  be  accompanied  by  an  EU-wide  groundwater  quality 
standard (GW QS). Substances added to Annex II must be considered by MS during the 
risk  assessment  phase  of  river  basin  management  planning,  and  appropriate  threshold 
values  (TVs)  must  be  set  at  national  level,  also  considering  the  background 
concentrations of naturally occurring substances. The choice of Annex is likely to reflect 
the  extent  of  the  problem  and  could  influence  the  effort  needed  to  meet  the 
environmental objectives for groundwater. 

3.2.  Links with the Drinking Water Directive 

Although  the  PFAS  listed  for  surface  water  and  in  the  recast  of  the  Drinking  Water 
Directive  were  selected  using  criteria  related  to  human  health  and  ecotoxicity,  new 
scientific  evidence  became  available  towards  the  end  of  the  adoption  process.  One 
example of this is the 2020 scientific opinion from the European Food Safety Authority 
(EFSA),  outlining  risks  to  human  health  arising  from  PFAS  in  human  food  are  higher 
than previously assumed. This information arrived too late in the process to be reflected 
in  the  revised  DW  standards.  In  light  of  the  ever-increasing  evidence  of  the  harmful 
effects  of  PFAS  to  human  health,  this  new  information  is  included  in  the  scientific 
process to derive the EQS. 

3.3.  Links with the derivation of EQS for PS 

Regarding PFAS, the situation of standard setting based on groundwater monitoring data 
is slightly diverging from the situation for surface waters. This is primarily caused by the 
fact  that  different  PFAS  substances  are  identified  in  surface  waters  compared  to  those 
found in groundwater due to the long lag times associated with adsorption processes in 
soil layers. Once the adsorption capacity is exhausted however, the same substances will 
start to appear in GW as well, which is potentially highly problematic since groundwater 
is the primary source for producing drinking water in the EU. 

Group  of  10  PFAS106  was  originally  proposed  for  groundwater,  differing  from  the  24 
PFAS substances proposed for surface water. 

3.4.  Opinions of the SCHEER107 

The  SCHEER  was  asked  to  evaluate  groundwater  quality  standards  for  proposed 
additional pollutants, including pollutant groups, in the annexes to the GWD. To do so, 

106 Perfluorobutanoic Acid, Perfluorobutane Sulfonate, Perfluorodecanoic Acid, Perfluoroheptanoic Acid, Perfluorohexanoic Acid, 
Perfluorohexane Sulfonate, Perfluorononanoic Acid, Perfluorooctanoic Acid, Perfluorooctane Sulfonate, Perfluoropentanoic Acid.  
107 https://ec.europa.eu/health/publications/groundwater-quality-standards-proposed-additional-pollutants-annexes-groundwater-
directive-2006118ec_en  

169 

 
 
 
 
 
 
 
                                                           
the  SCHEER  discussed  the  specificity  of  groundwater  ecosystems,  the  relationship 
between  quality  standards  for  surface  waters  (freshwaters)  and  groundwater,  the  risk 
assessment of mixtures, and the harmonisation of quality standards in MS. 

General conclusions:  

  uniform  EU-wide  quality  standards  should  be  set  for  the  groundwater  body  for 

 

chemicals with no natural background concentrations, 
it is appropriate to apply freshwater EQSs to groundwater given that these would 
have  included  an  AF  to  account  for  the  considerable  surface  freshwater 
biodiversity,  

  groundwater quality standards should not exceed the concentrations put  forward 

as quality standards for surface waters (AA-EQS),  

  quality standards set for groundwater should be less strict than those for drinking 

 

water,  
for  harmonising  principles,  drinking  water  QS  may  be  used  as  GW  standards, 
unless lower specific EQS exist, such as, for pharmaceuticals.  

For PFAS: 

  similar quality standards should be used for freshwater and groundwater,  
 

the relative potency factor (RPF) approach could be used for QSs of PFAS, and 
that  the  value  of  4.4  ng/L  for  PFOA  equivalents  can  be  adopted  as  a  quality 
standard for GW. The SCHEER did not agree with an EU group quality standard 
of “PFAS-30 total” of 0.50 μg/L.  

For Pharmaceuticals: 

 

 

the  value  of  0.5  μg/L  proposed  as  a  groundwater  quality  standard  for 
carbamazepine may not be sufficiently protective.  
the  proposal  for  a  sulfamethoxazole  groundwater  quality  standard  of  0.1  μg/L 
may not be sufficiently protective for human health, ecosystems and for antibiotic 
resistance,  

  a general  standard of 0.5 μg/L  for all pharmaceuticals  would not  be sufficiently 

 

protective, 
there  is  no  scientific  reason  to  consider  moving  pharmaceuticals  as  a  group  to 
Annex II.  

For non-relevant metabolites of plant protection products: 

  a uniform approach should be followed in the evaluation of nrMs, 
  not all sixteen metabolites were correctly identified as “non-relevant”,  
 

the proposal to use a uniform quality standard(s) for individual nrMs and for total 
nrMs  does  provide  adequate  protection  for  human  health  and  dependent 
ecosystems,  

  a group total quality standard for nrMs of 10 μg/L is not supported,  
  a value of 0.75 μg/L for all non-relevant metabolites should protect human health 
if  no  additional  relevant  toxicological  information  is  made  available,  e.g.,  ED 
effects.  However,  the  SCHEER  recommends  to  use  a  value  of  0.1  μg/L  as  an 
interim  quality  standard  for  nrMs  in  the  groundwater  body,  protecting  exposed 
groundwater biota,  
the  approach  should  not  be  limited  to  the  16  nrMs  currently  identified  but  also 
applied to other nrMs identified in the future. 

 

170 

 
 
 
 
 
3.5.  Groundwater option selection 

Following the comments of the Regulatory Scrutiny Board stating that the groundwater 
option design was complex and too technical, an attempt to re-arrange and simplify the 
available policy choices  and their presentation  in  the main report was made.  Instead of 
aggregating options per each substance group (i.e. PFAS, pharmaceuticals and nrMs), the 
design  was  changed  to  better  reflect  the  legislative  choices  (i.e.  Annex  I  or  Annex  II?; 
listing individually or as groups?). This presentation also aligns with surface water option 
design and increases the coherence within the IA report. 

Table A7.3 shows all the options for the LFR substances, presented in the arrangement of 
Annex  I/Annex  II  policy  choices  as  in  the  main  report,  but  including  the  original 
numbering  as  in  the  support  study.  The  opinions  of  the  SCHEER  are  also  indicated  as 
they were the main driver for selection of one option over another concerning the same 
substance within the same policy option. The differences among these choices relate to 
the scope of addition (i.e. substances included as group of some listed compounds or all) 
and the proposed quality standard. The rationale of selection among the original options 
for PFAS and nrMs concerning their Annex I listing individually is explained below. 

Table A7.3: Transposition of groundwater options from the IA support study to the SWD main text 

Policy 
option 

Description 

Option No. in 
support study 
&  SCHEER 
opinion 

Included  in 
main text of 
IA SWD? 

Option 1 

Add LFR substances to GWD Annex I individually or as group of specific chemicals 

PFAS 

PFAS (Group of 10) included in Annex I  and  assigned a  GW QS of 
0.10 µg/l as “sum of” the 10 PFAS. 

1a 

PFAS  (Group  of  24  as  for  SW)  included  in  Annex  I  and  assigned  a 
GW QS of 4.4 ng/l sum of PFOA-equivalents. 

1d  (SCHEER 
recommended) 

Pharma-
ceuticals 

Carbamazepine and Sulfamethoxazole added to Annex I and assigned 
GW QS of 0.5 and 0.1 µg/l respectively (protective of human health). 

2a  (SCHEER 
endorsed) 

nrMs (Group of 16) added to Annex I as individual substances with a 
GW QS of 1 µg/l. 

3a 

nrMs (Group of 16) added to Annex I as individual substances with a 
GW  QS  of  0.1  µg/l  (protective  of  human  health  and  groundwater 
biota). 

nrMs 

All nrMs added to Annex I as individual substances with a GW QS of 
0.1 µg/l (protective of human health and groundwater biota). 

3d  (SCHEER 
recommended) 

3e  (SCHEER 
recommended 
+ 
future 
proofing) 

Option 2 

Add LFR substances to GWD Annex I as groups of all substances 

PFAS 

Pharma-
ceuticals 

nrMs 

All PFAS added as group to Annex I with a GW QS for “PFAS total” 
of  0.5  µg/l  (again  following  the  drinking  water  standard  for  PFAS 
total). 

Pharmaceuticals added as a group to Annex I and assigned a GW QS 
of 0.5 µg/l. 

All nrMs added to Annex I as a group and assigned a group GW QS 
of 10 µg/l (analogous with the existing group value for “pesticides”). 

Option 3 

Add LFR substances to GWD Annex II 

PFAS 

Pharma-
ceuticals 

All PFAS added as a group to Annex II for MS to consider setting a 
TV  for  specific  substances  posing  a  risk  to  groundwater  bodies 
(GWBs). 

All pharmaceuticals added as a group to Annex II for MS to consider 
setting  a  TV  for  substances  that  pose  a  risk  to  their  GWBs.  The 
specific pharmaceuticals on the LFR are included in the minimum list 
for consideration, with a guideline to include Primidone. 

1b 

2b 

3b 

1c 

2c 

nrMs 

All nrMs added to Annex II for MS to consider a TV for substances  3c 

171 

No 

Yes 

Yes 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

 
 
 
 
Policy 
option 

Description 

that pose a risk to their GWBs. 

For PFAS: 

Option No. in 
support study 
&  SCHEER 
opinion 

Included  in 
main text of 
IA SWD? 

Option  1a  is  based  on  the  findings  from  the  GW  WL  which  indicates  10  PFAS  for 
addition to the LFR (see Table A7.1). The proposed QS is based on the drinking water 
standard  for  20  identified  PFAS108  –  the  10  PFAS  would  be  a  subset  of  the  20.  This 
option was not endorsed by the SCHEER. 

Option  1d was proposed by the SCHEER  in  their Preliminary  Opinion  on groundwater 
quality  standards  REF.  This  option  entails  an  individual  standard  of  4.4  ng/l  PFOA-
equivalent for the 24 listed PFAS in line with surface water EQS. The concentration of 
each listed PFAS would be calculated using the relative potency factor (RPF) compared 
to  PFOA.  For  PFAS  not  included  on  the  PS  list,  the  PFOA  RPF  would  be  used  to 
calculate the GW QS. If no RPF exists, then the RPF of PFOA should be assumed and a 
GW QS  of 4.4 ng/l applied. For some reservations regarding this approach, see section 
3.6 below. 

For nrMs: 

Option  3a  is  based  on  reported  TVs  used  by  MS  which  range  from  0.1  µg/l  to  1  µg/l 
(with  an  exceptional  case  of  4.5  µg/l  for  one  particular  nrM)  and  a  uniform  value  of  1 
µg/l is proposed by analogy with the existing uniform value for individual “pesticides” in 
Annex  I  of  the  GWD.  Commission  guidance  (2003  and  2021)  suggests  a  case-by-case 
assessment but with an (individual) upper limit of 10 µg/l and a value of 0.75 µg/l if a 
risk assessment has been performed but is incomplete. This option was not endorsed by 
the SCHEER. 

The  SCHEER  recommendations  for  nrMs  were  translated  into  Options  3d  and  3e.  The 
difference between these two options is the number of nrMs covered: the 16 individual 
compounds as identified by the GW WL (see Table A7.2) or all nrMs. The wider scope 
of Option 3e contributes to future-proofing the legislation as it sets a limit for any nrM 
compound  found  in  groundwater  even  if  not  explicitly  mentioned  in  the  legislation. 
Therefore,  out  of  the  two  SCHEER  proposals,  Option  3e  was  selected  to  represent  the 
Annex I individual listing policy choice in the main text of this document.  

3.6.  Considerations  around  the  possible  use  of  Relative  Potency  Factors  for 

PFAS 

A  number  of  governmental  bodies  in  the  EU  (EFSA)  and  the  United  States  have 
proposed health-based standards or  guidelines for PFAS  in  water and/or  food based on 

108 This refers to the following compounds: Perfluorooctanoic acid (PFOA) (CAS 335-67-1), Perfluorooctane sulfonic acid (PFOS) 
(CAS 1763-23-1), Perfluorohexane sulfonic acid (PFHxS) (CAS 355-46-4), Perfluorononanoic acid (PFNA) (CAS 375-95-1), 
Perfluorobutane sulfonic acid (PFBS) (CAS 375-73-5), Perfluorohexanoic acid (PFHxA) (CAS 307-24-4), Perfluorobutanoic acid 
(PFBA) (CAS 375-22-4), Perfluoropentanoic acid (PFPeA) (CAS 2706-90-3), Perfluoropentane sulfonic acid (PFPeS) (CAS 2706-91-
4), Perfluorodecanoic acid (PFDA) (CAS 335-76-2), Perfluorododecanoic acid (PFDoDA or PFDoA) (CAS 307-55-1), 
Perfluoroundecanoic acid (PFUnDA or PFUnA) (CAS 2058-94-8), Perfluoroheptanoic acid (PFHpA) (CAS 375-85-9), 
Perfluorotridecanoic acid (PFTrDA) (CAS 72629-94-8), Perfluoroheptane sulfonic acid (PFHpS) (CAS 375-92-8), Perfluorodecane 
sulfonic acid (PFDS) (CAS 335-77-3), Perfluorononane sulfonic acid (PFNS) (CAS 68259-12-1), Perfluoroundecane sulfonic acid 
(PFUnDS) (CAS 749786-16-1), Perfluorododecane sulfonic acid / 10:2 Fluorotelomer sulfonic acid (PFDoS or PFDoDS) (CAS 
120226-60-0) and Perfluorotridecane sulfonic acid (PFTrDS or PFTriS) (CAS 791563-89-8). 

172 

 
 
 
 
 
                                                           
one or more relatively better-studied PFAS such as PFOA or PFOS (EFSA bases its limit 
on epidemiologic results for the sum of four PFAS) (113) (114). To this is compared the 
sum  of  concentrations  of  a  small  number  of  PFAS  including  some  that  are  less  well 
studied  but  are  thought  likely  to  have  similar  pharmacokinetics  and  toxicity.  This 
summing approach is concentration additive. A refinement of this approach using relative 
potency factors (RPFs) has also been proposed  (115), but this additional step is not  yet 
warranted for legislative purposes. 

Concentration  addition  (CA)  is  based  on  the  idea  that  compounds  “work  together”  to 
bring about a biological effect. The simplest form of CA is RPFs in which all compounds 
in the system are assumed to have the same concentration-response curve differing only 
in potency. The concentrations of compounds are multiplied by their potency relative to a 
reference  compound  –  generally  the  one  best  studied  –  and  summed.  The  sum  is  then 
inserted into the concentration-response function of the reference compound. 

The  best  known  RPF  system  is  for  dioxin-like  compounds  where  the  RPFs  are  called 
TEFs  and  2,3,7,8-TCDD  is  the  reference  compound  (117).  The  TEF  system  has  been 
widely  tested.  Its  validity  depends  in  part  on  the  fact  that  dioxin-like  compounds  are 
believed  to  act  via  the  AhR,  a  cellular  receptor.  Here  the  AhR  acts  as  the  molecular 
initiating event (MIE). Assuming that downstream biological effects are a function of the 
signal arising from the MIE, the RPF model (indeed other mixtures effects) should still 
apply  at  downstream  biological  effects  even  if  the  concentration-response  curve  has 
changed (116). 

There are two main problems with applying a RPF system to PFAS: 

1)  There may be  more than one MIE. PFAS  can bind  to  a number of receptors, e.g. 
(118). Although it is possible that key sensitive biological outcomes might depend 
on  a  single  MIE,  the  biology  is  not  well  enough  understood  to  know  this  yet  or 
which  one.  When  there  is  more  than  one  MIE  it  is  more  difficult  to  predict  the 
downstream  mixture  effects.  Converging  AOPs  may  or  may  not  lead  to  CA 
downstream, although CA might be the more protective default position. 

2)  PPARα  is  one  of  the  better  studied  MIEs  for  PFAS  and  may  be  involved  with 
effects  in  the  liver  and  elsewhere.  A  recent  paper  (118)  studied  concentration-
response  curves  for  a  number  of  PFAS  using  a  reporter-cell  line  and  compared 
mixture results with several different models. They found that PFAS can differ in 
both  potency  and  efficacy  (i.e.,  maximal  effect),  violating  an  assumption  of  the 
RPF model. Consequently, the RPF model did worse at predicting mixture effects 
than other more general models that do not make this assumption.  

While research into RPF models for PFAS is worthwhile, it is premature to use them as a 
basis for regulation as it would place more confidence in the values of the RPFs than is 
warranted at this time. Consequently, one or both of the following options are preferred: 

1)  The current system of summing a small number of PFAS for which there are some 
data appears to be a reasonable first step. While one can think of this procedure as 
assuming  the  same  RPF  (one)  for  all  compounds,  it  makes  the  uncertainty  behind 
this assumption explicit. One problem with this approach is that it can ignore other 
PFAS.  To  limit  the  risks  of  that  an  additional  uncertainty  factor  to  take  this  into 
account is considered. 

2)  Another approach could examine extractable organic fluorine (EOF). Typically there 
is a gap between the total EOF in a sample of water, serum, and other media and that 
which  can  be  explained  by  measured  PFAS,  e.g.  (119).  The  identity  of  the 

173 

 
 
 
 
uncharacterized EOF is  not known and is a current area of research. Although it is 
unlikely that all of the compounds in a sample that contribute to EOF have the same 
kind of toxicity, such an approach might serve as a warning sign. 

174 

 
 
 
 
ANNEX 8: RESULTS OF THE QUALITY STANDARD DERIVATION PROCESS FOR REVISION OF THE ANNEXES TO THE EQSD AND GWD 

ENVIRONMENTAL QUALITY STANDARDS (EQS) FOR PRIORITY SUBSTANCES IN SURFACE WATERS 

ANNEX I to Directive 2008/105/EC 

Note: Where an EQS is listed between [] this value is subject to confirmation in the light of the opinion requested from the Scientific Committee on 
Health, Environmental and Emerging Risks. 

(1) 

N° 

(2) 

(3) 

(4) 

(5) 

Name of substance 

Category of 
substances 

CAS 
number (1) 

EU number 
(2) 

(6) 
AA-EQS (3) 
Inland 
surface 
waters (4) 

(7) 
AA-EQS (3) 
Other surface 
waters 

[µg/l] 

[µg/l] 

(2) 

Anthracene 

(3) 

(4) 

(5) 

Atrazine 

Benzene 

Brominated 
diphenylethers 

Industrial 
substances  

120-12-7 

204-371-1  0,1 

Herbicides 

1912-24-9  217-617-8  0,6 

Industrial 
substances 

Industrial 
substances 

71-43-2 

200-753-7  10 

not 
applicable 

not 
applicable 

0,1 

0,6 

8 

175 

(8) 

(9) 

(10) 

(11) 

(12) 

(13) 

Identified as 
priority 
hazardous 
substance  

Identified as 
Ubiquitous 
Persistent, 
Bioaccumul
ative and 
Toxic 
(uPBT) 
substance 

EQS 
Biota (6) 
[µg/kg wet 
weight]  
or EQS 
Sediment 
[µg /kg dry 
weight] 
where so 
indicated 

X 

Identified 
as 
substance 
that tends 
to 
accumula
te in 
sediment 
and/or 
biota  

X 

MAC-EQS 
(5) 
Inland 
surface 
waters (4Error! 
Bookmark not 
defined.) 

MAC-EQS 
(5) 
Other 
surface 
waters 

[µg/l] 

[µg/l] 

0,1 

2,0 

50 

0,1 

2,0 

50 

0,14 (7) 

0,014 (7) 

[0,00028] 
(7) 

X (8) 

X 

X 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(6) 

Cadmium and its 
compounds 
(depending on water 
hardness classes) (9) 

Metals 

7440-43-9  231-152-8  ≤ 0,08 (Class 

0,2 

1) 
0,08 (Class 
2) 
0,09 (Class 
3) 
0,15 (Class 
4) 
0,25 (Class 
5) 

X 

X 

≤ 0,45 (Class 
1) 
0,45 (Class 
2) 
0,6 (Class 3) 
0,9 (Class 4) 
1,5 (Class 5) 

≤ 0,45 (Class 
1) 
0,45 (Class 
2) 
0,6 (Class 3) 
0,9 (Class 4) 
1,5 (Class 5) 

C10-13 Chloroalkanes (10)  Industrial 
substances 

85535-84-
8 

287-476-5  0,4  

0,4 

1,4 

1,4 

(7) 

(9) 

Chlorpyrifos 
(Chlorpyrifos-ethyl) 

(9a)  Cyclodiene pesticides: 

Aldrin  
Dieldrin  
Endrin  
Isodrin  
(9b)  DDT total (11) 

Organophosp
hate 
pesticides 

Organochlori
ne pesticides 

2921-88-2  220-864-4  0, 00046 

4,6 10-5 

0,0026 

0,00052 

Σ = 0,01 

Σ = 0,005 

not 
applicable 

not 
applicable 

309-00-2 
60-57-1 
72-20-8 
465-73-6 

206-215-8 
200-484-5 
200-775-7 
207-366-2 

Organochlori
ne pesticides 

not 
applicable 

not 
applicable 

0,025 

0,025 

para-para-DDT 

50-29-3 

200-024-3  0,01 

0.01 

(10)  1,2-Dichloroethane 

(11)  Dichloromethane 

(12)  Di(2-ethylhexyl)-
phthalate (DEHP) 

Industrial 
substances 

Industrial 
substances 

Industrial 
substances 

107-06-2 

203-458-1  10  

75-09-2 

200-838-9  20 

117-81-7 

204-211-0  1,3 

10  

20 

1,3 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

(13)  Diuron 

Herbicides 

330-54-1 

206-354-4  0,049 

0,0049 

0,268 

0,054 

176 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(14)  Endosulfan 

(15)  Fluoranthene 

(16)  Hexachlorobenzene 

(17)  Hexachlorobutadiene 

Organochlori
ne pesticides 

Industrial 
substances  

Organochlori
ne pesticides 

Industrial 
substances 
(solvents) 

115-29-7 

204-079-4  0,005 

0,0005 

0,01 

0,004 

206-44-0 

205-912-4  7,62 10-4 

7,62 10-4 

0,012] 

0,012 

6,1 

118-74-1 

204-273-9 

87-68-3 

201-765-5  0,44 

0,044 

0,002 

0,3 

1,3 

2 

3,1 

0,5 

0,6 

0,04 

1,0 

14 

0,07 

130 

8,2 

2,0 

0,05 

19,63 

0,6 

24,5 

[0,255] 

0,02 

1,0 

14 

0,07 

130 

8,2 

0,17 

not 
applicable 

not 
applicable 

(18)  Hexachlorocyclohexane  Insecticides  608-73-1 

210-168-9  0,02 

(19) 

Isoproturon 

Herbicides 

(20)  Lead and its compounds  Metals 

(21)  Mercury and its 

Metals 

251-835-4  0,3 

34123-59-
6 
7439-92-1  231-100-4  1,2 (12) 
7439-97-6  231-106-7 

Industrial 
substances  

91-20-3 

202-049-5  2 

Metals 

7440-02-0  231-111-4  2 (12) 

84852-15-
3 

284-325-5  0,037 

0,00182 

140-66-9 

205-426-2  0,1 

0,01 

compounds 

(22)  Naphthalene 

(23)  Nickel and its 

compounds 
(24)  Nonylphenols (13) 
(4-Nonylphenol) 
(25)  Octylphenols (14)  
((4-(1,1',3,3'-
tetramethylbutyl)-
phenol)) 

(26)  Pentachlorobenzene 

(27)  Pentachlorophenol 

Industrial 
substances 

Industrial 
substances 

Industrial 
substances 

Organochlori
ne pesticides 

608-93-5 

210-172-0  0,007 

0,0007 

not 
applicable 

not 
applicable 

87-86-5 

201-778-6  0,4 

0,4 

1 

1 

177 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
X  

X 

X 

(28)  Polyaromatic 

hydrocarbons (PAHs) 
(15) 

Combustion 
products 

not 
applicable 

not 
applicable 

not 
applicable 

not applicable  not 

applicable 

not 
applicable 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

50-32-8 

200-028-5 

205-99-2 

205-911-9 

0,27 

0,017 

0,027 

0,017 

Benzo(k)fluoranthene 

207-08-9 

205-916-6 

0,017 

0,017 

Benzo(g,h,i)perylene 

191-24-2 

205-883-8 

8,2 10-3 

8,2 10-4 

Indeno(1,2,3-cd)pyrene 

193-39-5 

205-893-2 

Chrysene 

218-01-9 

205-923-4 

not 
applicable 

not 
applicable 

0,07 

0,007 

Benzo(a)anthracene 

56-55-3 

200-280-6 

0,1 

0,01 

Dibenz(a,h)anthracene 

53-70-3 

200-181-8 

0,014 

0,0014 

Sum of 
Benzo(a)p
yrene 
equivalents 
[0.6] (16) 

[0,6] 

see 
footnote 16 

see 
footnote 16 

see 
footnote 16 

see 
footnote 16 

see 
footnote 16 

see 
footnote 16 

see 
footnote 16 

(29a)  Tetrachloroethylene  

(29b)  Trichloroethylene  

(30)  Tributyltin compounds 
(17) (Tributyltin-cation) 

(31)  Trichlorobenzenes 

(32)  Trichloromethane 

Industrial 
substances 

Industrial 
substances 

Biocides 

Industrial 
substances 
(solvents) 

Industrial 
substances 

127-18-4 

204-825-9  10 

79-01-6 

201-167-4  10 

10 

10 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

X 

36643-28-
4 

not 
applicable 

0,0002 

0,0002 

0,0015 

0,0015 

[1,3] (18)  X  

X 

X 

12002-48-
1 

234-413-4  0,4  

0,4 

not 
applicable 

not 
applicable 

67-66-3 

200-663-8  2,5  

2,5  

not 
applicable 

not 
applicable 

178 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(33)  Trifluralin 

Herbicides 

1582-09-8  216-428-8  0,03 

0,03 

115-32-2 

204-082-0 

 [4,45 10-3] 

[0,185 10-3] 

not 
applicable 

not 
applicable 
(19) 

not 
applicable 

not 
applicable 
(19) 

X 

X 

[5.45] 

1763-23-1  217-179-8  See substance 65 (Per- and poly-fluorinated alkyl substances (PFAS) – sum of 24) 

(34)  Dicofol 

(35)  Perfluorooctane sulfonic 

acid and its derivatives 
(PFOS) 

(36)  Quinoxyfen 

Organochlori
ne pesticides 

Industrial 
substances 

Plant 
protection 
products 

124495-
18-7 

not 
applicable 

0,15 

0,015 

2,7 

0,54 

(37)  Dioxins and dioxin-like 
compounds (20) 

Industrial 
byproducts 

not 
applicable 

not 
applicable 

not 
applicable 

not 
applicable 

(38)  Aclonifen 

Herbicides 

(39)  Bifenox 

Herbicides 

(40)  Cybutryne 

Biocides 

(41)  Cypermethrin (22) 

(42)  Dichlorvos 

Pyrethroid 
pesticides 

Organophosp
hate 
pesticides 

74070-46-
5 

42576-02-
3 

28159-98-
0 

52315-07-
8 

277-704-1  0,12 

0,012 

0,12 

0,012 

255-894-7  0,012 

0,0012 

0,04 

0,004 

248-872-3  0,0025 

0,0025 

0,016 

0,016 

257-842-9 

[3 10-5] 

[3 10-6] 

6 10-4 

6 10-5 

62-73-7 

200-547-7  6 10-4 

6 10-5 

7 10-4 

7 10-5 

179 

X 

X 

X 

Sum of 
PCDDs+ 
PCDFs+ 
PCB-DLs 
equivalents 
[3,5 10-5] 
(21) 

X 

X 

X 

X 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(43)  Hexabromocyclododeca
ne (HBCDD) (23) 

Industrial 
substances 

See 
footnote 23 

See 
footnote 
Error! 
Bookmar
k not 
defined.3 

[4.6 10-4] 

[2 10-5] 

0,5 

0,05 

[3.5] 

X 

X 

X 

(44)  Heptachlor and 

heptachlor epoxide 

Organochlori
ne pesticides 

76-44-8 / 
1024-57-3 

200-962-3/ 
213-831-0 

[1,7 10-7] 

[1,7 10-7] 

3 10-4 

3 10-5 

 [0,013] 

X 

X 

X 

(45)  Terbutryn 

Herbicides 

886-50-0 

57-63-6 

212-950-5  0,065 
200-342-2  1,7 10-5 

0,0065 
1,6 10-6 

0,34 

0,034 

not derived  not derived 

(46)  17 alpha-ethinylestradiol 

(EE2) 

(47)  17 beta-estradiol (E2) 

(48)  Acetamiprid 

(49)  Azithromycin 

(50)  Bifenthrin 

(51)  Bisphenol-A (BPA) 

(52)  Carbamazepine 

Pharmaceutic
als 
(Estrogenic 
hormones) 

Pharmaceutic
als 
(Estrogenic 
hormones) 

Neonicotinoi
d pesticides 

Pharmaceutic
als 
(Macrolide 
antibiotics) 

Pyrethroid 
pesticides 

Industrial 
substances 

Pharmaceutic
als 

50-28-2 

200-023-8  0,00018 

9 10-6 

not derived  not derived 

135410-
20-7 / 
160430-
64-8 

83905-01-
5 

82657-04-
3 

603-921-1  0,037 

0,0037 

0,16 

0,016 

617-500-5  0,019 

0,0019 

0,18 

0,018 

617-373-6  9,5 10-5 

9,5 10-6 

0,011 

0,001 

80-05-7 

201-245-8 

[0.46] 

[0.46] 

[129] 

[31] 

X 

298-46-4 

206-062-7  2,5 

0,25 

1,6 103 

160 

X 

X 

180 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(53)  Clarithromycin 

(54)  Clothianidin 

(55)  Deltamethrin 

(56)  Diclofenac 

(57)  Erythromycin 

(58)  Esfenvalerate 

(59)  Estrone (E1) 

(60)  Glyphosate 

(61) 

Ibuprofen 

(62) 

Imidacloprid 

81103-11-
9 

Pharmaceutic
als 
(Macrolide 
antibiotics) 

Neonicotinoi
d pesticides 

210880-
92-5 

Pyrethroid 
pesticides 

Pharmaceutic
als 

52918-63-
5 

15307-86-
5 / 15307-
79-6  

658-034-2  0,13 

0,013 

0,13 

0,013 

433-460-1  0,01 

0,001 

0,34 

0,034 

258-256-6  1,7 10-6 

1,7 10-7 

1,7 10-5 

3,4 10-6 

239-348-5 / 
239-346-4 

0,04 

0,004 

290 

29 

114-07-8 

204-040-1  0,5 

0,05 

1 

0,1 

Pharmaceutic
als 
(Macrolide 
antibiotics) 

Pyrethroid 
pesticides 

66230-04-
4 

613-911-9  1,7 10-5 

1,7 10-6 

0.0085 

0.00085 

Pharmaceutic
als 
(Estrogenic 
hormones) 

Herbicides 

53-16-7 

200-164-5  0,00036 

0,000018 

not derived  not derived 

1071-83-6  213-997-4  0,1109 
90110 

9 

398,6 

39,86 

Pharmaceutic
als 

15687-27-
1 

Neonicotinoi
d pesticides 

138261-
41-3 / 
105827-
78-9 

239-784-6  0,22 

0,022] 

428-040-8  0,0068 

0,00068 

0,057 

0,0057 

109 For freshwater used for the abstraction and preparation of drinking water 

110 For freshwater not used for the abstraction and preparation of drinking water 

181 

X 

X 

X 

X 

X 

X 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
(63)  Nicosulfuron 

Herbicides 

(64)  Permethrin 

(65)  Per- and poly-

fluorinated alkyl 
substances (PFAS) – 
sum of 24 (24) 

Pyrethroid 
pesticides 

Industrial 
substances 

111991-
09-4 

52645-53-
1 

601-148-4  0,0087 

0,00087 

0,23 

0,023 

258-067-9  0,00027 

2.7 10-5 

0,0025 

0,00025 

not 
applicable 

not 
applicable 

Sum of 
PFOA 
equivalents 
0,0044 (25) 

Sum of PFOA 
equivalents 
0,0044 (25) 

not 
applicable 

not 
applicable 

X 

Sum of 
PFOA 
equivalents 
0,077 (25)  

X 

X 

X 

(66)  Silver 

Metals 

7440-22-4  231-131-3  0,01 

0,022 

not derived 

0,006 (10% 
salinity) 
0,17 (30% 
salinity) 

(67)  Thiacloprid 

(68)  Thiamethoxam 

Neonicotinoi
d pesticides 

111988-
49-9 

Neonicotinoi
d pesticides 

153719-
23-4 

601-147-9  0,01 

0,001 

428-650-4  0,04 

0,004 

(69)  Triclosan 

Biocides 

3380-34-5  222-182-2  0,02 

(70)  Total of active 

substances in pesticides, 
including their relevant 
metabolites, degradation 
and reaction products 
(26) 

Plant 
protection 
products and 
biocides 

0.5 (27) 

0,0156 
0.5 (27) 

0,05 

0,77 

0,02 

0,005 

0,077 

0,0156 

(1)  CAS: Chemical Abstracts Service. 
(2)  EU number: European Inventory of Existing Commercial Substances (EINECS) or European List of Notified Chemical Substances (ELINCS). 
(3)  This parameter is the EQS expressed as an annual average value (AA-EQS). Unless otherwise specified, it applies to the total concentration of all substances and isomers. 
(4)  Inland surface waters encompass rivers and lakes and related artificial or heavily modified water bodies. 
(5)  This  parameter  is  the  EQS  expressed  as  a  maximum  allowable  concentration  (MAC  EQS).  Where  the  MAC  EQS  are  marked  as  "not  applicable",  the  AA  EQS  values  are 

considered protective against short-term pollution peaks in continuous discharges since they are significantly lower than the values derived on the basis of acute toxicity. 

(6)  If an EQS biota is given, it, rather than the water EQS, shall be applied, without prejudice to the provision in Article 3(3) of this Directive allowing an alternative biota taxon, or 
another  matrix, to be  monitored instead, as long as the  EQS applied provides an equivalent level of protection. Unless otherwise indicated, the biota EQS relate to  fish.  For 
substances  numbered  15  (Fluoranthene)  and  28  (PAHs),  the  biota  EQS  refers  to  crustaceans  and  molluscs.  For  the  purpose  of  assessing  chemical  status,  monitoring  of 

182 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fluoranthene and PAHs in fish is not appropriate. For substance number 37 (Dioxins and dioxin-like compounds), the biota EQS relates to fish, crustaceans and molluscs, in line 
with Commission Regulation (EU) No 1259/2011* Annex Section 5.3. 

(7)  For the group of priority substances covered by brominated diphenylethers (No 5), the EQS refer to the sum of the concentrations of congener numbers 28, 47, 99, 100, 153 and 

154. 

(8)  Tetra, Penta, Hexa, Hepta, Octa and Decabromodiphenylether (CAS numbers 40088-47-9, 32534-81-9, 36483-60-0, 68928-80-3, 32536-52-0, 1163-19-5, respectively). 
(9)  For Cadmium and its compounds (No 6) the EQS values vary depending on the hardness of the water as specified in five class categories (Class 1: <40 mg CaCO3/l, Class 2: 40 

to <50 mg CaCO3/l, Class 3: 50 to <100 mg CaCO3/l, Class 4: 100 to <200 mg CaCO3/l and Class 5: ≥200 mg CaCO3/l). 

(10)  No indicative parameter is provided for this group of substances. The indicative parameter(s) must be defined through the analytical method. 
(11)  DDT total comprises the sum of the isomers 1,1,1 trichloro 2,2 bis (p chlorophenyl) ethane (CAS 50 29 3, EU 200 024 3); 1,1,1 trichloro 2 (o chlorophenyl) 2 (p chlorophenyl) 
ethane (CAS 789 02 6, EU 212 332 5); 1,1-dichloro 2,2 bis (p chlorophenyl) ethylene (CAS 72 55 9, EU 200 784 6); and 1,1 dichloro 2,2 bis (p chlorophenyl) ethane (CAS 72 
54 8, EU 200 783 0). 

(12)  These EQS refer to bioavailable concentrations of the substances. 
(13)  Nonylphenol (CAS 25154-52-3, EU 246-672-0) including  isomers 4-nonylphenol (CAS 104-40-5, EU 203-199-4) and 4-nonylphenol (branched) (CAS 84852-15-3, EU 284-

325-5). 

(14)  Octylphenol (CAS 1806-26-4, EU 217-302-5) including isomer 4-(1,1',3,3'-tetramethylbutyl)-phenol (CAS 140-66-9, EU 205-426-2). 
(15)  Benzo(a)pyrene (CAS 50-32-8) (RPF 1), benzo(b)fluoranthene (CAS 205-99-2) (RPF 0,1), benzo(k)fluoranthene (CAS 207-08-9) (RPF 0,1), benzo(g,h,i)perylene (CAS 191-24-
2) (RPF 0), indeno(1,2,3-cd)pyrene (CAS 193-39-5) (RPF 0,1), chrysene (CAS 218-01-9) (RPF 0,01), benzo(a)anthracene (CAS 56-55-3) (RPF 0,1), and dibenz(a,h)anthracene 
(CAS 53-70-3) (RPF 1). The PAHs anthracene[, fluoranthene] and naphthalene are listed separately. 

(16)  For the group of polyaromatic hydrocarbons (PAHs) (No 28), the biota EQS refers to the sum of the concentrations of seven of the eight PAHs listed in footnote 17 expressed 
as.benzo(a)pyrene equivalents based on the carcinogenic potencies of the substances relative to that of benzo(a)pyrene, i.e.  the RPFs in footnote 15. Benzo(g,h,i)perylene does 
not need to be measured in biota for the purposes of determining compliance with the overall EQS biota. 

(17)  Tributyltin compounds including tributyltin-cation (CAS 36643-28-4). 
(18)  Sediment EQS 
(19)  There is insufficient information available to set a MAC-EQS for these substances. 
(20)  This refers to the following compounds: 

7 polychlorinated dibenzo-p-dioxins (PCDDs): 2,3,7,8-T4CDD (CAS 1746-01-6, EU 217-122-7), 1,2,3,7,8-P5CDD (CAS 40321-76-4), 1,2,3,4,7,8-H6CDD (CAS 39227-28-6), 
1,2,3,6,7,8-H6CDD (CAS 57653-85-7), 1,2,3,7,8,9-H6CDD (CAS 19408-74-3), 1,2,3,4,6,7,8-H7CDD (CAS 35822-46-9), 1,2,3,4,6,7,8,9-O8CDD (CAS 3268-87-9) 
10 polychlorinated dibenzofurans (PCDFs): 2,3,7,8-T4CDF (CAS 51207-31-9), 1,2,3,7,8-P5CDF (CAS 57117-41-6), 2,3,4,7,8-P5CDF (CAS 57117-31-4), 1,2,3,4,7,8-H6CDF 
(CAS 70648-26-9), 1,2,3,6,7,8-H6CDF (CAS 57117-44-9), 1,2,3,7,8,9-H6CDF (CAS 72918-21-9), 2,3,4,6,7,8-H6CDF (CAS 60851-34-5), 1,2,3,4,6,7,8-H7CDF (CAS 67562-
39-4), 1,2,3,4,7,8,9-H7CDF (CAS 55673-89-7), 1,2,3,4,6,7,8,9-O8CDF (CAS 39001-02-0)  
12  dioxin-like  polychlorinated  biphenyls  (PCB-DLs):  3,3’,4,4’-T4CB  (PCB  77,  CAS  32598-13-3),  3,3’,4’,5-T4CB  (PCB  81,  CAS  70362-50-4),  2,3,3',4,4'-P5CB  (PCB  105, 
CAS  32598-14-4),  2,3,4,4',5-P5CB  (PCB  114,  CAS  74472-37-0),  2,3',4,4',5-P5CB  (PCB  118,  CAS  31508-00-6),  2,3',4,4',5'-P5CB  (PCB  123,  CAS  65510-44-3),  3,3’,4,4’,5-
P5CB  (PCB  126,  CAS  57465-28-8),  2,3,3',4,4',5-H6CB  (PCB  156,  CAS  38380-08-4),  2,3,3',4,4',5'-H6CB  (PCB  157, CAS  69782-90-7),  2,3',4,4',5,5'-H6CB  (PCB  167,  CAS 
52663-72-6), 3,3’,4,4’,5,5’-H6CB (PCB 169, CAS 32774-16-6), 2,3,3',4,4',5,5'-H7CB (PCB 189, CAS 39635-31-9). 

(21)  For the group of Dioxins and dioxin-like compounds (No 37), the biota EQS refers to the sum of the concentrations of the substances listed in footnote 20 expressed as toxic 

equivalents based on the World Health Organisation 2005 Toxic Equivalence Factors. 

(22)  CAS  52315-07-8  refers  to  an  isomer  mixture  of  cypermethrin,  alpha-cypermethrin  (CAS  67375-30-8,  EU  257-842-9),  beta-cypermethrin  (CAS  65731-84-2,  EU  265-898-0), 

theta-cypermethrin (CAS 71691-59-1) and zeta-cypermethrin (CAS 52315-07-8, EU 257-842-9). 

(23)  This  refers  to  1,3,5,7,9,11-Hexabromocyclododecane  (CAS  25637-99-4,  EU  247-148-4),  1,2,5,6,9,10-  Hexabromocyclododecane  (CAS  3194-55-6,  EU  221-695-9),  α-

Hexabromocyclododecane (CAS 134237-50-6), β-Hexabromocyclododecane (CAS 134237-51-7) and γ- Hexabromocyclododecane (CAS 134237-52-8). 

(24)  This refers to the following compounds, listed with their CAS number, EU number and Relative Potency Factor (RPF):: 

183 

 
 
 
 
Perfluorooctanoic  acid  (PFOA)  (CAS  335-67-1,  EU  206-397-9)  (RPF  1),  Perfluorooctane  sulfonic  acid  (PFOS)  (CAS  1763-23-1,  EU  217-179-8)  (RPF  2),  Perfluorohexane 
sulfonic  acid  (PFHxS)  (CAS  355-46-4,  EU  206-587-1)  (RPF  0,6),  Perfluorononanoic  acid  (PFNA)  (CAS  375-95-1,  EU  206-801-3)  (RPF  10),  Perfluorobutane  sulfonic  acid 
(PFBS) (CAS 375-73-5, EU 206-793-1) (RPF 0,001), Perfluorohexanoic acid (PFHxA) (CAS 307-24-4, EU 206-196-6) (RPF 0,01), Perfluorobutanoic acid (PFBA) (CAS 375-
22-4, EU 206-786-3) (RPF 0,05), Perfluoropentanoic acid (PFPeA) (CAS 2706-90-3, EU 220-300-7) (RPF 0,03), Perfluoropentane sulfonic acid (PFPeS) (CAS 2706-91-4, EU 
220-301-2) (RPF 0,3005), Perfluorodecanoic acid (PFDA) (CAS 335-76-2, EU 206-400-3) (RPF 7), Perfluorododecanoic acid (PFDoDA or PFDoA) (CAS 307-55-1, EU 206-
203-2) (RPF 3), Perfluoroundecanoic acid (PFUnDA or PFUnA) (CAS 2058-94-8, EU 218-165-4) (RPF 4), Perfluoroheptanoic acid (PFHpA) (CAS 375-85-9, EU 206-798-9) 
(RPF 0,505), Perfluorotridecanoic acid (PFTrDA) (CAS 72629-94-8, EU 276-745-2) (1,65), Perfluoroheptane sulfonic acid (PFHpS) (CAS 375-92-8, EU 206-800-8) (RPF 1,3), 
Perfluorodecane  sulfonic  acid  (PFDS)  (CAS  335-77-3,  EU  206-401-9)  (RPF  2),  Perfluorotetradecanoic  acid  (PFTeDA)  (CAS  376-06-7,  EU  206-803-4)  (RPF  0,3), 
Perfluorohexadecanoic acid (PFHxDA) (CAS 67905-19-5, EU 267-638-1) (RPF0,02), Perfluorooctadecanoic acid (PFODA) (CAS 16517-11-6, EU 240-582-5) (RPF 0,02), and 
Ammonium perfluoro (2-methyl-3-oxahexanoate) (HFPO-DA or Gen X) (CAS 62037-80-3) (RPF 0,06), Propanoic Acid / Ammonium 2,2,3-trifluoro-3-(1,1,2,2,3,3-hexafluoro-
3-(trifluoromethoxy)propoxy)propanoate (ADONA) (CAS 958445-44-8) (RPF 0,03), 2- (Perfluorohexyl)ethyl alcohol (6:2 FTOH) (CAS 647-42-7, EU 211-477-1) (RPF 0,02), 
2-(Perfluorooctyl)ethanol  (8:2  FTOH)  (CAS  678-39-7,  EU  211-648-0)  (RPF  0,04)  and  Acetic  acid  /  2,2-difluoro-2-((2,2,4,5-tetrafluoro-5-(trifluoromethoxy)-1,3-dioxolan-4-
yl)oxy)- (c604) (CAS 1190931-41-9) (RPF 0,06) 

(25)  For the group of PFAS (No 65), the EQS refer to the sum of the concentrations of the 24 PFAS listed in footnote 24 expressed as PFOA-equivalents based on the potencies of the 

substances relative to that of PFOA, i.e. the RPFs in footnote 24. 

(26)  ‘Pesticides’ means plant protection products and biocidal products as defined in Article 2 of Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 
October 2009 concerning the placing of plant protection products on the market and in Article 3 of Regulation (EU) No 528/2012 of the European Parliament and of the Council 
of 22 May 2012 concerning the making available on the market and use of biocidal products, respectively. 

(27)  ‘Total’ means the sum of all individual pesticides detected and quantified in the monitoring procedure, including their relevant metabolites, degradation and reaction products. 

ANNEX I to Directive 2006/118/EC 

GROUNDWATER QUALITY STANDARDS 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

No  Name of 
substance 

Category of 
substances 

CAS number 
(1) 

EU number 
(2)   

Quality Standard (3)  

[µg/l unless otherwise 
indicated] 

1 

Nitrates 

Nutrients 

2 

Active 
substances in 

Pesticides 

not applicable  50 mg/l 

not applicable  0,1 

not 
applicable 

not 
applicable 

184 

 
 
 
 
 
(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

0,5 (total) (5)  

Industrial 
substances 

See footnote 
6 

See footnote 
6 

0.0044 (7)  

pesticides, 
including their 
relevant 
metabolites, 
degradation and 
reaction 
products (4)  

Per- and poly-
fluorinated 
alkyl substances 
(PFAS) - sum 
of 24 (6)   

Carbamazepine   Pharmaceuticals 

298-46-4 

not applicable  0.25 

Sulfamethoxazo
le  

Pharmaceutical 
active 
substances – 
total (8)  

Non-relevant 
metabolites of 
pesticides 
(nrMs)  

Pharmaceuticals 

723-46-6 

not applicable  0.01 

Pharmaceuticals 

not 
applicable 

not applicable  0.25 

Pesticides 

not 
applicable 

not applicable  0,1 (9)  or 1 (10)  

0,5 (9)  or 5 (10) (total) 
(11)   

3 

4 

5 

6 

7 

(1)  CAS: Chemical Abstracts Service. 
(2)   EU number: European Inventory of Existing Commercial Substances (EINECS) or European List of Notified Chemical Substances (ELINCS). 
(3)  This parameter is the QS expressed as an annual average value. Unless otherwise specified, it applies to the total concentration of all substances and isomers. 
(4)  ‘Pesticides’ means plant protection products and biocidal products as defined in Article 2 of Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 
October 2009 concerning the placing of plant protection products on the market and in Article 3 of Regulation (EU) No 528/2012 of the European Parliament and of the Council 
of 22 May 2012 concerning the making available on the market and use of biocidal products, respectively. 

(5)  ‘Total’ means the sum of all individual pesticides detected and quantified in the monitoring procedure, including their relevant metabolites, degradation and reaction products. 

185 

 
 
(6)  This refers to the following compounds, listed with their CAS number, EU number and Relative Potency Factor (RPF): Perfluorooctanoic acid (PFOA) (CAS 335-67-1, EU 206-
397-9) (RPF 1), Perfluorooctane sulfonic acid (PFOS) (CAS 1763-23-1, EU 217-179-8) (RPF 2), Perfluorohexane sulfonic acid (PFHxS) (CAS 355-46-4, EU 206-587-1) (RPF 
0,6)),  Perfluorononanoic  acid  (PFNA)  (CAS  375-95-1,  EU  206-801-3)  (RPF  10),  Perfluorobutane  sulfonic  acid  (PFBS)  (CAS  375-73-5,  EU  206-793-1)  (RPF  0,001), 
Perfluorohexanoic acid (PFHxA) (CAS 307-24-4, EU 206-196-6) (RPF 0,01), Perfluorobutanoic acid (PFBA) (CAS 375-22-4, EU 206-786-3) (RPF 0,05), Perfluoropentanoic 
acid  (PFPeA)  (CAS  2706-90-3,  EU  220-300-7)  (RPF  0,03),  Perfluoropentane  sulfonic  acid  (PFPeS)  (CAS  2706-91-4,  EU  220-301-2)  (RPF  0,3005),  Perfluorodecanoic  acid 
(PFDA) (CAS 335-76-2, EU 206-400-3) (RPF 7), Perfluorododecanoic acid (PFDoDA or PFDoA) (CAS 307-55-1, EU 206-203-2) (RPF 3), Perfluoroundecanoic acid (PFUnDA 
or  PFUnA)  (CAS  2058-94-8,  EU  218-165-4)  (RPF  4),  Perfluoroheptanoic  acid  (PFHpA)  (CAS  375-85-9,  EU  206-798-9)  (RPF  0,505),  Perfluorotridecanoic  acid  (PFTrDA) 
(CAS 72629-94-8, EU 276-745-2) (1,65), Perfluoroheptane sulfonic acid (PFHpS) (CAS 375-92-8, EU 206-800-8) (RPF 1,3), Perfluorodecane sulfonic acid (PFDS) (CAS 335-
77-3, EU 206-401-9) (RPF 2), Perfluorotetradecanoic acid (PFTeDA) (CAS 376-06-7, EU 206-803-4) (RPF 0,3), Perfluorohexadecanoic acid (PFHxDA) (CAS 67905-19-5, EU 
267-638-1) (RPF 0,02), Perfluorooctadecanoic acid (PFODA) (CAS 16517-11-6, EU 240-582-5) (RPF 0,02), Ammonium perfluoro (2-methyl-3-oxahexanoate) (HFPO-DA or 
Gen  X)  (CAS  62037-80-3)  (RPF  0,06),  Propanoic  Acid  /  Ammonium  2,2,3-trifluoro-3-(1,1,2,2,3,3-hexafluoro-3-(trifluoromethoxy)propoxy)propanoate  (ADONA)  (CAS 
958445-44-8) (RPF 0,03), 2- (Perfluorohexyl)ethyl alcohol (6:2 FTOH) (CAS 647-42-7, EU 211-477-1) (RPF 0,02), 2-(Perfluorooctyl)ethanol (8:2 FTOH) (CAS 678-39-7, EU 
211-648-0) (RPF 0,04) and Acetic acid / 2,2-difluoro-2-((2,2,4,5-tetrafluoro-5-(trifluoromethoxy)-1,3-dioxolan-4-yl)oxy)- (c604) (CAS 1190931-41-9) (RPF 0,06). 

(7)  The QS refers to the sum of the 24 PFAS listed in footnote 6 expressed as PFOA-equivalents based on the potencies of the substances relative to that of PFOA, i.e. the RPFs in 

footnote 6. 

(8)  ‘Total’ means the sum of all individual pharmaceuticals detected and quantified in the monitoring procedure, including relevant metabolites and degradation products. 
(9)  Applicable to ‘data-poor substances’, i.e. ‘substances which are not data rich’ 
(10)  Applicable to ‘data-rich’ substances, i.e. substances where the QS can be derived from a species sensitivity distribution with an assessment factor of one, on the basis of chronic 

and acute toxicity studies covering at least one species of algae, of invertebrates and of fish in fresh and saltwaters. 
(11)  ‘Total’ means the sum of all data-poor or data-rich individual nrMs detected and quantified in the monitoring procedure. 

186 

 
 
Minimum  list  of  pollutants  and  their  indicators  for  which  MS  have  to  consider 
establishing threshold values in accordance with Article 3 (ANNEX II to GWD)  

Substances or ions or indicators which may occur both naturally and/or as a result of 

1. 
human activities  

Arsenic 

Cadmium  

Lead  

Mercury 

Ammonium  

Chloride  

Sulphate 

Nitrites  

Phosphorus (total)/Phosphates 111 

2. 

Synthetic substances 

Primidone 

Trichloroethylene 

Tetrachloroethylene 

3. 

Parameters indicative of saline or other intrusions 112 

Conductivity 

111 MS may decide to establish threshold values either for phosphorus (total) or for phosphates. 
112 With regard to saline concentrations resulting from human activities, MS may decide to establish threshold values either for sulphate and 
chloride or for conductivity. 

187 

 
 
 
 
 
                                                           
ANNEX 9: DETAILED ASSESSMENT OF IMPACTS PER POLICY OPTION 

1.  Surface water options 

1.1.  Option 1: Include each candidate priority substance individually and set 

corresponding individual EQS 

Option 1 provides the impact assessment for the addition of candidate substances to the 
priority substance list individually with individual EQSs, with the caveat that PFAS will 
be  assessed  as  a  group  (due  to  the  very  large  number  of  substances  involved).  The 
assessment has been based on the EQS dossiers and monitoring data to derive a distance 
to  target,  apply  a  dynamic  baseline,  and  assess  what  measures  might  be  needed  to 
achieve  good  chemical  status.  The  distance  to  target  can  be  relatively  large  (67-100% 
expected  exceedance),  medium  (33-66%  expected  exceedance)  or  small  (0%-32% 
expected exceedance). 

Additionally,  as  part  of  the  impact  assessment  consideration  has  been  given  to  the 
economic, environmental, and societal benefits of adding the identified candidates to the 
priority list of substances. Where these  are in balance with the costs, an addition to the 
priority  substance  list  is  still  worthwhile  but  that  there  is  a  closer  balance  between  the 
costs and benefits. 

Based  on  this  analysis  the  majority  of  substances  fall  into  the  first  category  where 
benefits outweigh costs, which helps validate the prioritisation of substances in the first 
instance.  The  neutral  category  is  made  up  of  a  smaller  set  of  substances  (ibuprofen, 
nicosulfuron, clothianidin, bisphenol A, and microplastics). As an example, the costs of 
helping achieve good chemical status for bisphenol A are really very challenging, given 
that  source  control  alone  is  unlikely  to  be  sufficient  and  that  management  of  diffuse 
sources as pathway disruption and end-of-pipe treatment will also be needed. However, 
again,  where  bisphenol  A  has  been  identified  to  have  endocrine  disrupting  effects  for 
both humans (particularly on childhood development), and aquatic species, and where the 
monitoring  data  suggests  the  problem  is  widespread  with  a  high  level  of  exceedances 
geographically  (distance  to  target  is  large),  there  are  very  strong  benefits  to  addressing 
the issues. In this case it could be argued that managing bisphenol A is ‘high cost, high 
benefit’, and therefore it belongs in the neutral category. 

As silver is used in many products. Its antibacterial properties are driving many medical 
applications, including e.g. silver-coated medical devices including urinary and vascular 
catheters and for the treatment of burn wounds by silver containing creams and ointments 
and by the application of silver sheets. Silver nanoparticles (nanosilver (NAg); are widely 
produced  and  used  nanoparticles  thanks  to  their  unique  characteristics  and  diverse 
antimicrobial mechanisms113. Often, silver is one of few remaining available treatments 
to protect the body for heavy bacterial infections. Numerous studies have demonstrated 
the  antimicrobial  efficacy  of  NAg  against  many  viral,  fungal,  parasitic,  and  bacterial 
organisms114 115. As a result, the healthcare sector is probably the largest market for NAg, 

113  Silva,  G.  A.  (2004).  Introduction  to  nanotechnology  and  its  applications  to  medicine.  Surg.  Neurol.  61,  216–220.  doi: 
10.1016/j.surneu.2003.09.036: https://pubmed.ncbi.nlm.nih.gov/14984987/ 

114 Rai, M., Deshmukh, S., Ingle, A., and Gade, A. (2012). Silver nanoparticles: the powerful nanoweapon against multidrug-resistant 
bacteria. J. Appl. Microbiol. 112, 841–852. doi: 10.1111/j.1365-2672.2012.05253.x: https://pubmed.ncbi.nlm.nih.gov/22324439/ 

188 

 
 
                                                           
with  nanoparticles  being  widely  used  as  a  coating  agent  in  medical  devices,  such  as 
intravenous  catheters,  wound  dressings,  and  organ/dental  implants  to  inhibit  bacterial 
colonisation116 117. Worryingly, NAg is also used into many ordinary consumer products, 
like  in  household  appliances,  textiles  /clothing,  cosmetics,  childcare  products,  food 
packaging and containers118. 

The  widespread  use  of  NAg  has  raises  concerns  related  to  the  rise  of  silver-resistant 
bacteria  119. Over several years, a multitude of studies describe the increasing resistance 
in bacteria exposed to different forms of silver, including NAg. Silver resistance has been 
reported in A. baumannii and many other important pathogenic bacteria  120  121  122  123 124 
125.  Evidence  also  shows  that  NAg  also  promotes  the  co-emergence  of  antibiotic 
resistance  in  bacteria126  127  128.  In  combination  with  the  fact  that,  in  Europe,  6.5%  of 
patients in acute care hospitals develop at least one healthcare-associated infection129 thus 
affecting millions of patients every year, is a worrying and challenging concern. 

In this case the distance to target was identified as ‘medium’. While acknowledging that 
the  specific  form  of  silver  plays  a  key  role  in  its  bioavailability  and  impacts,  it  is  also 
undisputed  that  (surface)  water  is  a  pool/  reservoir  of  bacteria  with  various  forms  of 

115  Ge,  L.,  Li,  Q.,  Wang,  M.,  Ouyang,  J.,  Li,  X.,  and  Xing,  M.  M.  (2014).  Nanosilver  particles  in  medical  applications:  synthesis, 
performance, and toxicity. Int. J. Nanomedicine 9, 2399–2407. doi: 10.2147/IJN.S55015: https://pubmed.ncbi.nlm.nih.gov/24876773/ 

116  Khan,  I.,  Saeed,  K., and  Khan,  I.  (2017).  Nanoparticles:  properties,  applications  and  toxicities.  Arab. J.  Chem. 2017, 1–24.  doi: 
10.1016/j.arabjc.2017.05.011: https://www.sciencedirect.com/science/article/pii/S1878535217300990?via%3Dihub 

117 Rai, M., Yadav, A., and Gade, A. (2009). Silver nanoparticles as a new generation of antimicrobials. Biotechnol. Adv. 27, 76–83. 
doi: 10.1016/j.biotechadv.2008.09.002: https://pubmed.ncbi.nlm.nih.gov/18854209/ 

118 State of the art in human risk assessment of silver compounds in consumer products: a conference report on silver and nanosilver 
held at the BfR in 2012: https://pubmed.ncbi.nlm.nih.gov/23779146/ 

119 Gunawan, C., Teoh, W. Y., Marquis, C. P., and Amal, R. (2013). Induced adaptation of  Bacillus sp. to antimicrobial nanosilver. 
Small 9, 3554–3560. doi: 10.1002/smll.201300761: https://pubmed.ncbi.nlm.nih.gov/23625828/ 

120 Gupta, A., Matsui, K., Lo, J.-F., and Silver, S. (1999). Molecular basis for resistance to silver cations in Salmonella. Nat. Med. 5, 
183–188. doi: 10.1038/5545: https://pubmed.ncbi.nlm.nih.gov/9930866/ 

121 Gunawan, C., Teoh, W. Y., Marquis, C. P., and Amal, R. (2013). Induced adaptation of  Bacillus sp. to antimicrobial nanosilver. 
Small 9, 3554–3560. doi: 10.1002/smll.201300761: https://pubmed.ncbi.nlm.nih.gov/28339182/ 

122  Muller,  M.,  and  Merrett,  N.  D.  (2014).  Pyocyanin  production  by  Pseudomonas  aeruginosa  confers  resistance  to  ionic  silver. 
Antimicrob. Agents Chemother. 58, 5492–5499. doi: 10.1128/AAC.03069-14: https://pubmed.ncbi.nlm.nih.gov/25001302/ 

123  Panáček,  A.,  Kvítek,  L.,  Smékalová,  M.,  Večeřová,  R.,  Kolář,  M.,  Röderová,  M.,  et  al.  (2018).  Bacterial  resistance  to  silver 
nanoparticles 
10.1038/s41565-017-0013-y: 
https://pubmed.ncbi.nlm.nih.gov/29203912/ 

it.  Nat.  Nanotechnol. 

overcome 

65–71. 

how 

doi: 

and 

13, 

to 

124 Hosny, A. E.-D. M., Rasmy, S. A., Aboul-Magd, D. S., Kashef, M. T., and El-Bazza, Z. E. (2019). The increasing threat of silver-
resistance  in  clinical  isolates  from  wounds  and  burns.  Infect.  Drug  Resist.  2019,  1985–2001.  doi:  10.2147/IDR.S209881: 
https://pubmed.ncbi.nlm.nih.gov/31372006/ 

125 Valentin, E., Bottomley, A. L., Chilambi, G. S., Harry, E., Amal, R., Sotiriou, G. A., et al. (2020). Heritable nanosilver resistance 
in  priority  pathogen:  a  unique  genetic  adaptation  and  comparison  with  ionic  silver  and  antibiotic.  Nanoscale  12,  2384–2392.  doi: 
10.1039/C9NR08424J: https://pubmed.ncbi.nlm.nih.gov/31930233/ 

126  Ma,  Y.,  Metch,  J.  W.,  Yang,  Y.,  Pruden,  A.,  and  Zhang,  T.  (2016).  Shift  in  antibiotic  resistance  gene  profiles  associated  with 
nanosilver 
10.1093/femsec/fiw022: 
https://pubmed.ncbi.nlm.nih.gov/26850160/ 

during  wastewater 

FEMS  Microbiol. 

92:fiw022. 

treatment. 

Ecol. 

doi: 

127 Chen, Q.-L., Zhu, D., An, X.-L., Ding, J., Zhu, Y.-G., and Cui, L. (2019b). Does nano silver promote the selection of antibiotic 
resistance 
10.1016/j.envint.2019.04.061: 
https://pubmed.ncbi.nlm.nih.gov/31078874/ 

399–406. 

Environ. 

plant? 

genes 

128, 

doi: 

soil 

and 

Int. 

in 

128  Pietsch,  F.,  O’Neill,  A.  J.,  Ivask,  A.,  Jenssen,  H.,  Inkinen,  J.,  Kahru,  A.,  et  al.  (2020).  Selection  of  resistance  by  antimicrobial 
coatings 
10.1016/j.jhin.2020.06.006: 
https://pubmed.ncbi.nlm.nih.gov/32535196/ 

J.  Hosp. 

healthcare 

115–125. 

setting. 

Infect. 

106, 

doi: 

the 

in 

129 Widmer, A.F. et.al. Long-term antimicrobial effectiveness of Ag-impregnated foil on high-touch hospital surfaces... Antimicrobial 
Resistance & Infection Control 2021, Vol. 10: https://aricjournal.biomedcentral.com/articles/10.1186/s13756-021-00956-1 

189 

 
                                                                                                                                                                            
antimicrobial  resistance  (AMR)130.  As  a  result,  bacterial  genes  encoding  for  AMR  can 
easily  maintain  and  spread  through  such  reservoirs  also  to  pathogenic  bacteria.  The 
widespread  over-use  of  silver  also  leads  to  the  selection  of  silver  resistant  bacteria  and 
may  be  genotoxic  to  mammalian  cells.  Other  reports  indicate  adverse  effects  of  silver 
nanoparticles on reproduction of experimental animals, as well as neurotoxic effects on 
cognitive functions131.  

The  cost  for  the  removing  silver  from  effluents  via  UWWTPs  is  considerable  (source 
control  could  include  pre-treatment  or  onsite  wastewater  treatment  by  reverse  osmosis 
(RO) prior to direct discharges or releases to sewer), amounting to an estimated cost of 
0.1%  of  the  industry’s  annual  turnover132.  Alternatively,  urban  wastewater  treatment 
plants  would  need  to  invest  in  reverse  osmosis  to  clean  such  effluents.  Assuming  that 
between 1-5% UWWTPs would have to deploy reverse osmosis, costs for EU taxpayers 
would  be  between  €2,184,600  and  €109,230,000.  The  benefits  of  removing  silver  to 
reduce the risk for AMR and other risks, similar to the benefits of reducing AMR from 
antibiotics,  are  also  large.  In  2014,  it  was  estimated  that  infection  from  antibiotic-
resistant / multi-drug resistant bacteria in the United States resulted in a loss of over $20 
billion  in  direct  economic  costs,  and  $35  billion  through  decline  in  societal 
productivity133134, adding up to a total of $55 billion, which corrected for inflation would 
result in 63 billion in 2021135. In 2021 this would translate to costs of $0,19 billion per 
million  inhabitants136.  Assuming  comparability  in  US  and  EU  rates  of  AMR  and  their 
related  avoided  costs  /  benefits  this  translates  to  €84  billion  of  EU  wide  AMR-related 
avoided  costs  (benefits)137.  When  assuming  that  the  benefits  of  reducing  silver  related 
AMR  would  amount  to  between  50%  to  100%  of  the  AMR  costs  for  antibiotics,  this 
translates to EU-benefits of between €42 to €84 billion.  

Where there are multiple sources and pathways to environment including mine drainage, 
manufacturing,  use  of  products,  run-off,  end-of-pipe  treatment,  it  means  that  a  very 
targeted plan of action will be needed on a Member State by Member State basis. This 
makes judging the actual costs per Member State challenging, but it can be reasoned that 
where the issue will need to tackle both point source and diffuse emissions the package 
of  measures  will  need  to  be  comprehensive,  and  therefore  likely  balance  the  benefits 
identified. 

130 Gunawan, C. et.al. Widespread and Indiscriminate Nanosilver Use: Genuine Potential for Microbial Resistance. ACS Nano, 2017 
Apr 25;11(4):3438-3445. Doi: 10.1021/acsnano.7b01166. Epub 2017 Mar 24.  https://pubmed.ncbi.nlm.nih.gov/28339182/ 

131  Anna  Maria  Świdwińska-Gajewska,  Sławomir  CzerczakNanosilver 
https://pubmed.ncbi.nlm.nih.gov/25902699/ 

-  harmful 

effects  of  biological 

activity: 

132 An extrapolation of the RO costs based on the number of EU non-ferrous metals production facilities 847132 in 2019, assuming that 
around 5% - 10% of effluents need treatment, would potentially result in EU wide costs ranging from €423,500 to €8,470,000. In 
relation to the annual turnover of the EU non-ferrous metals industry (120 billion132) this would equal 0.1%. 
133 Zhen, X., Lundborg, C. S., Sun, X., Hu, X., and Dong, H. (2019). Economic burden of antibiotic resistance in ESKAPE organisms: 
10.1186/s13756-019-0590-7: 
a 
https://pubmed.ncbi.nlm.nih.gov/31417673/ 

Antimicrob. 

systematic 

Control 

review. 

Resist. 

8:137. 

Infect. 

doi: 

134 Golkar, Z., Bagasra, O., and Pace, D. G. (2014). Bacteriophage therapy: a potential solution for the antibiotic resistance crisis. J. 
Infect. Dev. Ctries. 8, 129–136. doi: 10.3855/jidc.3573: https://pubmed.ncbi.nlm.nih.gov/24518621/ 

135 https://www.in2013dollars.com/us/inflation/2014?endYear=2021&amount=55 

136 In 2021 the number of US inhabitant was 332 million: https://www.worldometers.info/world-population/us-population/ 

137  No.  of  EU  inhabitants  in  2021:  447  million  (https://european-union.europa.eu/principles-countries-history/key-facts-and-
figures/life-eu_en) 

190 

 
                                                           
Option  1  has  assessed  the  candidate  substances  as  individual  additions.  Further 
discussion on the possible application of grouping strategies is further covered in Option 
2. 

191 

 
 
Table A9.1: Surface water option 1 – summary of impacts 

Economic Impact 

Cost 

Benefits 

potential 

Some 
for 
source  control  and  end-
of-pipe treatment. Costs 
broadly 
look 
comparable with risk. 

Environmental 
impact 

Chronic 
level 
ecosystem 
from 
impacts 
to 
exposure 
hormones 
and 
EDC  effects  can 
be avoided. 

Dista
nce 
to 
targe
t 
Medi
um 

Medi
um 

Larg
e 

Medi
um 

Smal
l 

Smal
l 

Larg
e 

Substance 

Estrone 
E1 

17-  Beta 
estradiol 
(E2) 

Ethinyl 
estradiol 
(EE2) 

Azithromy
cin 

Clarithro
mycin 

Erythromy
cin 

Diclofena
c 

Chronic 
level 
ecosystem 
from 
impacts 
to 
exposure 
hormones 
and 
EDC  effects  can 
be avoided. 

Some  potential  for 
source  control  and 
end-of-pipe 
treatment.  Costs 
look 
broadly 
comparable  with 
risk. 

likely 

Cost  of  management 
would  be  challenging 
requiring  a  basket  of 
at 
measures 
higher costs. 
Impacts 
pharmaceutical 
industries 
restricted 
and 
for 
alternatives. 

if  use 
is 
/  banned, 
limited  options 
chemical 

on 

than 

Environmental 
impacts  for  aquatic 
likely 
species 
the 
stronger 
other 
two 
estrogenics,  with 
clear  benefits 
for 
avoided 
impacts. 
The  EQSD  dossier 
indicates 
risk  of 
potential 
biodiversity 
impacts 
concentrations 
above the EQS. 

from 

to 

concerns 
Primary 
relate to build up of 
antibiotics  within 
environment 
the 
anti-
leading 
microbial resistance 
(AMR). 
Potential 
toxicological 
effects  at  elevated 
doses,  likely  to  be 
site  specific  /  hot-
spots  dependent  on 
releases. 
Highlighted  as  one 
of 
highest 
the 
concern 
pharmaceuticals  for 
environmental 
impacts.  Potential 
effects  on 
toxic 
avian 
populations 
via  surface  water 

Very limited selection 
of alternatives, loss of 
macrolide  antibiotics 
restriction 
through 
to 
lead 
would 
increased  healthcare 
costs. 
Largely  end  of  pipe 
measures  only.  But 
Ozonation is effective 
and 
already 
costs 
captured by  
Forthcoming 
UWWT Directive.  
Source  control  options 
look  viable  (range  of 
alternatives); 
end-of-
pipe  measures  could 
also  be  considered  to 
risks.  Note 
address 
possible economic costs 
pharmaceutical 
on 
if 
industry 

revised 

192 

Overall 
balance 
costs 
benefits 

of 
and 

The  benefits  of 
addition  to  the 
list 
PS 
the 
outweigh 
costs. 

The  benefits  of 
addition  to  the 
list 
PS 
the 
outweigh 
costs. 

The  benefits  of 
addition  to  the 
list 
PS 
the 
outweigh 
costs. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 
The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 
The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

Social impact 

Societal  benefits 
from 
greater 
health 
protections, 
food 
and 
services. 

security, 
ecosystem 

Societal 
benefits 
from 
greater  health 
protections, 
food  security, 
and  ecosystem 
services. 

to 
and 

Societal 
benefits 
from 
avoided  health 
impacts 
relating 
EDC 
carcinogen 
effects. 
Possible 
societal 
impacts 
from 
loss  of  use 
(contraceptive 
HRT, 
pill, 
hormone 
treatments 
if 
restricted/bann
ed). 
Protection 
against  AMR 
has 
clear 
societal 
benefits. 

avoided 

Potential 
environmental 
impacts  and  human 
health  via  exposure 
through 
environment. 
Ecosystem  benefits, 
included  health  of 
and 
aquaculture 
fishing. 
Potential 
avoided 
environmental impacts 
and  human  health  via 
through 
exposure 
environment. 
Ecosystem 
benefits, 
included  health  of 
and 
aquaculture 
fishing. 
Potential 
avoided 
environmental impacts 
and  human  health  via 
through 
exposure 
environment. 
Ecosystem 
benefits, 
included  health  of 
aquaculture 
and 
fishing. 

costs 

to 
Avoid 
healthcare 
from 
protections  against  the 
development  of  AMR 
within health settings. 

Economic  benefits  for 
aquaculture 
from 
improved food quality. 
ecosystem 
Improved 
from 
services 
the 
protection 
aquatic environment. 

of 

Societal 
impacts 
from 
loss  of  use 
/restricted  use 
if 
controls 
implemented. 
Additional 
costs 
society 

for 
on 

 
Economic Impact 

Cost 

Benefits 

Dista
nce 
to 
targe
t 

Larg
e 

Medi
um 

Smal
l 

Smal
l 

Substance 

Carbamaz
epine 

Ibuprofen 

Nicosulfur
on 

Acetamipr
id 

Environmental 
impact 

species. 

Population  effects 
for  aquatic  species 
through  impacts  on 
fertility 
and 
reproduction 
(particularly 
crustaceans).  

High  volume  use, 
with  potential  toxic 
some 
effects 
for 
species. 
aquatic 
includes 
This 
effects 
fertility 
(hormone  levels)  in 
fish. 

issue. 

has 
Nicosulfuron 
toxicity 
aquatic 
(particularly 
to 
flora)  and  concerns 
over 
carcinogenicity as a 
secondary 
poisoning 
Environmental 
concentrations 
in 
decline over the last 
five years. 
Toxic 
effects 
invertebrates, 
arthropods, 
and 
crustaceans.  Wider 
environmental 
concerns 
terrestrial 
pollinators. 

aquatic 
against 

for 

Clothianid
in 

Smal
l 

aquatic 
against 

Toxic 
effects 
invertebrates, 
arthropods, 
and 
crustaceans.  Wider 

restricted/banned 
expect  production 
switch to alternatives. 

but 
to 

Source  control  options 
look  viable  (range  of 
alternatives 
although 
care  needed  as  patient-
to-patient  viability 
is 
unclear);  while  end-of-
pipe  measures  could 
also  be  considered  to 
address 
risks.  Note 
possible economic costs 
pharmaceutical 
on 
if 
industry 
but 
restricted/banned 
expect  production 
to 
switch to alternatives. 
Potential  impacts  from 
restriction/increased 
use. 
control 
Including 
economic 
costs  for  manufacturers 
as 
retailers 
and 
alternatives  are  more 
expensive.  WWTWs 
options 
more 
challenging  and  likely 
costly. 

of 

Primarily 
intervention 
relates to source control 
and pathway disruption. 
alternatives 
Chemical 
are  available  and  in use 
(primarily  glyphosate). 
Pathway 
disruption 
costs  are  balanced  with 
the risks. 

source 

of 
Wide-range 
alternatives  and  options 
for 
control, 
including  biocidal  use. 
disruption 
Pathway 
look  reasonable 
costs 
based  on  the  scale  of 
End-of-
exceedance. 
pipe  would 
require 
GAC,  which  is  costly. 
for 
Impacts 
manufacturers,  farmers, 
wastewater  companies, 
and general public. 
Use  as  pesticide  has 
ceased.  Use  as  biocide 
ongoing. 
Pathway 
disruption  costs  may  be 
significant.  End-of-pipe 

193 

Overall 
balance 
costs 
benefits 

of 
and 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

and 
Benefits 
costs assessed as 
neutral. 
(Medium  cost  / 
Medium 
benefit) 

Benefits 
and 
costs assessed as 
neutral. 
(Small  cost 
small benefit) 

/ 

Social impact 

willingness  to 
pay 
and 
advanced 
WWTWs. 
Societal 
from 
impacts 
loss  of  use 
/restricted  use 
if 
controls 
implemented. 
Additional 
for 
costs 
society 
on 
willingness  to 
pay 
and 
advanced 
WWTWs. 

cost 

Societal 
from 
loss/restriction 
ibuprofen 
of 
and 
increased 
costs  for  other 
types 
of 
medicine. 
Including 
prescription 
only 
medications. 
Societal 
benefit 
from 
protection  of 
exposure  and 
secondary 
poisoning 
action 
potential 
carcinogen. 

as 

a 

Economic  benefits  for 
from 
aquaculture 
improved food quality. 
ecosystem 
Improved 
from 
services 
protection 
the 
aquatic environment. 

of 

Economic  benefits  for 
aquaculture 
from 
improved food quality. 
ecosystem 
Improved 
from 
services 
the 
protection 
aquatic environment. 

of 

Economic  benefits  for 
aquaculture 
from 
improved food quality. 
ecosystem 
Improved 
from 
services 
protection 
the 
aquatic environment. 

of 

drinking 
Avoided 
water  treatment  costs. 
Economic  benefits  for 
aquaculture 
from 
improved food quality. 
economic 
Avoided 
impacts for agriculture 
(pollinators). 

Avoided 
human  health 
from 
impacts 
exposure 
to 
Neonicotinoids
. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

Avoided 
drinking 
water  treatment  costs. 
Economic  benefits  for 
aquaculture 
from 
improved food quality. 

Avoided 
human  health 
from 
impacts 
exposure 
to 
Neonicotinoids

Benefits 
and 
costs assessed as 
neutral. 
(Small  cost 
small benefit) 

/ 

 
 
Economic Impact 

Cost 

Benefits 

Social impact 

Overall 
balance 
costs 
benefits 

of 
and 

economic 
Avoided 
impacts for agriculture 
(pollinators). 

. 

Dista
nce 
to 
targe
t 

Medi
um 

Smal
l 

Smal
l 

Larg
e 

Larg
e 

Substance 

Imidaclop
rid 

Thiaclopri
d 

Thiametho
xam 

Bifenthrin 

Deltameth
rin 

Environmental 
impact 

environmental 
concerns 
terrestrial 
pollinators. 

for 

aquatic 
against 

Toxic 
effects 
invertebrates, 
arthropods, 
and 
crustaceans.  Wider 
environmental 
concerns 
terrestrial 
pollinators. 

for 

aquatic 
against 

Toxic 
effects 
invertebrates, 
and 
arthropods, 
crustaceans.  Wider 
environmental 
concerns 
terrestrial 
pollinators. 

for 

for 

aquatic 
against 

Toxic 
effects 
invertebrates, 
and 
arthropods, 
crustaceans.  Wider 
environmental 
concerns 
terrestrial 
pollinators. 
Highly  toxic  to  the 
aquatic 
environment 
at 
concentrations. 
Possible 
population 
impacts. 

risk  of 
level 

even 
low 

technologies  based  on 
Ozonation.  Costs  could 
considerable 
be 
to 
manage 
from 
run-off 
biocidal use in field. 
No  use  as  a  pesticide, 
but  ongoing  use  as  a 
including 
biocide 
veterinary 
for 
use 
animals  and  domestic 
pets.  Limited  chemical 
more 
alternatives, 
significant 
and 
effort for source control 
or end-of-pipe. 

cost 

despite 
Some 

Environmental 
look 
concentrations 
use 
stable 
use 
ceasing. 
issues  with  emergency 
authorisations.  Multiple 
chemical 
alternatives 
and  options  to  manage 
as  source  control  in  a 
cost-effective fashion.  
No  pesticide  approval 
but  use  as  a  biocide. 
Limited 
for 
source  control. pathway 
disruption  not  relevant. 
End-of-pipe 
would 
require  GAC  advanced 
treatment,  likely  to  be 
costly. 

options 

Limited 
chemical 
alternatives,  meaning 
/ 
restriction 
ban 
would 
likely  mean 
loss  of  crop  yield,  or 
of 
implementation 
integrated 
crop 
management. 
to 
Measures 
source  control  and 
pathway 
disruption, 
with  the  latter  set  of 
measures 
carrying 
significant  cost  given 
distance to target. 

linked 

drinking 
Avoided 
water  treatment  costs. 
Economic  benefits  for 
aquaculture 
from 
improved food quality. 
economic 
Avoided 
impacts for agriculture 
(pollinators). 

Avoided 
drinking 
water  treatment  costs. 
Economic  benefits  for 
from 
aquaculture 
improved food quality. 
Avoided 
economic 
impacts for agriculture 
(pollinators). 

Avoided 
drinking 
water  treatment  costs. 
Economic  benefits  for 
from 
aquaculture 
improved food quality. 
Avoided 
economic 
impacts for agriculture 
(pollinators). 

Avoided 
drinking 
water  treatment  costs. 
Economic  benefits  for 
aquaculture 
from 
improved food quality. 
Avoided 
economic 
impacts for agriculture 
(pollinators). 

even 
low 

Highly  toxic  to  the 
aquatic 
environment 
at 
concentrations. 
Possible 
population 
impacts. 

risk  of 
level 

Use  as  both  pesticide 
and  biocide.  Limited 
alternatives, 
chemical 
meaning 
/ 
restriction 
ban  would  likely  mean 
loss  of  crop  yield,  or 
of 
implementation 
integrated 
crop 
management.  Will  need 
a  package  of  measures 

Avoided 
drinking 
water  treatment  costs. 
Economic  benefits  for 
aquaculture 
from 
improved food quality. 
Avoided 
economic 
impacts for agriculture 
(pollinators). 

194 

Avoided 
human  health 
from 
impacts 
exposure 
to 
Neonicotinoids
. 
Societal 
impacts 
for 
domestic  pets 
if 
is 
use 
restricted. 
Avoided 
human  health 
from 
impacts 
to 
exposure 
Neonicotinoids
. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

Avoided 
human  health 
from 
impacts 
to 
exposure 
Neonicotinoids
. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

Avoided 
human  health 
impacts  where 
these 
substances  are 
identified 
as 
EDC.  Avoided 
impacts 
on 
pollinators. 
Possible 
food 
security  issues 
if  loss  of  use 
without 
chemical/non-
chemical 
alternatives  in 
place. 
Avoided 
human  health 
impacts  where 
these 
substances  are 
identified 
as 
EDC.  Avoided 
impacts 
on 
pollinators. 
Possible 

food 

 
 
 
 
 
Dista
nce 
to 
targe
t 

Larg
e 

Larg
e 

Larg
e 

Medi
um 

Substance 

Esfenvaler
ate 

Permethri
n 

Glyphosat
e 

Triclosan 

Economic Impact 

Environmental 
impact 

Cost 

Benefits 

even 
low 

Highly  toxic  to  the 
aquatic 
environment 
at 
concentrations. 
Possible 
population 
impacts. 

risk  of 
level 

even 
low 

Highly  toxic  to  the 
aquatic 
environment 
at 
concentrations. 
Possible 
population 
impacts. 

risk  of 
level 

to 

Potential  harm 
aquatic 
environments  given 
the very high usage 
rates  and  risks  for 
to  water, 
loss 
non-
including 
target  aquatic  flora. 
Exceedance 
rate 
based  on  potential 
EQS was high. 
Toxic  for  aquatic 
organisms 
(particularly  larvae 
eggs). 
and 
fish 
identified 
Effects 
range  of 
a 
on 
aquatic 
species 
including 
amphibians.  Some 

source  control, pathway 
disruption  and  end-of-
pipe.  Costs  likely  to  be 
significant. 

Limited 
chemical 
alternatives,  meaning 
restriction  /  ban  would 
likely mean loss of crop 
or 
yield, 
of 
implementation 
integrated 
crop 
management.  Measures 
linked  to  source  control 
and pathway disruption, 
with  the  latter  set  of 
measures 
carrying 
significant  cost  given 
distance to target. 

Use  as  both  pesticide 
and  biocide.  Limited 
alternatives, 
chemical 
meaning 
/ 
restriction 
ban  would  likely  mean 
loss  of  crop  yield,  or 
of 
implementation 
integrated 
crop 
management.  Will  need 
a  package  of  measures 
source  control, pathway 
disruption  and  end-of-
pipe.  The  end-of-pipe 
options 
to  be 
likely 
limited and costly (PAC 
treatment) 
advanced 
Overall  costs  likely  to 
be significant. 
Range  of  alternatives 
although 
available, 
costly. 
likely  more 
Source 
and 
pathway 
disruption 
measures  likely  needed 
will be costly. 

control 

as 

Intervention  is  either  as 
source  control  or  end-
of-pipe.  Use 
a 
biocidal  agent  in  soaps. 
Some  alternatives  and 
options for direct source 
End-of-pipe 
control. 
advanced 
treatment 
likely costly. 

195 

Avoided 
drinking 
water  treatment  costs. 
Economic  benefits  for 
from 
aquaculture 
improved food quality. 
Avoided 
economic 
impacts for agriculture 
(pollinators). 

drinking 
Avoided 
water  treatment  costs. 
Economic  benefits  for 
aquaculture 
from 
improved food quality. 
economic 
Avoided 
impacts for agriculture 
(pollinators). 

Avoided 
health 
impacts related to very 
wide  use  and  drinking 
water.  Avoided  costs 
of  water  treatment  for 
use  as  both  drinking 
water  and  agriculture 
use. 

costs 

of 
Avoided 
drinking 
water 
treatment.  Economic 
for 
benefits 
aquaculture 
from 
improved food quality 

Overall 
balance 
costs 
benefits 

of 
and 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

The  benefits  of 
addition  to  the 
PS list  outweigh 
the costs. 

Social impact 

security  issues 
if  loss  of  use 
without 
chemical/non-
chemical 
alternatives  in 
place. 
Avoided 
human  health 
impacts  where 
these 
substances  are 
identified 
as 
EDC.  Avoided 
impacts 
on 
pollinators. 
Possible 
food 
security  issues 
if  loss  of  use 
without 
chemical/non-
chemical 
alternatives  in 
place. 
Avoided 
human  health 
impacts  where 
these 
substances  are 
as 
identified 
EDC.  Avoided 
impacts 
on 
pollinators. 
Possible 
food 
security  issues 
if  loss  of  use 
without 
chemical/non-
chemical 
alternatives  in 
place. 

Protection  of 
drinking  water 
would be a key 
societal benefit 
usage 
given 
rates 
of 
glyphosate. 
Avoided 
health  impacts 
will be key. 

Avoided 
health  impacts 
human 
for 
health 
via 
exposure. 

 
 
Dista
nce 
to 
targe
t 

Larg
e 

Larg
e 

Not 
asses
sed 

Medi
um 

Substance 

PFAS 

Bisphenol 
A 

Microplast
ics 

Silver 

Economic Impact 

Environmental 
impact 

Cost 

Benefits 

Social impact 

Overall 
balance 
costs 
benefits 

of 
and 

and 
long-lasting 

evidence  of  anti-
microbial resistance 
issues. 
Widespread 
very 
environmental 
effects. 
dubbed 
chemicals’ 
good reason. 

PFAS 
‘forever 
with 

level 
an 

as 

Population 
effects 
endocrine 
disrupting  
chemical 
aquatic organisms. 

for 

Chronic  ecosystem 
level  effects  from 
physical 
and 
pathological 
impacts  of  micro-
plastics  for  aquatic 
and 
species 
accumulation 
at 
higher trophic tiers. 

aquatic 
effects, 
for 

Chronic 
toxicity 
primarily 
crustaceans. 
Nanoform  of  silver 
is the primary issue. 
Ionic form  of silver 
is  most  probably 
the primary issue. 

The  benefits  of 
addition  to  the 
PS list outweigh 
the costs. 

Benefits 
and 
costs assessed as 
neutral. 
(High 
cost 
high benefit) 

/ 

to 

that 
be 

Health 
are 
concerns 
founded 
well 
with 
human 
biomonitoring 
data 
highlighting 
societal 
impacts 
need 
minimised. 
Avoided 
health  impacts 
from exposure. 
Benefits  from 
protection  of 
aquatic 
environment 
as  ecosystem 
services. 

Benefits  from 
protection  of 
aquatic 
environment 
as  ecosystem 
services. 

Benefits 
and 
costs assessed as 
neutral. 
(High 
cost 
high benefit) 

/ 

Benefits 
and 
costs assessed as 
neutral. 
cost 
/ 
(High 
high 
benefit) 
Costs  outweigh 
the  benefits  of 
addition 

Benefits  from 
avoided  health 
impacts 
e.g. 
resulting  from 
to 
exposure 
bacteria 
that 
are co-resistant 
to 
the 
antibiotics  and 
silver  together 
(since 
they 
share  the  same 
mechanism  of 
the  resistance).  
No 
societal 
impacts 
identified. 

issue 

likely 
Complex 
needing  an 
integrated 
basket  of  measures  at 
all  stages  of  life-cycle. 
Costs  are  likely  to  be 
very significant. 

costs 

avoided 
Primarily 
from 
health 
to 
chronic  exposure 
pathway. 
Avoided 
environmental impacts 
for 
with 
benefits 
aquaculture, 
and 
farming. 

uses 

and 
Multiple 
to 
pathways 
Major 
environment. 
issue 
is  manufacture 
and use  of  epoxy  resins 
from 
losses 
and 
polycarbonate  and  PVC 
of 
articles.  Package 
measures  needed 
as 
source  control, pathway 
disruption  and  end-of-
pipe.  Diffuse  sources 
problematic  and  costs 
of 
achieving 
compliance  likely  very 
significant. 

Primary  source  is  for 
secondary 
microplastics 
are 
brake  and  tyre  wear, 
to  sewer 
emissions 
laundry 
from 
activities, 
land 
spreading  for  sludges. 
Management 
via 
disruption 
pathway 
and end-of-pipe likely 
to be costly. 
pathways 
Multiple 
to 
sources 
and 
environment  with  a 
package  of  measures 
source 
spanning 
control, 
pathway 
disruption,  and  end-
of-pipe needed to help 
achieve  compliance. 
‘small’ 
the 
Given 
target 
distance 
to 
expect 
would 
prioritisation 
of 
sources nationally. 

costs 

of 
Avoided 
water 
drinking 
treatment. 
Avoided 
environmental impacts 
for aquaculture. 
for 
Innovation 
development 
of 
alternative  chemicals 
and technologies. 

costs 

of 
Avoided 
water 
drinking 
treatment. 
Avoided 
environmental impacts 
for aquaculture. 
for 
Innovation 
development 
of 
alternative  chemicals 
and technologies. 

Avoided 
environmental impacts 
health 
for 
human 
(water  can  be 
the 
reservoir  of    bacteria 
resistant  to  the  silver 
due  to  the presence  of 
silver as pressure) and 
aquaculture. 
for 
Innovation 
development 
of 
alternative  chemicals 
and technologies. 

196 

 
 
Table A9.2: Examples of monetized impacts for surface water Option 1 

Environmental impact 

Economic Impact 

Social impact 

long-lasting 

reproduction 

Ibuprofen 
toxic  effects 

environmental 
Avoided/reduced 
impacts and potential toxic effects on 
aquatic  species.  E.g.  Carbamazepine 
has  population  effects  for  aquatic 
species  through  impacts  on  fertility 
and 
(particularly 
crustaceans).  Silver  also  has  chronic 
aquatic  toxicity  effects,  primarily  for 
crustaceans. 
exhibits 
for  some 
potential 
aquatic  species 
including  fertility 
effects (hormone levels) in fish while 
nicosulfuron  has  aquatic 
toxicity 
(particularly  to  flora)  and  concerns 
over  carcinogenicity  as  a  secondary 
poisoning issue. Diclofenac is one of 
the  highest  concern  pharmaceuticals 
impacts  with 
for  environmental 
potential 
toxic  effects  on  avian 
populations via surface water species. 
Estrone  E1,  17-  Beta  estradiol  (E2), 
Ethinyl estradiol (EE2) are associated 
with chronic ecosystem level impacts 
from  exposure 
to  hormones  and 
EDC.  PFAS  has  a  widespread  and 
very 
environmental 
effects  while  Bisphenol  A  causes 
population 
level  effects  as  an 
endocrine  disrupting  chemical  for 
aquatic  organisms.  Triclosan  is  toxic 
for  aquatic  organisms  particularly 
larvae  and  fish  eggs  with  effects 
identified  on  a  range  of  aquatic 
amphibians. 
species 
Clothianidin, 
Acetamiprid, 
Thiacloprid, 
Imidacloprid, 
Bifenthrin, 
Thiamethoxam 
Deltamethrin 
and 
Permethrin  are  associated  with  toxic 
aquatic  effects  against  invertebrates, 
arthropods,  and  crustaceans  with 
wider  environmental  concerns  for 
terrestrial 
(with 
Deltamethrin 
Bifenthrin, 
being 
Esfenvalerate, 
aquatic 
highly 
toxic 
low 
environment 
concentrations). 
is 
associated  with  potential  harm  to 
aquatic  environments  given  the  very 
high usage rates and risks for loss to 
water,  including  non-target  aquatic 
flora. 
Microplastics:  chronic  ecosystem 
level  effects  from  physical  and 
impacts  of  micro-
pathological 
plastics  for  aquatic  species  and 
accumulation  at  higher  trophic  tiers. 
Primary 
secondary 
microplastics  are  brake  and  tyre 
from 
wear,  emissions 
laundry activities, land spreading for 
sludges.  

Permethrin 
to 
even 

Esfenvalerate 

Glyphosate 

pollinators 

to  sewer 

including 

source 

the 

for 

at 

Significant  costs  to  ensure  compliance  with  proposed  EQS  for 
Ethinyl  estradiol  (EE2),  Ibuprofen,  Clothianidin,  Imidacloprid, 
Thiamethoxam, Bifenthrin, Deltamethrin, Esfenvalerate, Permethrin, 
Glyphosate, Triclosan, PFAS and Bisphenol A implementing a range 
of source control, pathway disruption, targeted end of pipe treatment 
measures.  E.g. 
the  cost  of  a  take-back  scheme  for  unused 
pharmaceuticals  in  France  is  €10  million.  The  2022  Annex  XV 
restriction report for the proposed restriction of PFASs in firefighting 
foams estimates that the ban is estimated to cost society €6.8 billion 
over  a  30-year  period  or  €390  million  per  year.  Costs  of  pathway 
disruption  measures  (e.g.  buffer  strips)  is  €472  million  per  year  for 
pharmaceuticals;  for  pesticides  these  range  from  €162  million  for 
clothianidin  and  imidacloprid  to  €285  million  for  glyphosate. 
Wastewater  treatment  range  is  €10-  €32  per  population  equivalent, 
per annum (technology dependent). For instance, use of GAC at 20% 
of  UWWTPs  at  or  above  50,000  P.E.  would  equate  to  annualised 
costs  of  €2  billion  per  year  (25  year  lifetime)  and  would  close 
distance to target for Thiamethoxam. 
Silver:  Multiple  pathways  and  sources  to  environment  with  a 
package  of  measures  spanning  source  control  (abatement  upgrades, 
restricted  use,  capture  and  treat  for  mine  drainage),  pathway 
disruption  (estimated  as  €103  million  per  annum),  and  end-of-pipe 
(estimated as €2.5 billion per annum for reverse osmosis in 33% of 
all  UWWTPs  serving  ≥50K  P.E.) 
  needed  to  help  achieve 
compliance. 
Moderate/Small  costs  to  ensure  compliance  for  Estrone  E1,  17- 
Beta  estradiol  (E2),  Diclofenac,  Carbamazepine,  Azithromycin, 
Thiacloprid, 
Clarithromycin, 
Nicosulfuron  due  to  small  distance  to  target,  availability  of  source 
control  and  pathway  disruption  measures  and/or  positive  impact  of 
forthcoming  revision  of  the  UWWTD  on  quaternary  end  of  pipe 
treatment.  E.g.  costs  of  pathway  disruption  measures  (e.g.  buffer 
strips)  for  pesticides    range  from  €1.6  million  for  acetamiprid  to 
€12.8  million  for  nicosulfuron.  Wastewater  treatment  cost  range  is 
€10-  €20  per  population  equivalent,  per  annum  (technology 
dependent).  For  instance,  use  of  ozonation  on  all  UWWTPs  at  or 
above 50,000 P.E. would equate to annualised costs of €318 million 
per  year  (25  year  lifetime)  and  would  close  distance  to  target  for 
Estrone  E1,  17-  Beta  estradiol  (E2),  Azithromycin,  Clarithromycin, 
Erythromycin, Diclofenac, Carbamazepine. 

Erythromycin, 

Acetamiprid, 

on 

and 

impacts 
Clothianidin, 

pollinators 
Imidacloprid, 

Monitoring costs: range from €11-100 per sample for all substances 
except  for  PFAS.  For  PFAS  analytical  costs  are  up  to  €250  per 
sample. 
agriculture 
Avoided/reduced 
(Acetamiprid, 
Thiacloprid, 
Thiamethoxam, Bifenthrin, Deltamethrin Esfenvalerate, Permethrin). 
E.g.  across  Europe,  crop  pollination  by  insects  accounted  for 
approximately €14.6 billion annually. 
Economic  benefits  for  aquaculture  from  improved  food  quality 
(Estrone  E1,  17-  Beta  estradiol  (E2),  Ethinyl  estradiol  (EE2), 
Acetamiprid, 
Thiacloprid, 
Thiamethoxam  Bifenthrin,  Deltamethrin  Esfenvalerate,  Permethrin, 
triclosan, 
Diclofenac,  Carbamazepine, 
PFAS, bisphenol A). 
Avoided costs of water treatment for drinking water, agriculture and 
industry  (Acetamiprid,  Clothianidin,  Imidacloprid,  Thiacloprid, 
Thiamethoxam  Bifenthrin,  Deltamethrin  Esfenvalerate,  Permethrin, 
glyphosate, triclosan, bisphenol A, PFAS, microplastics) (in the case 
of  source  control  and  pathway  disruption  measures).  E.g.  in  2015, 
approximately  €0.5 billion  was  spent  annually  to  remove  pesticides 
in wastewater treatment plants (WWTP) in Europe. 
Innovation 
technologies (e.g. Bisphenol A). 

for  development  of  alternative  chemicals  and 

ibuprofen,  Nicosulfuron, 

Imidacloprid, 

Clothianidin, 

197 

to 

and 

from 

Europe 

the  fact 
in 

Avoided/reduced human health impacts 
from  Glyphosate,  Triclosan,  PFAS, 
Bisphenol  A  via  reduced  exposure 
through drinking water (Bisphenol A is 
associated  with  childhood  obesity 
which  could  cost  the  EU  around  €1.8 
Neonicotinoids 
billion); 
Clothianidin, 
(Acetamiprid, 
Thiacloprid, 
Imidacloprid, 
(Bifenthrin, 
Thiamethoxam),  EDC 
Esfenvalerate, 
Deltamethrin 
(potential) 
Permethrin,  EE2) 
carcinogenic  effects  (Ethinyl  estradiol 
(EE2), Nicosulfuron). E.g. Annual costs 
related to endocrine disruptors exposure 
were estimated to be €163 billion. This 
is  due 
that  endocrine 
contribute 
disruptors 
substantially to neurobehavioral deficits 
and  disease,  with  a  high  probability  of 
>€150 billion  costs  annually  as  well  as 
childhood  obesity  which  costs  €1.54 
billion annually.  
Protection  against  AMR  has  clear 
societal  benefits  and  avoided  costs  to 
healthcare  from  protections  against  the 
development  of  AMR  within  health 
settings (Azithromycin, Clarithromycin, 
Erythromycin).  E.g.  It  is  estimated that 
AMR costs the EU €1.5 billion per year 
in  healthcare  costs  and  productivity 
losses. 
Specific  to  PFAS  the  annual  health 
to  kidney  cancer 
expenditure  due 
caused  by  PFAS  exposure  estimated  to 
be  €12.7  to  €41.4  million  in  the  EEA 
countries.  The  study  also  estimated 
around  €10.7  to  €35  billion  of  annual 
to  hypertension 
health  costs  due 
brought  about  by  background  exposure 
(exposed  via 
consumer  products, 
background levels).  
Possible  societal  impacts  from  loss  of 
use  (contraceptive  pill,  HRT,  hormone 
treatments  if  Ethinyl  estradiol  (EE2)  is 
restricted/banned. 
loss  of  use 
Societal 
/restricted 
Diclofenac, 
Carbamazepine,  Ibuprofen  if  controls 
implemented  and  increased  costs  for 
other 
types  of  medicine  (including 
prescription only medications). 
Possible  food  security  issues  if  loss  of 
chemical/non-chemical 
use  without 
(Bifenthrin, 
alternatives 
Deltamethrin, 
Esfenvalerate, 
Permethrin). 
Societal 
owners 
restricted. 
Increased  prices  of  goods  and  services 
as a result of source control measures.  

for  domestic  pet 
is 
Imidalcoprid 

impacts  from 
of 

impacts 
if  use  of 

place 

use 

in 

 
 
1.2.  Option 2: Include candidate PS as groups of substances where appropriate. 
Set  corresponding  EQS  using  markers  or  the  sum  of  substance 
concentrations in the case of groups. 

The  second  option  also  focusses  on  the  candidate  substances  to  add  to  the  PS  list,  but  as 
groups.  There  can  be  good  reasons  to  rationally  consider  the  possibility  of  using  grouping 
approaches when adding substances to the priority substance list. This option identified four 
possible  groups  –  estrogenic  hormones,  macrolide  antibiotics,  neonicotinoid  pesticides, 
pyrethroid pesticides (noting that the addition of PFAS as a group has already been confirmed 
and included as part of Option 1). 

Table A9.3 provides the outcome of the impact assessment and balance of costs and benefits. 
There  are  a  series  of  metrics  which  can  strengthen  of  weaken  the  argument  for  whether  a 
grouping  approach  is  sensible  and  adds  value  to  the  way  that  the  substances  are  managed. 
Based  on  the  analysis  of  these  metrics  three  out  of  the  four  possible  grouping  approaches 
(estrogens, neonicotinoids, and pyrethroids) have multiple problems which mean that in the 
balance of costs and benefits a grouping approach is not recommended. 

The final possible grouping (macrolide antibiotics) showed a great deal of benefits for using a 
grouping approach, with the one major issue being the variation in potency. In this case the 
proposed  EQS  values  vary  significantly  (Azithromycin  AA  and  MAC  0.019  µg/L; 
Clarithromycin AA and MAC 0.13 µg/L; Erythromycin AA and MAC 0.5 µg/L). In this case 
the use of a relative potency factor  (RPF)  approach (similar to  what  has been proposed for 
PFAS) aligned to the equivalency of azithromycin could warrant further investigation. If this 
proved  not  possible/unfruitful,  the  variations  in  potency  would  suggest  a  single  EQS  entry 
would be unwise. 

Table A9.3: Surface water option 2 – summary of impacts  

Substance 
group 

Environmental 
impacts 

Economic impacts 

Cost 

Benefit 

Estrogenic 
hormones 

Possible 
incoherence  issues 
linked to difference 
in potency. 

Incoherence  issues 
could 
affect 
measure  selection 
and  negative  cost 
impacts. 

consistent 
More 
approach 
to 
managing  selection 
of  alternatives  and 
substitution  where 
needed. 

Overall  balance 
of 
and 
costs 
benefits 

potential 
outweigh 
benefits. 
not 

The 
costs 
the 
Grouping 
recommended 

Social impacts 

in 

Lack  of  granular 
data  for  E1,  E2, 
aquatic 
EE2 
environment  could 
lead 
less 
to 
effective 
management  with 
societal 
negative 
consequences. 

Macrolide 
antibiotics 

Greater  coherence 
in  the  approach  to 
AMR if grouped. 

Neonicoti-
noids 

Greater  coherence 
in  the  approach  to 
of 
protection 
pollinators 
if 
grouped. 

Azithromycin has a 
greater  distance  to 
target,  if  grouped, 
would  measures 
have to work to the 
member 
worst 
substance 
(i.e., 
greater 
unnecessary cost?) 

Variations  in  use, 
pathways, 
and 
measures. 
Grouping 
could 
create  incoherence 
in  measures  and 

Correlation  on  use, 
to 
pathway 
and 
environment 
measures, 
could 
mean cost savings is 
managed as a group. 

Greater  coherence 
in  the  approach  to 
AMR if grouped. 

could 
Benefits 
outweigh  costs. 
But  variation  in 
potency  an  issue 
for investigation. 

No 
benefits identified. 

economic 

Greater  coherence 
in  the  approach  to 
of 
protection 
pollinators 
if 
grouped. 

potential 
outweigh 
benefits. 
not 

The 
costs 
the 
Grouping 
recommended. 

198 

 
 
 
 
Pyrethroids 

unnecessary costs. 

Uses  and  pathways 
environment 
to 
Grouping 
vary. 
create 
could 
issues 
coherence 
would 
that 
negatively 
impact 
environmental 
protections. 

Loss  of  granular 
by 
(substance 
data 
substance) 
impacts  measure 
and 
selection 
effectiveness 
of 
measures. 

limited 

Very 
alternatives, 
grouping  approach 
could  mean  a  more 
holistic 
approach 
avoiding  regrettable 
substitution 
and 
associated costs. 

or 
costs 
No 
benefits identified. 

potential 
outweigh 
benefits. 
not 

The 
costs 
the 
Grouping 
recommended. 

1.3.  Option  3:  Revise  EQS  where  necessary  based  on  new  scientific  data  for 

existing PS. 

Option 3 is based on the fact that the scientific data available has evolved since the original 
analysis  and  risk  assessment  for  pre-existing  EQS  values.  Where  the  proposed  EQS 
amendments reflect a robust and thorough investigation of the new and emerging science to 
re-appraise the EQS values it can be expected that the proposed amendments already reflect 
environmental benefits to address the risks more appropriately. Equally where the proposed 
EQS amendments also include a relaxation of the thresholds where the existing threshold is 
deemed overly cautious, it is possible to see that there would also be economic benefits in the 
fact that measures may no longer be needed and the resources can be reallocated in a more 
effective fashion to target other issues. 

The impact assessment has also recognised that for pre-existing EQS substances, there will be 
a distance to target based on the current situation (baseline) and based on the proposed EQS 
the distance target may remain unchanged, get bigger, or get smaller. Table A6.5 provides the 
results  of  this  impact  assessment.  Similarly,  to  option  1  the  relative  balance  of  costs  and 
benefits resulted in three possible outcomes - it has been possible for the benefits to outweigh 
the costs, the costs to outweigh the benefits, and the costs and benefits being balanced (i.e. a 
neutral result). 

For the majority of the substances targeted for amendment of EQS the benefits outweigh the 
costs,  either  through  greater  environmental  protections,  or  more  accurate  EQS  allowing 
suitable  prioritisation  of  risks  and  measures.  For  a  smaller  set  of  substances,  the  impact 
assessment  draws  a  neutral  result  (chlorpyrifos,  cypermethrin,  mercury,  nickel,  and  PAHs). 
This  is  because  the  revised  EQS  is  significantly  more  stringent  and  will  determine  new 
measures are likely needed to help achieve good chemical status. However, based on the new 
risk assessment it can also be determined that the risks to date have been underestimated, and 
therefore the additional effort is warranted. 

Based on the analysis of substances in the neutral category, the most uncertain will be nickel. 
The  proposed  EQS  amendment  is  likely  to  create  a  new  wave  of  exceedances,  with 
potentially an extensive package of measures needed to achieve good chemical status. Given 
the potential uncertainties involved, this may be the one substance where, depending on the 
specific measures implemented, the costs outweigh the benefits. However, the margins in this 
case are very tight and overall, the impact assessment assesses that the balance of costs and 
benefits will be neutral.  

199 

 
 
 
 
Table A9.4: Surface water option 3 – summary of impacts  

Substa
nce 

Distan
ce 
to 
target
* 

Economic Impact 

Environmenta
l impact 

Cost 

Chlorp
yrifos 

Mediu
m 

EQS 
Updated 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

lower 

is 
The  proposed  EQS 
than 
considerably 
the  existing  one.  Possible 
additional  analytical  costs. 
Where  Chlorpyrifos  is  no 
longer  approved,  measures 
will  likely  target  diffuse 
sources  and  legacy  issues. 
Potential additional costs. 

Benefits 

Limited 
economic 
benefits 
identified. 
Possible 
advances 
analytical 
techniques 
could 
bring 
down the cost of 
analysis 
over 
time. 

in 

Social 
impact 

Overall  balance  of 
costs and benefits 

the 

human 

Improved 
protections 
for 
health. 
Particularly 
given 
recent 
nomination 
as a POP and 
issues 
around 
bioaccumula
tion. 

Based  on  the  review 
of 
and 
reappraisal 
EQS 
additional 
be 
measures  may 
warranted.  Costs  are 
considered 
proportionate 
addressed risks. 
Option  assessed  as 
neutral 
(Medium 
cost 
medium benefit) 

the 

to 

/ 

Cyper
methri
n 

Mediu
m 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

is  more 
Proposed  EQS 
need 
stringent.  May 
additional 
measures 
targeting  timber  treatment, 
including 
in-use  stocks. 
Costs likely significant. 

Avoided  health 
costs 
for 
aquaculture  and 
ecosystem 
services. 

Improved 
environment
al 
protections 
for 
ecosystem 
services. 

Based  on  the  review 
of 
and 
reappraisal 
additional 
EQS 
measures  may 
be 
warranted.  Costs  are 
considered 
proportionate 
addressed risks. 
Option  assessed  as 
neutral 
(Medium 
cost 
medium benefit) 

the 

to 

/ 

Dicofol 

Small 

Diuron 

Mediu
m 

Small 

Heptac
hlor/ 
heptach
lor 
oxide 

Hexach
loro-
benzen

EQS 
Updated 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
provide 
would 
more  appropriate 
protections. 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

Proposed  EQS 
is  more 
stringent, but only a minor 
alteration to AA and biota. 
No  expected  additional 
costs. 

as 

EQS 

is 
Proposed 
more 
significantly 
stringent.  Use 
a 
pesticide  and  biocide  has 
ceased. 
Additional 
measures  likely  to  address 
as 
industrial 
improved 
restrictions 
abatement.  Also 
legacy 
issues  from  contaminated 
sites. 

uses 
/ 

The  proposed  EQS  is  less 
stringent.  No  additional 
costs expected. 

Proposed  EQS  is 
stringent, 
more 
but  only  a  minor 
alteration  to  AA 
and  biota.  No 
expected 
additional 
economic 
benefits. 

social 

No 
impacts 
identified. 

Potential 
innovation 
opportunity 
to 
remove use as an 
in 
intermediate 
manufacture  of 
rubber products. 

Improved 
human 
health 
protections 
given  diuron 
is an EDC. 

proposed 
The 
EQS 
less 
is 
stringent, 
meaning 
resources  can  be 
reallocated 
and 
costs  saved  from 
measures 
no 
longer needed. 

No  specific 
social 
impacts 
identified. 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified.  
Amendment 
preferrable. 

is 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
risks 
the  EQS  and 
understated. 
The 
benefits  still  outweigh 
the additional costs.  
Amendment 
preferrable. 

is 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified.  
Amendment 
preferrable. 

is 

Small 

Updated 
EQS 
based  on  new 
science  and  re-

The  proposed  EQS  is  less 
stringent.  No  additional 
costs expected. 

proposed 
The 
EQS 
less 
is 
stringent, 

No  specific 
social 
impacts 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 

200 

 
Distan
ce 
to 
target
* 

Economic Impact 

Environmenta
l impact 

Cost 

Substa
nce 

e 

appraisal  of  risk, 
provide 
would 
more  appropriate 
protections. 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

Proposed  EQS  is  more 
stringent  for  biota.  Given 
use  has  ceased.  Likely 
measures include upgrade 
of  WWTWs  and  natural 
attenuation.    The  costs  of 
the 
be 
former  will 
captured  by  the  revised 
UWWT Directive. 

Social 
impact 

Overall  balance  of 
costs and benefits 

identified. 

the EQS and no/limited 
impacts identified.  
Amendment 
preferrable. 

is 

Benefits 

meaning 
resources  can  be 
reallocated 
and 
costs  saved  from 
measures 
no 
longer needed. 

Avoided  health 
costs 
for 
aquaculture  and 
ecosystem 
services. 

No  specific 
social 
impacts 
identified. 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified. 
Amendment 
preferrable. 

is 

Tributy
ltin 

Mediu
m 

Dioxins 
and 
furans 

Mediu
m 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

Reduction in the proposed 
EQS  for  biota  could  lead 
to  additional  analytical 
costs.  Limited  scope  for 
additional measures likely 
natural attenuation. 

economic 

No 
benefits 
identified 
amendment 
the EQS. 

from 
of 

Fluora
n-thene 

Small 

Hexach
loro-
butadie
ne 

Small 

EQS 
Updated 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
provide 
would 
more  appropriate 
protections. 

The proposed EQS  is less 
stringent.  No  additional 
costs expected. 

still  be 

Proposed  EQS  is  more 
stringent,  likely  to  trigger 
some 
additional 
exceedances, but grouping 
‘small’. 
will 
Limited 
of 
sources,  which  would 
target  manufacturing  and 
end-of-pipe.  Costs 
are 
considered  proportionate 
to the addressed risks. 

number 

proposed 
The 
less 
is 
EQS 
stringent, 
meaning 
resources  can  be 
reallocated 
and 
costs  saved  from 
measures 
no 
longer needed. 

No  specific  cost 
benefits 
identified. 

Nonyl 
Phenol 

Small 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

Proposed EQS has a more 
stringent  AA  and 
less 
stringent  MAC.  Primary 
issue is imported clothing. 
Expect 
end-of-pipe 
measures to address much 
of the issue. 

No  specific  cost 
benefits 
identified. 

in 

Some 
additional 
society 
benefits 
tackling 
environment
al 
concentratio
ns 
given 
bioaccumula
tion 
potential. 

No  specific 
social 
impacts 
identified. 

human 

Improved 
protections 
for 
health. 
Particularly 
given 
HBCDD  is  a 
and 
POP 
issues 
around 
bioaccumula
tion. 

Improved 
human 
health 
protections 
from 
additional 
controls. 
Improved 
ecosystem 
services. 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified. 
Amendment 
preferrable. 

is 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified. 
Amendment 
preferrable. 

is 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified. 
Amendment 
preferrable. 

is 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified. 
Amendment 
preferable. 

is 

PAHs 

Mediu

Updated 
EQS 
based  on  new 

The  proposed  EQS  could 
be  expected  to  trigger  a 

No  specific  cost 
benefits 

Improved 
health 

Based  on  the  review 
of 
reappraisal 
and 

201 

 
Economic Impact 

Environmenta
l impact 

Cost 

Social 
impact 

Overall  balance  of 
costs and benefits 

Benefits 

identified. 

Substa
nce 

Distan
ce 
to 
target
* 
m 

PBDEs 

Large 

science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

to 

new wave of exceedances, 
including  promotion  of 
the  distance 
target. 
Measures  will  likely  need 
to target source-control on 
combustion 
and 
metallurgy  and  pathway 
disruption 
run-off 
from road and field. Costs 
could be significant. 

for 

The  proposed  EQS  is  less 
stringent.  No  additional 
costs expected. 

proposed 
The 
EQS 
less 
is 
stringent, 
meaning 
resources  can  be 
reallocated 
and 
costs  saved  from 
measures 
no 
longer needed. 

protection 
from 
avoiding 
exposure 
PAHs. 
Improved 
ecosystem 
services. 

to 

No  specific 
social 
impacts 
identified. 

Mercur
y 

Large 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

additional 

Amendment  of  the  EQS 
will likely trigger the need 
for 
source 
pathway 
and 
controls 
disruption. Costs are likely 
to be significant. 

Avoided  costs of 
health 
impacts 
for  aquaculture. 
Avoided costs on 
impacts 
to 
ecosystem 
services. 

Greater 
human 
health 
protections 
on  exposure 
to  mercury 
as  a  chronic 
pollutant. 

Nickel 

Mediu
m 

Updated 
EQS 
based  on  new 
science  and  re-
appraisal  of  risk, 
would 
provide 
more  appropriate 
protections. 

EQS 

likely 

a  wave 

is 
Proposed 
more 
significantly 
to 
stringent  and 
of 
trigger 
Primarily 
exceedances. 
to 
measures  will  need 
source-controls 
target 
(fossil 
fuel  combustion, 
metal  manufacture,  basic 
surface 
organics, 
and 
pathway 
treatments), 
disruption (mine drainage), 
and end of pipe treatments. 

Avoided  costs of 
health 
impacts 
for  aquaculture. 
Avoided costs on 
impacts 
to 
ecosystem 
services. 

Greater 
human 
health 
protections 
on  exposure 
to nickel as a 
chronic 
pollutant. 

* Bold and red denotes a change in group based on amended EQS. 

202 

EQS 
additional 
be 
measures  may 
warranted.  Costs  are 
considered 
proportionate 
addressed risks. 
Option  assessed  as 
neutral 
(High  cost 
benefit) 

/  high 

the 

to 

On  the  basis  that  new 
scientific  evidence  has 
been  used  to  re-assess 
the EQS and no/limited 
impacts identified. 
Amendment 
preferrable. 

is 

The  distance  to  target 
was already large with 
mercury 
responsible 
for the highest number 
of EQS failures. 
The  amendment  of 
biota 
and 
EQS 
addition  of  AA  EQS 
will  likely  trigger  a 
of 
wave 
new 
with 
exceedances 
significant  cost 
for 
compliance.  However, 
the 
are 
benefits 
equally as important. 
Option  assessed  as 
neutral 
(High  cost 
benefit) 

/  high 

The  proposed  amended 
EQS is likely to trigger 
of 
a 
new  wave 
exceedances 
with 
application of extensive 
measures 
to  achieve 
compliance.  This  will 
carry significant costs. 
However,  based  on  the 
review of new evidence 
the 
from 
benefits 
avoiding 
impacts  are 
also  more  significant 
previously 
than 
thought. 
Option  assessed  as 
neutral 
(High  cost 
benefit) 

/  high 

 
Table A9.5: Examples of monetized impacts for surface water Option 3  

Environmental 
impact 

Economic Impact 

Social impact 

(all 

for 
services 

Updated  EQS  based 
on  new  science  and 
re-appraisal  of  risk 
would  provide  more 
appropriate 
protections 
substances). 
Reduced 
environmental 
concentrations, 
improved 
environmental 
protections 
ecosystem 
(cypermethrin, 
nonylphenols, 
PAHs). 
Avoided  health  costs 
for 
aquaculture 
(cypermethrin, 
tributyltin,  mercury, 
nickel) 
innovation 
Potential 
opportunity 
to 
remove  use  as  an 
in 
intermediate 
of 
manufacture 
rubber 
products 
(diuron).  

endocrine 

associated 

for 
Improved  protections 
human health particularly in 
relation  of  POP  substances, 
around 
issues 
bioaccumulation 
(dioxins 
furans,  chlorpyrifos, 
and 
hexachlorobutadiene),  EDC 
chlorpyrifos), 
(diuron, 
exposure 
chronic 
to 
pollutants (mercury, nickel). 
E.g. chlorpyrifos and PBDE 
disruptors 
as 
with 
were 
deficit 
attention 
hyperactivity 
disorder 
(ADHD)  and  with  other 
cognitive  deficiencies.  The 
productivity  loss  caused  by 
these  disorders  is  estimated 
to  be  €124  billion  annually 
Additionally, 
in 
prenatal 
to 
chlorpyrifos  across  the  EU 
would  cost  an  additional 
€21.4 billion in social costs. 
The 
of 
neurotoxicity 
chlorpyrifos  is  estimated  to 
be 70 to 100% according to 
and 
the 
epidemiological 
evidence, 
toxicological 
which  corresponds 
to  a 
social  cost  of  €46.8  billion 
and €195 billion annually in 
the  EU. 
also 
estimated  that  the  cognitive 
by 
deficits 
chlorpyrifos 
and 
methylmercury  would  cost 
the  EU  €177  billion  and 
€9.89 billion, respectively. 

exposure 

It  was 

caused 

EU. 

the 

cobalt 

and  mercury 

copper,  nickel, 

toxicity  exposure  from 

Significant  costs  to  ensure  compliance  for  Cypermethrin,  Chlorpyrifos, 
Diuron,  PAHs,  Mercury,  Nickel  implementing  a  range  of  source  control, 
pathway  disruption,  targeted  end  of  pipe  treatment  measures.  Wastewater 
treatment (end of pipe) related measures for heavy metal removal, generally 
relates  to  primary  treatments  (usually  primary  settling  followed  by  an 
activated  sludge  process).  Although,  conventional  treatment  of  wastewater 
already  significantly  reduces 
inorganic 
constituents  (including  heavy  metals)  on  freshwater  and  seawater,  recent 
available  data  on  heavy  metal  speciation  and  removal  shows  that,  during 
primary  settling,  sorption  technologies  may  cost  effectively  enhance  the 
removal  of  Cu  and  Ni,  while  coagulation  may  be  efficient  for  Cd,  Cr,  Cu, 
Pb,  Zn  and  Hg  removal  (but  not  as  efficient  for  Ni  removal)  138  139.  Also, 
scientific  results  show  that  Apatite  can  be  suitable  material  to  remove 
from  water140. 
cadmium, 
For PAHs, e.g. the restriction proposal which would ensure that granules or 
mulches  (in  particular  from  end-of-life  tyres)  are  not  placed  on  the  market 
for  use  or  used  as  infill  material  in  synthetic  turf  pitches  or  similar 
applications  if  they  contain  more  than  20  mg/kg  in  total  of  the  eight 
indicator-PAHs would cost €45m over a 10-year period. Run-off disruption 
from  roads  would  cost  €75  million to install  gully  pots.  Data  suggests  that 
gully pots cost €50 per item to install and to be effective should be placed 50 
metres apart. Based on the total length of all EU27 motorways (75,000 km), 
around 1,500,000 gully pots should be installed. Also, water  from the road 
surface from motorways is typically channelled into surface water untreated. 
Minor roads/city roads on the other hand are often connected to a Combined 
Sewer Overflow (CSO) system and go to WWTWs. Therefore, minor roads 
were excluded from the calculations.  
Costs  of  additional  controls  and  treatment  for  farmed  animal  use  of 
cypermethrin  are  €27.6  m.  Wastewater  treatment  (Mercury,  Nickel,  PAH, 
Cypermethrin)  -  €1.17-  €26.2  per  population  equivalent,  per  annum 
(technology dependent). 
Mine  drainage  (Mercury  /  Nickel)  -  €100,000  -€10,000,000  per  plant  and 
€0.4 per dm3 operating costs. 
Moderate/Small  costs  to  ensure  compliance  for  Dioxins  and  furans, 
Hexachlorobutadiene,  Nonyl  Phenol,  Tributyltin  due  to  small  distance  to 
target  and/or  limited  scope  for  additional  measures  (likely  to  be  natural 
attenuation  and  baseline  end  of  pipe  treatment  (under  the  revised 
UWWTD)).  E.g.  the  costs  of  restricting  nonylphenol  (NP)  and  its 
ethoxylates (NPE) in textiles was estimated to cost the EU €3.2m per annum 
for a reduction of 15 tonnes of NP/NPE released to surface water. 
No additional costs for Dicofol. 
Monitoring:  Amendments  for  Chlorpyrifos  and  Dioxins  and  furans  could 
lead  to  additional  analytical  costs  (due  to  the  proposed  EQS  being 
considerably lower). 
Cost  savings  and  efficiencies:  the  proposed  EQS  is  less  stringent  for 
heptachlor/ heptachlor oxide, hexachlorobenzene, PBDEs and fluoranthene- 
resources  can  be  reallocated  and  costs  saved  from  measures  no  longer 
needed.  For  PBDEs  it  needs  to  be  noted  that  the  avoided  costs  for  human 
health will also decrease if a less stringent EQS would be implemented. 

138  Heavy  metal  removal  from  wastewater  using  various  adsorbents:  a  review:  https://iwaponline.com/jwrd/article/7/4/387/28171/Heavy-metal-
removal-from-wastewater-using-various 

139 
https://www.researchgate.net/publication/350998245_Removal_of_Heavy_Metals_during_Primary_Treatment_of_Municipal_Wastewater_and_Possi
bilities_of_Enhanced_Removal_A_Review 

140 Removal of cadmium, copper, nickel, cobalt and mercury from water by Apatite: https://pubmed.ncbi.nlm.nih.gov/21871722/ 

203 

 
                                                           
1.4.  Option  4:  Review  possible  deselection  of  substances  shortlisted  following 

agreed deselection criteria. 

The final option within the surface water category relates to the potential  deselection of PS 
that no longer present an EU-wide risk to the environment. A set of deselection criteria were 
used  to  identify  candidates  for  deselection.  Deselected  substances  could  and  should  still  be 
addressed as RBSPs at national level where a risk still exists. 

The outcome of the impact assessment, which concluded that the identified substances could 
be deselected from the PS list with the economic and environmental benefits outweighing any 
potential costs. This includes consideration of the risk that use might recommence/increase. 

Table A9.6: Surface water option 4 – summary of impacts 

Substance  

Environmental impacts 

Economic impacts 

Cost 

Benefit 

Social impacts 

Alachlor 

Simazine 

Chlorfenvinphos 

Trichlorobenzenes 

Carbon 
tetrachloride 

in 

Banned 
the  EU  for 
many  years,  only  5  water 
bodies  out  of  97,000 
exceed  the  EQS.  Risk  to 
environment is low. 

in 

Banned 
the  EU  for 
many  years,  only  4  water 
bodies  out  of  97,000 
exceed  the  EQS.  Risk  to 
environment is low. 

in 

the  EU  for 
Banned 
many  years,  only  6  water 
bodies  out  of  97,000 
exceed  the  EQS.  Risk  to 
environment is low. 

are 
the 

in  use,  and 

these 
Still 
acutely 
substances 
toxic 
aquatic 
to 
environment. However, the 
rate  of  exceedance  is  very 
low.  Possible  to  maintain 
protection  by  designating 
as a RBSP where needed. 

Still  in  use  but,  is  not  a 
POP,  and  as  noted  under 
the 
option  4, 
rate  of 
exceedance 
is  extremely 
low  and  the  risk  to  the 
equally 
environment 
low.  Possible  to  maintain 
protection  by  designating 
as a RBSP where needed. 

is 

Continued 
monitoring 
could 
be 
expected 
to  utilise 
finite 
economic 
resources 
with  more 
limited 
benefit. 

Deselection 
could 
free 
up  resources 
that could be 
reallocated 
to 
monitoring 
and 
controlling 
emerging 
risks. 
Cost  savings 
€3.8  -  €11.7 
million  Euro 
year 
per 
(monitoring 
of 
5 
substances). 

While the health hazards 
of  alachlor  are  clearly 
documented, 
of 
exposure is very low and 
would  not  be  expected 
to increase. 

risk 

While the health hazards 
of  simazine  are  clearly 
of 
documented, 
exposure is very low and 
would  not  be  expected 
to increase. 

risk 

While the health hazards 
of  chlorfenvinphos  are 
clearly documented, risk 
of  exposure  is  very  low 
and  would 
be 
expected to increase. 

not 

to 

Less  monitoring  would 
reduce  the  information 
available 
assess 
exposure  and  decide  on 
measures 
reduce 
but  MS 
emissions, 
should  assess  whether 
these  substances  should 
be 
and 
designated 
managed as RBSPs. 

to 

Overall 
balance 
costs 
benefits 

of 
and 

Deselection 
would  have 
more benefits 
than costs. 

Deselection 
would  have 
more benefits 
than costs. 

Deselection 
would  have 
more benefits 
than costs. 

Deselection 
would  have 
costs 
more 
than benefits. 

Deselection 
would  have 
more benefits 
than costs. 

2.  Groundwater options 

Tables A9.7 to A9.9 below summarise the impacts of implementing the groundwater policy 
options, compared to  the status  quo. The options presented  are mutually  exclusive for each 
substance group under consideration. More detailed economic costs of potential measures are 

204 

 
 
 
 
 
included  in  Annex  10. A  note  on  the  impacts  of  options  not  analysed  in  the  main  report  is 
included below. 

Note on impacts of groundwater options not analysed in the main report 

As shown in Annex 7 Table A7.3, three groundwater options were not discussed in the main 
report in order to simplify the presentation and better reflect the key policy choices available. 
These options were: 

  a group of 10 PFAS included in Annex I and assigned a GW QS of 0.1 µg/l; 
  group of 16 nrMs added to Annex I as individual substances with a GW QS of 1 µg/l; 
  group  of  16  nrMs  added  to  Annex  I  as  individual  substances  with  a  GW  QS  of  0.1 

µg/l. 

For transparency, and to report all analysis done, the impacts of these options are included in 
the tables below and some explanatory text is also provided here. 

PFAS 

Costs for a group of 10 PFAS included in Annex I and assigned a GW QS of 0.1 µg/l will be 
lowest, given the DWD requirements and additional data collated. This is especially the case 
for  the  MS  which  are  already  monitoring  PFAS  and  carrying  out  risk  assessments  for 
groundwater.  

Pathway  disruption  measures  like  the  capture  of  contaminated  sludge,  containing  and 
incineration are very costly due the energy intensiveness, so these measures are suitable only 
in  extreme  circumstances.  Guidance  on  the  best  practise  use  of  waste  and  wastewater  by-
products  in  agriculture  would  be  a  cheaper  option.  However,  this  will  ultimately  result  in 
PFAS accumulating in agricultural soils. Instead of using pathway disruption measures, it is 
more likely that for a group of 10 PFAS included in Annex I and assigned a GW QS of 0.1 
µg/l actions to restrict use of PFAS and better management of waste streams are used, as well 
as groundwater or soil remediation. 

nrMs 

The  costs  of  adding  nrMs  to  the  monitoring  networks  are  likely  to  be  limited,  since  the 
existing  framework  for  assessing  risk  to  groundwater  from  ‘parent’  pesticides  and  their 
relevant metabolites are already in place. This is particularly the case for adding a group of 
16 nrMs to Annex I with a GW QS of 1 µg/l and adding a group of 16 nrMs to Annex I with 
a GW QS of 0.1 µg/l.  

The implementation of the EU Farm to Fork Strategy will likely lead to reductions in the use 
of  any  permitted  parent  pesticides  of  the  nrMs  considered.  This  will  be  delivered  in  part 
through  the  planned  revision  of  the  Directive  on  the  Sustainable  Use  of  Pesticides  and 
national  action  plans  for  pesticide  use  reduction.  This  will  limit  what  additional  measures 
need to be taken to protect their water bodies. By including all nrMs in  Annex I under, the 
administrative  burden  may  be  progressively  reduced  further  as  the  legislation  would  be 
“future proofed”. 

Environmental  benefits  are  rather  similar  for  the  5  assessed  options  for  nrMs  but  options 
covering all nrMs and setting a GW QS at EU level are expected to generate greater benefits. 

205 

 
 
 
 
 
2.1.  Option 1: Add LFR substances to GWD Annex I individually, and assign an individual 

EU-wide GW QS 

Prefe
rred 
optio
n? 

No  – 
prote
cts 
again
st 
curre
nt 
know
n 
PFAS 
but 
not 
future 
pollut
ion. 

Table A9.7: Groundwater Option 1 – summary of impacts and preferred option 

Description 

Administrati
ve burden 

Economic Impacts 

Environmental Impacts 

Societal Impacts 

Costs 

Benefits  Costs 

Benefits 

Costs 

Benefits 

to 

to 

Reduced  energy 
use 
for 
wastewater 
treatment 
tackle PFAS. 
Increased 
knowledge 
and 
understanding  of 
the risks of PFAS 
the 
posed 
water 
environment. 
Consistent 
approach  to  data 
collection  at  EU 
level 
and 
improved 
knowledge (more 
data 
collected) 
on  the  impact  of 
PFAS. 
Reduced 
pollution 
groundwater. 
Lower 
(irreversible) 
damage 
to 
natural  resources 
as 
such 
groundwater  and 
connected 
surface  waters 
and  ecosystems 
reduced 
(i.e. 
impact 
on 
sensitive  water 
bodies  such  as 
wetlands 
and 
rivers, and fish). 

risk  of 

of 

Loss 
of 
organi
c 
materi
als 
to 
spread 
to  land 
by 
farmin
g 
comm
unity. 

healthy 

Avoided  illness  / 
through 
death 
exposure 
lower 
to  PFAS 
via 
drinking  water  / 
food. In the EEA 
countries,  health-
related 
costs 
could  reduce  by 
to  €52-84 
up 
billion  per  year 
on 
(based 
population 
of 
207.8 million). 
A 
ecosystem 
(fishing, 
swimming, etc.). 
Sectors  requiring 
a  high  quality  of 
groundwater 
such  as  bottled 
water 
or 
aquaculture. 
raw 
Clean 
for 
groundwater 
abstraction 
(for 
drinking  water, 
irrigation, 
livestock 
watering). 
Avoided  costs  of 
(pre)treatment  as 
a 
of 
result 
improved  quality 
for  potable  water 
process 
and 
for 
water 
agriculture 
and 
industry. 
Increased 
knowledge 
and 
understanding  of 
the risks of PFAS 
posed 
the 
water 
environment. 

to 

PFAS  (Group 
10) 
of 
in 
included 
Annex  I  and 
assigned 
a 
GWQS of 0.10 
µg/l  (based  on 
drinking 
the 
water  standard 
for 
20 
identified 
PFAS – the 10 
PFAS  would 
be  a  subset  of 
the 20) 

Costs  -  €15-
16  million 
(Europe) 
Benefits from 
the 
DWD 
implementati
on 

(to 

Cost 
of 
remediation  of 
legacy 
pollution 
taxpayer 
where  polluter 
pays  principle 
be 
cannot 
enforced). 
From 
landfill 
sites this could 
amount to €0.7 
on 
million 
and 
average, 
€77 
up 
to 
million 
per 
site. 
Environmental 
PFAS 
remediation 
totalling  €821 
million 
to 
billion 
€170 
(EEA/EU), 
with  plausible 
best  estimate 
€10–20 
of 
billion. 
Cost  of  high 
temperature 
incineration  of 
- 
biosolids 
€5000-7500 
million/yr  (EU 
level). 
Cost of landfill 
€2000 
- 
million/yr  (EU 
level). 
Restriction  of 
€390 
use: 
per 
million 
year 
per 
substitute use. 

to 

Reduce
d energy 
costs 
and 
related 
process 
costs for 
wastewa
ter 
treatme
nt 
tackle 
PFAS. 
Avoided 
costs  of 
(pre)trea
tment  as 
a  result 
of 
improve
d 
quality 
for 
potable 
water 
and 
process 
water 
for 
drinking 
water 
supply, 
agricult
ure 
(irrigati
on, 
livestoc
k 
waterin
g 
taken 
directly 
from  a 
GWB) 
and 
industry 
(GAC 
treatme

Energy 
intensive 
measures 
including 
high 
temperat
ure 
incinerati
on 
of 
biosolids 
and  other 
PFAS 
containin
g  waste 
materials. 
Loss 
of 
organic 
materials 
to  spread 
to 
land 
by 
farming 
communi
ty. 

206 

 
Description 

Administrati
ve burden 

Economic Impacts 

Environmental Impacts 

Societal Impacts 

Costs 

Benefits  Costs 

Benefits 

Costs 

Benefits 

Prefe
rred 
optio
n? 

Yes  – 
future 
proof
ed 
/ 
huma
n 
healt
h 
focus 

above  but 

As 
improved 
targeting on more 
potent PFAS. 

PFAS  (Group 
24 
of 
proposed  as 
to 
additions 
the 
surface 
water 
Priority 
Substance 
list) 
included 
in Annex I and 
assigned a GW 
QS  of  4.4  ng/l 
PFOA-
equivalent. 
If 
no  RPF  exists, 
then  the  RPF 
PFOA 
of 
should 
be 
assumed  and  a 
GW QS of 4.4 
ng/l applied. 

€45-48 
million 
Highest 
burden due to 
need  to  use 
RPFs 
Benefits from 
the 
DWD 
implementati
on 

Carbamazepi
ne 
and 
Sulfamethoxa
zole  added  to 
Annex  I  and 
assigned  GW 
QS  of  0.5  and 
0.1 
µg/l 
respectively. 

of 
Costs 
monitoring  - 
€2  million 
(no 
significant 
additional 
administrativ
e  costs 
for 
risk  /  status 
assessments) 

nt  costs 
millions 
of  €  per 
site). 

costs 

Generally 
smaller 
than 
under Option 2 
the 
to 
due 
focus  on  two 
substances. 
Product 
substitution 
for 
viable 
Sulfathemoxaz
but 
ole 
unlikely 
for 
Carbamazepin
- 
e 
associated 
with 
substitution  of 
pharmaceutica
and 
ls 
availability  of 
alternatives. 
Green 
Pharmacy 
initiatives  in  a 
small  number 
of MS (<€1-10 
million 
per 
MS). 
Treatment  of 
biosolids 
/ 
manures 
unlikely  to  be 
used 
(disproportion
ately 
expensive). 

More 
data 
collecte
d 
to 
understa
nd 
the 
impact 
of  these 
two 
pharmac
euticals 
Consiste
nt 
approac
h to data 
collectio
n  at  EU 
level. 
Reduce
d 
pollutio
n 
ground
water 

of 

of 

Impacts 
from 
substituti
on 
other 
pharmace
uticals 
with 
increased 
productio
n 

for 

As 
pharmaceuticals 
under  Option  2, 
but  with  much 
reduced  scale  as 
only  addressing 
two pollutants. 

Restric
ting 
use 
could 
impact 
on 
health 
and 
well-
being 
of 
people 
and 
animal
s 
where 
alterna
tives 
have 
side 
effects 
/ 
differe
nt 
efficac
y 

in 
Reduction 
AMR likely to be 
(mainly 
small 
covered 
by 
baseline 
measures) 
Small  increase  in 
well-being  from 
reduced  risk  of 
chronic  ingestion 
in  drinking  water 
/ 
improved 
ecosystem health. 
Positive 
impact 
on  shellfish  and 
fisheries  where 
groundwater 
inputs 
to  rivers 
and  estuaries  is 
significant 

Yes 

207 

 
Description 

Administrati
ve burden 

Economic Impacts 

Environmental Impacts 

Societal Impacts 

Costs 

Benefits  Costs 

Benefits 

Costs 

Benefits 

Prefe
rred 
optio
n? 

to 

of 

Costs 
pesticide 
sector  through 
loss 
of 
approved 
substances, 
costs 
product 
development 
and 
product 
substitution  to 
farming 
the 
sector. 
Substitute 
pesticides  are 
available  and 
can be cheaper 
(up to 3 times) 
or  up  to  100 
more 
times 
costly 
than 
permitted 
parent 
pesticides. 
Cost  of  legacy 
pollution  from 
landfill  sites  – 
average 
of 
€0.7 up to €77 
million 
per 
site. 
Increased  data 
requirements 
could  make 
gaining 
authorisation 
of 
new 
products  more 
challenging. 

from 

not 
by 
and 

Reduced  risk  of 
to 
damage 
natural  resources 
such 
as 
groundwater  and 
connected 
ecosystems. 
Increased 
ecosystems 
services 
groundwater 
biota 
impacted 
nrMs 
cocktail effects. 
Consistent 
approach  to  data 
collection  at  EU 
level 
and 
improved 
knowledge (more 
collected) 
data 
on 
in 
nrMs 
groundwater 
leading  to  better 
understanding  of 
risks. 
Increased 
knowledge 
and 
understanding  of 
of 
the 
risks 
metabolites 
of 
pesticides  posed 
to 
the  water 
environment. 
Improved 
and 
knowledge 
for 
better  data 
during 
use 
pesticide  parent 
authorisation 
process.  
Climate  change 
through 
benefits 
reduced 
energy 
use  (e.g.  due  to 
to 
changes 
wastewater 
and 
drinking  water 
treatment 
processes) (in the 
case  of  source 
control 
and 
pathway 
disruption 
measures). 

Using 
substitute
s 
that 
an 
have 
impact on 
other 
environm
ental 
compart
ments. 
Un-
intention
al 
impacts 
for 
example 
glyphosat
e  is  used 
to destroy 
cover 
crops, 
which are 
to 
used 
mitigate 
nutrients 
in  run-off 
/ leaching 
from 
agricultur
al 
fields 
over 
winter. 

Increase
d 
availabil
of 
ity 
clean 
raw 
ground
water 
for 
abstracti
on 
(for 
drinking 
water, 
irrigatio
n, 
livestoc
k 
waterin
g). 
Avoided 
costs  of 
(pre)trea
tment  as 
a  result 
of 
improve
d 
quality 
for 
potable 
water 
and 
process 
water 
for 
agricult
ure  and 
industry
. 
Better 
data  for 
use 
during 
pesticid
e  parent 
authoris
ation 
process. 

Potenti
al 
for 
margin
al  cost 
increas
es 
in 
food 
produc
tion 
due  to 
more 
limited 
choice 
in 
pestici
des. 

healthy 

A 
ecosystem 
(fishing, 
swimming, etc.) 
Benefits 
to 
sectors  requiring 
a  high  quality  of 
groundwater 
such  as  bottled 
water 
or 
aquaculture. 
raw 
Clean 
for 
groundwater 
abstraction 
(for 
drinking  water, 
irrigation, 
livestock 
watering). 
Avoided  costs  of 
(pre)treatment  as 
a 
of 
result 
improved  quality 
for  potable  water 
process 
and 
for 
water 
and 
agriculture 
industry. 
Increased 
knowledge 
and 
understanding  of 
of 
risks 
the 
metabolites 
of 
pesticides  posed 
to 
the  water 
environment. 

nrMs  (Group 
of  16)  added 
to  Annex  I  as 
individual 
substances 
with a GW QS 
of 1 µg/l. 

of 

€4-5 million 
Costs 
monitoring 
(no 
significant 
additional 
administrativ
e  costs 
for 
risk  /  status 
assessments) 

nrMs  (Group 
of  16)  added 
to  Annex  I  as 
individual 
substances 

As  above  but 
more stringent. 

As  above 
but  more 
stringent. 

As  above  plus 
impacts 
reduced 
on  groundwater 
biota. 

As 
above 
but 
more 
stringe

208 

No 

No 

 
Description 

Administrati
ve burden 

Economic Impacts 

Environmental Impacts 

Societal Impacts 

Costs 

Benefits  Costs 

Benefits 

Costs 

Benefits 

with a GW QS 
of 0.1 µg/l. 

nrMs 
to 
I  as 

All 
added 
Annex 
individual 
substances 
with a GW QS 
of 0.1 µg/l. 

As  above  but 
with 
future 
proofing. 

nt. 

Prefe
rred 
optio
n? 

Yes 

2.2. Option 2: Add LFR substances to GWD Annex I as groups, and assign an EU-wide GW 

QS for the group “total” or “sum of”. 

Prefe
rred 
optio
n? 

/ 

No  – 
GW 
QS 
not 
suffic
iently 
preca
ution
ary 
prote
ctive, 
altho
ugh  it 
future 
proof
s 
legisl
ation. 

Table A9.8: Groundwater Option 2 – summary of impacts and preferred option 

Descripti
on 

Admin
istrativ
e 
burden 

Economic Impacts 

Environmental Impacts 

Societal Impacts 

Costs  

Benefits 

Costs 

Benefits 

Costs 

Benefits 

All  PFAS 
added  as 
to 
group 
I 
Annex 
with 
a 
GWQS 
for 
“PFAS 
total”  of 
0.5  µg/l 
(again 
following 
the 
drinking 
water 
standard 
for  PFAS 
total). 

€45-48 
million 
Benefit
s  from 
the 
DWD 
implem
entatio
n. 

of 
Cost 
remediation 
of 
legacy  pollution 
taxpayer 
(to 
polluter 
where 
principle 
pays 
cannot 
be 
enforced). 
Cost 
of 
temperature 
incineration 
of 
biosolids  €5000-
7500  million/yr 
(EU level). 
Cost  of  landfill 
€2000  million/yr 
(EU level). 

high 

of 

for 

Reduced 
energy costs 
and  related 
process 
costs 
wastewater 
treatment  to 
tackle 
PFAS. 
Avoided 
cost 
drinking 
water 
treatment. 
More  data 
collected  to 
understand 
the 
impact 
of these two 
PFAS. 
Consistent 
approach  to 
data 
collection  at 
EU level. 
Reduced 
pollution  of 
groundwate
r. 

Energy 
intensiv
e 
measure
s 
includin
g  high 
tempera
ture 
incinera
tion  of 
biosolid
s 
and 
other 
PFAS 
containi
ng 
waste 
material
s. 
Loss  of 
organic 
material
to 
s 
spread 
to 
by 
farming 
commu
nity. 

land 

of 

Avoided  costs  of 
availability  of  clean 
raw 
groundwater 
for abstraction. 
Lower  production 
and  maintenance 
through 
costs 
availability 
of 
cleaner  raw  potable 
groundwater. 
risk 
Lower 
(irreversible) 
damage  to  natural 
resources  such  as 
groundwater 
and 
surface 
connected 
and 
waters 
ecosystems 
(i.e. 
reduced  impact  on 
water 
sensitive 
bodies 
as 
wetlands and rivers, 
and fish). 
(avoided 
Benefit 
associated 
costs) 
with  availability  of 
raw 
clean 
for 
groundwater 
abstraction 
(for 
irrigation,  livestock 
taken 
watering 
directly 
a 
GWB). 

from 

such 

Loss  of 
organic 
material
to 
s 
spread 
to 
by 
farming 
commu
nity. 

land 

healthy 

raw 
for 
(for 
water, 

A 
ecosystem 
(fishing, 
swimming, etc). 
Sectors requiring a 
high  quality  of 
groundwater  such 
as bottled water or 
aquaculture 
Clean 
groundwater 
abstraction 
drinking 
irrigation, 
livestock 
watering) 
Avoided  costs  of 
(pre)treatment as a 
result  of  improved 
quality  for  potable 
water  and  process 
for 
water 
agriculture 
and 
industry 
Increased 
knowledge 
and 
understanding  of 
the  risks  of  PFAS 
posed  to  the  water 
environment. 

209 

 
 
Descripti
on 

Admin
istrativ
e 
burden 

Economic Impacts 

Environmental Impacts 

Societal Impacts 

Costs  

Benefits 

Costs 

Benefits 

Costs 

Benefits 

Product 
substitution  /  ban 
in  animals 
use 
for 
(viable 
Sulfathemoxazol
e but unlikely for 
Carbamazepine  - 
€140,000 
average  cost  of 
alternative 
to 
carbamazepine in 
animals). 
Returns  program 
Green 
/ 
Pharmacy 
initiatives 
– 
focused  on  two 
pharmaceuticals 
(less  than  €1-€10 
million per MS) 
Capture 
of 
biosolids  –  EU 
level  €2  to  7500 
billion  to  landfill 
or incinerate 
and 
Capture 
treatment 
of 
animal  manures 
– EU level 
Treatment 
wastewater 
(baseline 
measure  –  no 
cost). 

of 

Restrictions 
on 
use  of  parent 
pesticides  across 
specific  sensitive 
GWBs  /  drinking 
water  protected 
not 
areas 
(if 
may 
statutory 
require 
compensation  for 
lost crop yield). 

All 
pharmac
euticals 
added  as 
a group to 
Annex 
I 
and 
assigned a 
GW  QS 
of 
0.5 
µg/l. 

Costs 
of 
monitor
ing 
plus 
additio
n 
adminis
trative 
costs 
€5.5 
million 
to  €11 
million. 

All  nrMs 
to 
added 
Annex 
I 
as a group 
and 
assigned a 
group 
GW  QS 
of 
10 
µg/l. 

€4-5 
million 
Costs 
of 
monitor
ing  (no 
signific
ant 
additio
nal 
adminis
trative 
costs 
for  risk 
/  status 
assess
ments). 

to 

More  data 
collected for 
pharmaceuti
cals 
in 
groundwate
leads 
r 
better 
understandi
ng of risks. 
Consistent 
approach  to 
data 
collection  at 
EU level. 
Future 
proofed 
legislation 
leads 
to 
reduction  in 
pharmaceuti
cals 
in 
groundwate
r 
informs 
industry 
permitting 
of 
new 
substances. 

and 

/ 

Energy 
use 
to 
capture, 
store 
and 
destroy 
biosolid
s 
and 
animal 
manures 
to 
prevent 
leaching 
to 
ground
water. 

Reduced  pollution 
of  groundwater  and 
aquatic 
connected 
ecosystems 
with 
reduced  impact  on 
sensitive habitats. 
energy, 
Reduced 
carbon 
emissions 
and  chemicals  use 
associated 
with 
treatment 
reduced 
of  drinking  water 
(in 
the  case  of 
source  control  and 
pathway  disruption 
measures). 
Increase  reuse  and 
recovery 
of 
pharmaceutical-free 
materials  (e.g.  use 
treated 
of  sludge, 
wastewater). 
Increased 
knowledge 
understanding 
environmental 
behaviours 
pharmaceuticals. 
Reduction  in  AMR 
likely  to  be  small 
(mainly  covered  by 
baseline  measures) 
-  Reduction 
in 
through 
AMR 
anti-
of 
control 
biotic  use 
(costs 
avoided  of  €1.5 
billion to the EU). 

and 
of 

of 

Unlikely  to 
lead  to  loss 
of 
parent 
pesticides. 

Using 
substitut
es 
that 
have  an 
impact 
on  other 
environ
mental 
compart
ments. 

More data  collected 
in 
for 
nrMs 
groundwater 
leads 
better 
to 
understanding 
of 
risks. 
Consistent approach 
to data collection at 
EU level. 
Better  data  for  use 
during 
pesticide 
parent  authorisation 
process. 
Future  proof 
other 
nrMs. 

for 
(unlisted) 

the 

Restricti
ng  use 
could 
impact 
on 
health 
and 
well-
being  of 
animals 
where 
alternati
ves have 
side 
effects  / 
different 
efficacy. 
Capture 
of 
biosolid
s 
/ 
incinera
tion  of 
manures 
has 
impact 
on 
farming 
sector 
with 
loss  of 
low  cost 
soil 
improve
r 
/ 
fertiliser
. 

Potentia
l 
for 
cost 
increase
s  due  to 
lower 
crop 
yields. 

Prefe
rred 
optio
n? 

No 

of 

in 
Reduction 
through 
AMR 
of 
control 
Sulfamethoxazole 
in 
is 
small 
comparison 
to 
baseline  measure 
restricting 
of 
prophylactic use in 
animals. 
Increased 
knowledge 
and 
understanding  of 
environmental 
behaviours 
pharmaceuticals 
Small  increase  in 
from 
well-being 
risk  of 
reduced 
chronic 
ingestion 
in drinking water / 
improved 
ecosystem health. 
Benefits 
from 
impact on shellfish 
and 
fisheries 
where 
groundwater 
inputs 
and 
estuaries 
significant. 

rivers 
coastal 
is 

to 

As for nrMs under 
Option  1  but  in 
restricted 
areas 
only. 

No 

2.3.  Option 3: Add LFR substances to GWD Annex II for MS to consider setting a TV for 

specific substances posing a risk to groundwater bodies. 

210 

 
Table A9.9: Groundwater Option 3 – summary of impacts and preferred option 

Economic Impacts 

Environmental Impacts 

Societal Impacts 

Costs 

Benefits 

Costs 

Benefit
s 

Option 

Administra
tive burden 

All 
PFAS 
added  as  a 
group 
to 
Annex  II  for 
to 
MS 
consider  for 
the 
development 
of  a  TV  for 
specific 
substances 
posing  a  risk 
to GWBs. 

All 
pharmaceuti
cals added as 
to 
a  group 
Annex  II  - 
guideline 
to 
include 
carbamazepi
ne, 
sulfamethoxa
zole 
and 
primidone. 

nrMs 
All 
to 
added 
Annex  II  for 
MS 
to 
consider  for 
the 
development 
of  a  TV  for 
substances 
that  pose  a 
risk  to  their 
GWBs. 

than 
Less 
all 
other 
options  for 
PFAS. 
Benefits 
from 
DWD 
implementa
tion. 

the 

Costs 
negligible 
and 
absorbed 
into 
baseline.  If 
all 
MS 
added 
Primidone 
via  Annex 
the 
II, 
additional 
costs  would 
be  half  of 
Option 1 for 
pharmaceuti
cals. 

Costs 
negligible 
and 
absorbed 
into 
baseline. 
Dependant 
on 
identified 
from  nrMs 
by 
each 
MS. 

risks 

Benefit
s 

for 

As 
PFAS 
under 
Option 
but 
1, 
reduced 
consiste
ncy 
/ 
less 
data 
collecti
on. 

Unkno
wn 
– 
likely  to 
be 
much 
smaller 
scale 
than  for 
pharma
ceutical
s  under 
Options 
1 and 2. 

Costs 

As  for  PFAS 
under  Option 
fewer 
1  but 
sites 
to 
remediate. 

/ 

– 
on 

Returns 
program 
Green 
Pharmacy 
initiatives 
focused 
two 
pharmaceutica
ls  (less 
than 
€1-10  million 
per MS) 
Treatment  of 
wastewater 
(baseline 
measure  –  no 
cost). 

Inconsistent 
approach 
between MS. 
Does 
influence 
pesticide 
approval 
process. 

not 

(but 

More 
data 
collecte
d 
less 
than  for 
Annex  I 
listing). 

for 

As 
PFAS 
under 
Option  1, 
but 
reduced 
extent. 

for 
As 
pharmace
uticals 
under 
Option  2 
but  scale 
depends 
on  how 
far  MS 
impleme
nt 
monitori
ng 
and 
measures
. 

Few 
additiona
costs 
l 
(uncertai
n)  as  the 
extent  of 
these 
impacts 
will 
depend 
on 
TV 
adopted 
per MS. 

the 

Preferr
ed 
option? 

No  -  too 
variable 
and  will 
not 
address 
pollutio
n 
of 
groundw
ater 
at 
the  EU-
wide 
level. 

Yes, 
only  for 
Primido
ne 

As  for  PFAS  under 
Option 1. 

for 

As 
PFAS 
under 
Option  1, 
but 
reduced 
extent. 

for 

As 
PFAS 
under 
Option 
1. 

risks 

to 
Specific 
are 
groundwater 
and 
investigated 
locally 
dealt  with 
rather  than  through 
EU  wide  schemes 
which  may  be  too 
high 
to  be 
level 
effective.  
Monitoring 
data 
collected  for  at  risk 
pharmaceuticals with 
a tailored approach.  

As 
for 
pharmaceu
ticals 
under 
Option  2 
but 
scale 
depends 
on how far 
MS 
implement 
monitorin
g 
and 
measures. 

for 

but 

As 
pharma
ceutical
s  under 
Option 
2 
scale 
depends 
on  how 
far  MS 
implem
ent 
monitor
ing  and 
measure
s. 

The  extent  of  these 
impacts  will  depend 
on the TV adopted.  
Could 
improve 
efficiency  -  specific 
risks  to  groundwater 
are  investigated  and 
locally 
dealt  with 
rather  than  through 
EU  wide  schemes 
which  may  be  too 
to  be 
level 
high 
effective. 

Few 
additional 
costs 
(uncertain)
. 

Limited 
program
me 
of 
measure
s 
required
. 

No 

211 

 
 
3.  Monitoring, reporting and administrative streamlining policy options 

Table A9.11 below depicts the additional impacts of implementing the monitoring, reporting 
and  administrative  streamlining  options,  compared  to  the  status  quo.  The  options  presented 
are  not  mutually  exclusive,  and  can  co-exist.  As  illustrated  in  the  main  text,  the  proposed 
policy  options  have  significantly  different  economic,  environmental  and  social  impacts.  An 
overall  assessment  of  the  impacts  is  summarised  below,  whereby  the  options  were 
categorised  as  having  (overall):  no  impact;  positive  impacts;  negative  impacts;  or  neutral 
impacts.  

Sub-options under Policy Option 1 include the drafting of (additional) guidance documents. 
For the economic impacts of these sub-options, the primary cost will be the development of 
the guidance document itself. To estimate the costs of developing a guidance document, it is 
important  to  note that these are largely dependent  on the scope of the guidance, its breadth 
and the process followed. Extensive guidance documents that involve a lot of technical input 
(e.g.  Best  Available  Technique  Reference  Documents  under  the  Industrial  Emissions 
Directive) are an example of costly guidance documents that take years to develop. Within a 
process like the WFD Common Implementation Strategy guidance, such documents are not 
envisaged.  The  primary  difference  between  the  two  cost  estimates  stems  from  the  effort 
required  in  establishing  the  guidance  document.  One-off  estimates  of  costs  for  the 
development  of  several  types  of  guidance  documents  are  presented  in  Table  A9.10  below. 
Under  the  WFD  CIS,  only  simple  to  more  elaborate  technical  guidance  documents  are 
drafted, thus not exceeding €500,000 per document. 

Table A9.10: Categories for estimating cost of guidance documents  

Type of guidance 

Range of cost per guidance (€) 

Simple  

Elaborate 

Extensive 

Up to €290,000 

€290,000 – €500,000 

€5 million – €10 million 

212 

 
 
 
 
 
 
Table A9.11: Monitoring, reporting and administrative streamlining policy options – summary of impacts 

Option description 

Impacts 

impact 

Environmental 

Economic 

impact 

Social impact 

Overall  balance  of 
costs and benefits 

Option 1 – Provide / improve guidance and advice on monitoring 

Develop 
applying 
in 
procedures, 

1a: 
on 

Option 
guidelines 
innovative  methods 
monitoring 
including 
continuous/automated 
monitoring techniques. 

Option  1b:  Follow  -up  to 
improve  existing  guidelines 
on EBMS in view of setting 
application  ‘trigger  values’ 
improve 
in  practice 
of 
monitoring 
groups/mixtures 
of 
pollutants  by  using  EBMs, 
and trigger values. 

to 

a 
Option  1c:  Develop 
harmonised  measurement 
and 
monitoring 
methodology  and  guidance 
for  microplastics,  as  a  basis 
for mandatory MS reporting 
on  microplastics  and  a 
future 
under 
listing 
EQSD/GWD. 

Neutral  impact:  depending 
on the measures that will be 
described in the document. 

Limited 
cost 
(≤€500,000) to develop 
the guidance document. 
to  MS 
Other  costs 
depend  on  uptake  of 
measures. 

Guideline impacts would be 
neutral,  and  dependent  on 
uptake of measures. 

Limited 
cost 
(≤€500,000) to develop 
the guidance document. 

to 

have 
social 
depending 
of 

uptake 

Likely 
positive 
impacts 
on 
measures. 

to 

have 
social 
depending 
of 

uptake 

Likely 
positive 
impacts 
on 
measures. 

Positive impact in the longer 
run, allowing for monitoring 
regulating 
and  ultimately 
in 
microplastics 
water. 

levels 

Limited 
cost 
(≤€500,000) to develop 
the guidance document. 

longer  run, 
the 
In 
health 
positive 
impacts 
from 
preventing  exposure 
to  microplastics,  as 
well  as  reduction  of 
costs 
water 
of 
treatment 
downstream. 

Option 
guidelines 
frequency 
RBSPs. 

1d: 
on 
for  PS 

Develop 
sampling 
and 

Neutral  impact:  depending 
on the measures that will be 
described in the document. 

cost 
Limited 
(≤€500,000) to develop 
the guidance document. 
Other  costs 
to  MS 
depend  on  uptake  of 
measures. 

1e:  Provide 

Option 
a 
repository  for  sharing  best-
practices from MS regarding 
monitoring 
available 
foster 
techniques, 
cooperation 
implement 
these. 

and 

to 

Possible  positive 
impacts, 
but  depending  on  uptake  of 
knowledge 
and 
implemented actions. 

Minimal 
economic 
costs,  with  significant 
benefits  to  knowledge 
sharing and innovation. 

to 

have 
social 
depending 
of 

uptake 

Likely 
positive 
impacts 
on 
measures. 

to 

Likely 
positive 
impacts 
more 
monitoring. 

have 
social 
through 
accurate 

Depending 
on 
uptake of measures. 

Benefits 
outweigh costs 

clearly 

Depending 
on 
uptake of measures. 

Benefits 
outweigh 
initial  costs  due  to 
knowledge 
sharing 
and development. 

Option 2 – Establish / amend obligatory monitoring practices 

Option  2a: 
Include  an 
obligation  in  the  EQSD  to 
use  EBMs 
to  monitor 
estrogens. 

Provision  on  monitoring 
estrogens  will  have  positive 
impacts. 

Option  2b:  Establish  an 
obligatory 
groundwater 
watch 
list  mechanism 
analogous  to  that  of  surface 
waters  and  drinking  water, 
and  provide  guidance  as 
necessary on the monitoring 
of the listed substances. 

impacts  due 

to 
Positive 
decision-making 
better 
regarding 
processes 
substances  posing  risks  and 
better comparability of data. 

Monitoring 
of 
estrogen  will  have 
positive  impacts  by 
allowing 
better 
targeting  of  policy 
measures. 

Costs  of  monitoring 
are 
estrogens 
outweighed 
by 
significant benefits. 

Neutral impacts  

through 
Benefits 
data 
enhanced 
and 
comparability 
cohesion  out-weigh 
costs of monitoring. 

due 

Costs 
to 
monitoring  of  estrogen 
are  low,  but  possible 
measures  to  be  taken 
to  monitoring 
due 
results 
be 
substantial. 

may 

cost 

for 
Additional 
monitoring 
and 
reporting,  balanced  by 
of  more 
benefits 
and 
comparable 
coherent 
to 
efficient 
implement 
measures 
improve 
groundwater status. 

data 

to 

213 

 
 
Option description 

Impacts 

impact 

Environmental 

Economic 

impact 

Social impact 

Option  2c:  Improve 
the 
monitoring and review cycle 
of  the  surface  water  watch 
list  so  that  there  is  more 
time  to  process  the  data 
before revising the list. 

they 
impacts  as 
Neutral 
the 
actions 
depend  on 
implemented 
(i.e.  which 
substances added to Priority 
Substance list), but expected 
to be positive 

Neutral  impacts  due  to 
administrative  costs  for 
additional  and  more 
frequent  monitoring, 
by 
compensated 
decrease  in  frequency 
of updating the list 

Neutral impacts  

Option 3 – Harmonise reporting and classification 

Overall  balance  of 
costs and benefits 

Significant 
environmental 
benefits and reduced 
burden 
reporting 
likely 
to  outweigh 
the  possible  costs  of 
monitoring 
frequency-  yet  this 
is  dependent  on  the 
measures 
implemented 
following  enhanced 
monitoring 
procedures. 

Option  3a:  Establish  an 
automated  data  delivery 
mechanism  for  the  EQSD 
and the WFD to ensure easy 
access  at  short  intervals  to 
to 
monitoring/status  data 
streamline 
reduce 
associated  with 
efforts 
current  reporting,  and 
to 
raw 
access 
allow 
monitoring data. 

and 

to 

Option  3b: 
Introduce  a 
reference  list  (repository  of 
for 
standards)  of  EQS 
RBSPs  as  an  annex  to  the 
EQSD and modify Annex V 
of  WFD 
section  1.2.6 
(Procedure for the setting of 
chemical  quality  standards 
by  MS)  accordingly,  and 
incorporate  RBSPs  into  the 
assessment 
chemical 
of 
status for surface waters.  

impacts 

Positive 
by 
improving  accessibility  of 
spatial/temporal  knowledge 
for more effective actions. 

Positive 
through 
impact 
harmonization  of  EU-wide 
standards  allowing  more 
effective measures  

Option 4 – Legislative and administrative aspects 

Option 4a: Use an annex in 
the  EQSD  instead  of  Annex 
X  to  the  WFD  to  define  the 
list  of  PS,  and  update  the 
lists  of  SW  and  GW 
substances  by  Comitology 
or delegated acts. 

the 
Option  4b:  Change 
status  of  the  ‘eight  other 
to 
pollutants’  added 
the 
former 
EQSD 
the 
Dangerous 
Substances 
Directive  (76/464/EEC)  to 
that of PS/PHS. 

from 

Pesticides:  Aldrin,  Dieldrin, 
Endrin, Isodrin, DDT (all to 

impact  due 

Positive 
to 
quicker  actions  to  address 
new substances. 

to 

Dieldrin 

The  cyclodiene  pesticides 
are 
Aldrin, 
be 
suspected 
Carcinogenic 
and 
recognised  as  POP.  Endrin 
is  recognised  as  POP  and 
toxic 
nervous 
system. Isodrin is very toxic 
to  aquatic  life  with  long 
lasting effects. For DDT, the 

the 

for 

Initial  cost  for  aligning 
data  and  establishing 
harvesting 
but 
mechanisms, 
outweighed  by  benefits 
of  data-sharing 
and 
long-term  cost  savings 
for reduced reporting. 

Negative  impact  due  to 
agreeing  on  RBSPs 
EQSs  likely  leading  to 
substantial  costs 
for 
MS  for  implementation 
of monitoring and costs 
for  economic  actors 
taking  measures  where 
necessary   

by 

Neutral  impact  due  to 
cost  of  measures  to  be 
economic 
taken 
actors  and  minor  costs 
associated  to  delegated 
acts,  but  balanced  by 
innovation 
stimulating 
and 
possible 
improvement  in  market 
competitiveness. 

additional 
Minor 
compliance 
costs 
(extremely  low  current 
exceedances). 

214 

Positive  impacts  due 
to  accessibility  of 
information. 

Significant 
term 
outweighing 
costs. 

long-
benefits 
initial 

Positive  impacts  for 
social well-being and 
providing 
health, 
equal 
standard  of 
water resource across 
EU 

Significant 
and 
environmental 
benefits 
social 
the 
outweigh 
costs 
possible 
incurred  by  MS  and 
economic actors. 

Positive  impacts  as 
innovation 
and 
research  will  lead  to 
possible employment 
opportunities. 

Significant 
environmental, 
economic, 
and 
social  benefits  that 
out-weigh  possible 
costs. 

The  societal  benefits 
of 
monitoring 
tetrachloroethylene 
and trichloroethylene 
within 
the  water 
environment  may  be 
a  valuable  addition 
track 
to 
and 
emissions 
human 
possible 

help 

Benefits 
the costs. 

outweigh 

 
 
Option description 

Environmental 

Economic 

Impacts 

Overall  balance  of 
costs and benefits 

Social impact 

exposure 
environment. 

via 

the 

impact 

to 

impact 
isomer 111 -trichloro -22 bis 
(p  -  chlorophenyl)  ethane  is 
recognised  as  POP  and  is 
be 
suspected 
carcinogenic. DDTs are also 
known endocrine disruptors. 
and 
Tetrachloroethylene 
are 
Trichloroethylene 
mutagenic and carcinogenic. 
The rate of EQS exceedance 
suggests  environmental  risk 
is low.  
the 
Greater  coherence 
policy 
landscape  would 
have  societal  benefits  for 
how  these  substances  are 
addressed. 

in 

chemicals: 

PHS) 
Industrial 
Tetrachloroethylene, 
Trichloroethylene (to PHS) 
Note:  Carbon  tetrachloride 
is  deselected  under  surface 
water option 4, hence is not 
considered here. 

Option  4c:  Change 
the 
status of some existing PS to 
that  of  PHS  where  it  fulfils 
the  POP 
the  criteria  of 
Regulation and/or Article 57 
of REACH Regulation. 

Industrial  chemicals:  1,2-
Dichloroethane, 
Fluoranthene,  Octylphenol, 
Pentachlorophenol 
Metals: Lead 

in 

the 
Greater  coherence 
policy 
landscape  would 
have environmental benefits 
for how these substances are 
addressed. 

No 
– 
costs 
administrative  change 
only. 

Greater  coherence  in 
the  policy  landscape 
would  have  societal 
benefits 
how 
these  substances  are 
addressed. 

for 

Benefits 
the costs 

outweigh 

215 

 
 
ANNEX  10:  POTENTIAL  COSTS  OF  SELECTED  SURFACE  WATER  AND  GROUNDWATER 
POLLUTION REDUCTION MEASURES 

Surface water measures 

Within  the  pharmaceuticals  category,  possible  measures  MS  could  take  is  trying  to 
reduce the demand and or the production of the most harmful substances by encouraging 
producers  to  switch  to  manufacturing  alternatives.  This  could  lead  to  an  increase  in 
demand  for  alternatives  that  fill  a  similar  function  to  the  original  substance.  For  the 
pharmaceuticals,  an  illustrative  list  of  potential  alternatives  is  presented  in  the  table 
below with  a range of costs. Where the information  was available, data  on the average 
costs of a prescription for each pharmaceutical has been supplied. Note, it is not possible 
to  extract  information  on  the  size  of  each  prescription.  Furthermore,  there  will  be 
differences  in  the  typical  effectiveness  of  each  substance.  As  a  result,  the  total  cost  of 
treating a given condition using either the original pharmaceutical or the alternative will 
vary from the values given in Table A10.1. 

Table A10.1: Pharmaceutical substances, potential alternatives, and the costs of each 

Original substance 

Cost  per  prescription  of 
substance (EUR)* 

Alternative substance 

Cost  range  for  the 
prescription 
of 
alternatives 
(EUR)* 

17-Beta estradiol (E2) 

9.87 

Azithromycin 

Clarithromycin 

Erythromycin 

Carbamazepine 

Diclofenac 

Ibuprofen 

13.75 

3.99 

33.02 

7.45 

11.93 

8.93 

Tibolone, 
Sertraline  

Clarithromycin, 
Erythromycin 

Azithromycin 

Clarithromycin, 
Azithromycin  

Pregabalin, 
Phenytoin 

Clonidine, 

10.42 to 23.29 

3.99 to 33.02 

13.75 

3.99 to 13.75 

Gabapentin, 

4.36 to 23.40 

Aspirin, 
Indometacin, 
Etoricoxib, Ibuprofen 

Celecoxib, 
Naproxen, 

4.00 to 8.93 

Aspirin, 
Etoricoxib, Diclofenac 

Celecoxib, 

4.00 to 11.93 

* Only possible substitute substances within a price range of max 3.5x the costs of the original substance are included in the table. 
Costs are 2021 values and converted from GBP using an average of 1 GBP = 1.15 EUR over period from 2 January 2020 to 31 
December 2021. 

For pesticides and biocides, the best approach for limiting emissions to environment (and 
therefore  environmental  concentrations) is  to  restrict  use in specific settings or ban use 
entirely  (assuming  priority  hazardous  substance  status).  This  requires  looking  into 
possible  alternatives  that  might  be  available  instead.  The  table  below  provides  an 
overview of possible alternatives to the candidate priority/priority hazardous substances” 
(non-exhaustive analysis of alternatives to pesticides). Where many alternatives exist, it 
is possible to identify alternatives with similar efficacy and cost. Therefore, a restriction / 
ban could be used as a viable measure with the price differential affecting farmers, vets, 
society,  and  manufacturers  of  pesticides/biocides.  An  online  marketplace  was  used  to 
establish estimates for the wholesale cost of the relevant pesticides and their alternatives, 
and the application rates of these substances, it was possible to derive estimates for the 

216 

 
 
costs per hectare of application associated with each in Table A10.2 below. It should be 
noted  that  the  costs  were  obtained  from  estimations  based  on  sales  prices  of  bulk 
chemicals. The values provided should therefore be viewed with this in mind. 

Table A10.2: Pesticides, their possible alternatives, and the estimated costs 

brackets: 

Pesticide substance 
(type 
in 
H:Herbicide; 
F:Fungicide: 
I:Insecticide) 

Acetamiprid (I) 

Clothianidin (I) 

Thiacloprid (I) 

Thiamethoxam (I) 

Bifenthrin (I) 

Esfenvalerate (I) 

Deltamethrin (I) 

Nicosulfuron (H) 

Glyphosate (H) 

Candidate  priority 
substance 
Cost 
hectare* 

(EUR) 

per 

Possible alternative 

Cost 
for 
range 
possible  alternative 
substances 
Cost 
hectare* 

(EUR) 

per 

3.43 

0.82 

0.61 

0.92 

0.24 

0.06 

0.27 

1.53 

Fludioxonil, 
Spirotetramat, 
Tebufenozide, Flonicamid, Avermectin 

0.03 to 4.58 

Pyriproxyfen 

See alternatives to acetamiprid 

No likely alternatives identified yet 

Cypermethrin 

Lambda-cyhalothrin 

0.55 

0.07 

0.03 

Lambda-cyhalothrin, Pirimicarb 

0.03 to 0.33 

Mesotrione, Tembotrione, Glyphosate 

0.62 to 1.53 

Penoxsulam,  Florasulam,  Oxyfluorfen, 
Propaquizafop,  Clethodim,  Metribuzin, 
Dicamba,  Diflufenican,  Bentazone, 
Propyzamide, Bifenox, Chlorotoluron 

0.02 to 4.12 

* Only possible substitute substances within a price range of max 3.5x the costs of the original substance are included  in the table. 
Costs are converted using an average of USD 1 = EUR 0.8619 for the period between 6 April 2021 to 6 April 2022. 

For pesticides in particular a major pathway to environment is run-off from fields, with 
spray-drift  as  secondary  pathway.  This  assumes  that  good  farming  practices  should 
already  limit  the  risks  associated  with  spray  drift  from  use  of  pesticides  in  boom-
sprayers, back-pack sprayers, and crop dusting. Participants in the stakeholder workshops 
indicated that the use of physical barriers is not at saturation level and more can be done. 
Consequently,  calculations  have  been  undertaken  to  derive  indicative  (orders  of 
magnitude)  costs  attributed  to  the  application  of  pathway  disruption141  for  pesticides 
using  physical  barriers  (see  Table  A10.3  below).  The  footnote  to  the  table  provides 
further  details  on  how  these  calculations  have  been  made,  but  it  should  be  noted  that 
there is a high level of uncertainty in the estimates, and the values in table should only be 
used  for  comparative  purposes  and  orders  of  magnitude  only.  In  line  with  the  polluter 
pays principle, it is  assumed that these costs would  be borne by farmers either through 
implementation of barriers on the land (e.g., buffer strips), or through additional activities 
relating  to  biocides  (capture  and  management  of  wastes  contaminated  with  biocides). 
From  these  estimations,  it  appears  that  the  use  of  physical  barriers  for  the  treatment  of 
glyphosate  would  come  at  the  highest  cost,  but  this  reflects  its  very  high  usage  rates 
across the EU. A possible compromise position could be a combination of source control 
(reduce  use  through  greater  application  of  alternatives)  and  reduced  need  for  pathway 
disruption options. 

141 The values in the table can only be used for comparative purposes and orders of magnitude. In line with the polluter pays principle, 
it is assumed that these costs would be borne by farmers either through the setting up of barriers on the land (e.g., buffer strips), or 
through additional activities relating to biocides (capture and management of wastes contaminated with biocides). 

217 

 
 
 
 
 
                                                           
Table  A10.3:  Pesticides  for  which  the  use  of  physical  barriers  could  possibly  be  further  increased,  and 
associated costs of such measures  

Substance 

Measure 

Acetamiprid 

Physical barriers to surface water buffer strips (see notes to right) 

Clothianidin 

Imidacloprid 

Potential  to  create  physical  barriers  to  surface  water  seems  particularly 
high  in  the  intensive  rearing  of  poultry  sector  due  to  use  as  biocide. 
Additional emission controls for farm waste. 
Potential  to  create  physical  barriers  to  surface  water  seems  particularly 
high  in  the  intensive  rearing  of  poultry  sector  due  to  use  as  biocide. 
Additional emission controls for farm waste. 

Nicosulfuron 

Physical barriers - buffer strips 

Deltamethrin 

Physical  barriers  -  additional  controls  and  treatment  for  farmed  animal 
use 

Esfenvalerate 

Physical barriers to surface water buffer strips  

Total 
(€), million 

cost* 

1.6 

162 

162 

12.8 

184.6 

No data 

Physical barriers to surface water buffer strips  

Glyphosate 
*Cost calculations for buffer strips: data has been gathered on tonnes of pesticide used per annum as well as application rates per 
hectare. Based on previous section for pharmaceuticals again assume that the vast majority of arable land is away from rivers and 
water courses with limited risk of run-off. On that basis assume that 10% of arable land is at risk as a worst-case scenario, and then 
apply buffer strips at €160 per hectare.  
Cost  calculations  for  biocidal  use  in  farms  (chicken  coops  and  stables):  data  has  been  gathered  from  Eurostat  for  numbers  of 
animals,  and  excretion  rates  1,000  chickens  produce  65  tonnes  of  litter  per  annum.  Assume  all  litter  and  wastes  will  need  to  be 
retained  and  incinerated.  All  washings  retained  and  sent  for  further  treatment  (e.g.,  ozonation/GAC/PAC  etc.)  and  not  washed 
directly to drain, costs per dm3 applied. 

284.7 

For pesticides used in  agricultural  settings  the pathway via end of pipe is  less relevant, 
although use of pesticides in amenity areas with hard surfaces that allow wash-off/run-off 
to storm drains will be important. Conversely, the use of biocides, can be carried out both 
in  outdoor  settings  (e.g.,  sheep-dips),  and  indoor  settings  (stables,  coops,  domestic 
homes,  work-places,  etc.).  Therefore,  for  biocidal  uses,  particularly  within  indoor 
settings, the potential was wash-off or rinsing to drains during cleaning and maintenance 
is an issue. Based on work already completed by the JRC to support the revision of the 
urban  wastewater  directive  and  further  implementation  of  quaternary  treatment 
technologies,  an  analysis  of  technologies,  unit  prices,  and  efficacies  for  the  possible 
removal  of  specific  substances  was  made.  The  same  methodology  as  outlined  in  the 
previous sub-section for pharmaceuticals has been used to help identify options and costs 
for  end-of-pipe  measures  for  those  substances  with  biocidal  uses.  Table  A10.4  below 
provides these results. 

Table A10.4: Estimated costs of end-of-pipe measures for biocides 

Measure 

Cost  (€  per  population 
equivalent/ per yr) 

Efficacy (%) 

Imidacloprid, 

WWTWs - Ozonation 

10 

From 90 – to 99 

Substance 

Clothianidin, 
Deltamethrin 

Triclosan 

90-100 

From 83 to 99 

WWTWs 
Osmosis 

- 

Reverse 

20.7 

Acetamiprid,  Thiamethoxam, 
Permethrin 
* Costs for EU27 in € / year - costs are amortised (assuming 25 year asset lifetime) 

WWTWs - GAC 

26.2 to 32 

218 

 
 
Groundwater measures 

Table A10.6: Costs of selected measures to address groundwater pollution by PFAS 

Measure 

Type 
measure 

of 

Unit 

Unit cost 

Comment on calculation 

Soil remediation 

Receptor 
remediation 

EU level 

€5 to €760 million 
at  EU  level  (one 
off cost) 

Groundwater 
remediation 

Receptor 
remediation 

EU level 

€1.7-€35  million  / 
level 
yr  at  EU 
(annualised  over 
30 years) 

Capture 
biosolids 
treatment  

of 
for 

End  of  pipe 
control 
- 
WWT 

EU level 

Capture 
of 
industrial  waste, 
e.g. in paper mills 

Source control 
- WWT 

EU level 

€201  million  per 
year  to  send  to 
landfill  
€503-755 
million/yr for high 
temperature 
incineration 

Landfill  -  €76.72 
million / yr 
High  temperature 
incineration 
- 
€191.8  to  €287.7 
million / yr. 

Remediation  of  point  sources  based  on  an 
assumed  total  of  10-20  airfields  /  fire 
training stations sites at EU level identified 
for remediation.  
Soil remediation costs per site are given for 
(28,125 m3) 
low 
volumes of contaminated soils:  
  Soil  incineration  -  €0.5-18  million  per 

(2,700 m3)  and  high 

site  

  Landfill – €2.5-38 million per site  
Groundwater  pump  and  treat  costs  per  site 
is  €2.9-30.3  million  over  a  30-year  period 
of  construction, operation  and  maintenance 
(120).  Annual  equivalent  costs  are  €0.17 
million-€1.75 million per site respectively. 

High temperature sludge incineration: Total 
sludge generated in EU: 
441  million  (population)  x  0.0782  kg  per 
person/day (dry weight) = 34,398 tonne/day 
or 12.6 million tonnes /yr.  
Assume  10%  requires  incineration  –  1.26 
million  tonnes  /yr  at  a  cost  of  €400-
600/tonne = €500-755 million/yr.  
Cost  to  send  to  landfill  of  the  1.26  million 
tonnes/yr (2013 highest landfill gate fee and 
tax of €160 per tonne (121)) - €201 million 
per year.  

The  894  paper  mills  in  the  EU  recycled 
47,950,000  tonnes  of  paper  in  2020  (122). 
10%  ends  up  as  recycling  paper  sludge 
waste  with  potential  for  spreading  to  land 
i.e.  4,795,000  tonnes/yr  available.  Assume 
that  a  further  10%  of  this  sludge  waste  is 
contaminated  with  PFAS 
i.e.  479,500 
tonnes per year requires treatment.  
Cost  to  send  the  same  volume  to  landfill 
(using  the  highest  gate  fees  in  2013  of 
€160/t) is €76.72 million/yr. 
High 
temperature 
biosolids) - €191.8 to €287.7 million/yr.  
Not  costed –  the  loss  to  the  farming  sector 
of cheap soil improver.  

incineration 

(as 

for 

Landfill 
treatment 

leachate 

Source control   Per site 

Between €530 and 
€358 million 

Capex  and  Opex  for  two  pass  reverse 
osmosis  system  with  pre-treatment  and 
evaporation  ponds  dealing  with  17.5  m3/yr 
leachate (123). 

use 

on 
Guidance 
proper 
of 
PFAS  containing 
products  which 
could be spread to 
land 

back 

Take 
schemes/ 
incentives 
to 
replace  domestic 
products  that  may 
contain PFAS 

Source control 
(Behavioural) 

One  set  of 
European 
level 
guidance 
or per MS 

€50,000 

Source control 
(Behavioural) 

per MS 

Millions 

See  see  Section  6.2.1  and  table  A9.7    for 
derivation 

219 

 
 
Measure 

Type 
measure 

of 

Unit 

Unit cost 

Comment on calculation 

Restriction  of  use 
of  PFAS  in  one 
sector 
(fire-
fighting foams) 

Source control  EU level  

€390  million  /  yr 
over 30 years (per 
use) 

Cost of restriction on PFAS in fire-fighting 
foams,  based  on  estimated  cost  on  placing 
on the market and after use / sector specific 
transitional  periods  (see  Section  6.2.1  and 
table A9.7 for derivation). 
Cost is for use of PFAS. Other key sectors 
are personal care products, food packaging, 
chrome  metal  plating,  building  materials, 
electronics  –  assuming  replacement  in  10 
further  uses  -  €3,900  million/yr  over  30 
years.  

Table A10.7: Costs of selected measures to address groundwater pollution by pharmaceuticals 

Measure 

Type 
measure 

of 

e
l
o
z
a
x
o
h
t
e
m
a
f
l
u
S

e
n
i
p
z
a
m
a
b
r
a
C

e
n
o
d
i
m
i
r
P

Unit 

Unit cost 

Comments 

in 

Ban 
use 
agricultural 
animals 

Source control 
(animals) 

Y  N  Y 

0 

0 

Provide  guidance 
on proper disposal 

Source control 
(prescribing) 

Y  Y  Y 

One  set  of 
European 
level 
guidance 
or per MS 

€50,000 circa 

Improved  returns 
program 
for 
unused drugs 

Source control 
(prescribing) 

Y  Y  Y  MS level 

Less  than  €1-
10 million  

Establish  national 
returns  programs 
(if non-existent) 

in 
Innovation 
green  pharmacy  – 
allow  medicine 
experts 
to 
promote  prudent 
use  and  correct 
disposal 
of 
pharma -  

Tailoring 
drug 
dosage/  providing 
a 
of 
range 
package sizes 

Source control 
(prescribing) 

Y  Y  Y  MS level 

€1-10 million  

Source control 
(prescribing) 

Y  Y  Y  MS level 

 €1-10 million  

Source control 
(prescribing) 

Y  Y  Y  MS level 

0 

Improved  sludge 
management 
at 
wastewater 
treatment works 

End-of-pipe  / 
pathway 
disruption 

Y  Y  Y 

EU level 

€201  million 
to 
per  year 
to 
send 
landfill  
€503-755 
million//yr  for 
high 

220 

Sulfamethoxazole  -  Assume 
no  cost  difference  for  many 
alternatives  available  but  risk 
of 
is 
swapping  pollutant 
possible. 
Product  substitution  deemed 
feasible 
not 
for 
carbamazepine 
animals 
in 
(costs of €140,000). 

Represents better investment / 
expansion of a returns scheme 
to  more  substances  (based  on 
France  Cyclamide  scheme  - 
population circa 60 million). 

based 

on  France 
Costs 
Cyclamide  scheme  –  (actual 
costs  will 
on 
population  of  MS 
-  FR 
population circa 60 million). 

depend 

Likely  to  be  cost  neutral  / 
administrative  costs  /  start  up 
but will use less of the active 
ingredient. 

sludge 
sludge 

High 
temperature 
incineration.  Total 
generated in EU: 
441  million  (population)  x 
0.0782 kg per person/day (dry 
weight)  =  34,398  tonnes/day 
or 12.6 million tonnes/yr.  

 
 
 
 
 
 
Measure 

Type 
measure 

of 

e
l
o
z
a
x
o
h
t
e
m
a
f
l
u
S

e
n
i
p
z
a
m
a
b
r
a
C

e
n
o
d
i
m
i
r
P

Unit 

Unit cost 

Comments 

temperature 
incineration  

10% 

highly 
Assume 
is 
contaminated  and 
requires 
incineration  -  1.26  million 
tonnes/ year at a cost of €400-
€503-755 
600/tonne= 
million/yr.  
Cost to send to landfill of the 
12.6  million  tonnes  /yr  (2013 
highest  landfill  gate  fee  and 
tax of €160 per tonne (121)) - 
€201 million per year.  
Note  EU 
to 
reduce  landfill  to  10%  by 
2035  and  the  high  energy 
costs  of  incineration  so  this 
measure is not coherent. 

requirement 

Table A10.8: Costs of selected measures to address groundwater pollution by nrMs 

Measure 

Type 
measure 

of 

Unit 

Unit cost 

Comment 

Source control 

Cost 
difference  of 
use 
of 
substitute  per 
hectare  

to  100 

Flufenacet  can  be  3  times 
cheaper 
Fluopicolide  –  30 
times more costly  
Glyphosate  similar  or  up  to 
40 times more expensive  
Metazachlor  –  one  eight  to 
half the cost  

End  of  pipe  / 
pathway 
disruption 

EU level 

EU 

estimate 

/ 
No 
extrapolations  available  only, 
limited indicative data from 1 
Member State 

pesticides 

Costs  of  permitted  parent 
– 
substitute 
is 
dimethachlor  substitute 
not 
metazachlor 
appropriate  

so 

Irish  EPA  expenditure  on 
landfill  remediation  in  2019 
at  122  sites  €158.4  million 
ranging  from  €690,000  to 
€77 million to per site. 

/  restrict 

Ban 
agricultural 
uses  of  parent 
(use 
pesticide 
substitute) 

Historical 
landfill 
remediation 
deal 
pesticide 
contamination 

to 
with 

221 

 
 
 
 
 
 
 
ANNEX 11: SURFACE WATER MONITORING DATA 

Table A11.1: Monitoring data for candidate PS 

Substance 

Main uses / sources of pollution 

s
l
a
c
i
t
u
e
c
a
m
r
a
h
P

c
i
n
e
g
o
r
t
s
E

s
e
n
o
m
r
o
h

e
d
i
l
o
r
c
a
M

s
c
i
t
o
i
b
i
t
n
a

r
e
h
t
O

s
d
i
o
n
i
t
o
c
i
n
o
e
N

s
d
i
o
r
h
t
e
r
y
P

Estrone (E1) 

17-eta-estradiol (E2) 

Ethylestradiol (EE2) 

Used  as  medication,  e.g.  in  hormonal  birth 
control,  menopausal  hormone 
therapy, 
treatment of hormone-sensitive cancers. 

Azithromycin 

Clarithromycin 

Erythromycin 

Carbamazepine 

Diclofenac 

Ibuprofen 

Acetamiprid 

Clothianidin 

Imidacloprid 

Thiacloprid 

Thiamethoxam 

Bifenthrin 

Deltamethrin 

Esfenvalerate 

Permethrin 

Glyphosate 

Used  in  animal  farming  and  as  medication 
to treat various infections 

Used  as  medication  to  treat  trigeminal 
neuralgia,  diabetic  neuropathy  and  bipolar 
disorder. 
Used  as  medication 
to 
moderate  pain,  or  signs  and  symptoms  of 
osteoarthritis or rheumatoid arthritis. 
Used  as  medication  to  reduce  fever  and 
treat pain or inflammation caused by  many 
conditions. 

treat  mild 

to 

Used  to  control  insect  pests  in  agriculture 
(crops,  vegetables,  fruits),  animal  farming 
(e.g.  for  invertebrate  pest  control  in  fish 
farming). 

Used  to  control  insect  pests  in  agriculture, 
public health and animal farming. 

Used  as  an  herbicide  to  control  weeds  and 
grasses. Current approval expires December 
2022, but likely to be extended. 

Nicosulfuron 

Used as an herbicide to control weeds. 

s
e
d
i
c
i
t
s
e
P

r
e
h
t
O

Triclosan 

Used  as  an  antibacterial  and  antifungal 
agent in some consumer products, including 
toothpaste,  soaps,  detergents,  toys,  and 
surgical cleaning treatments. Also added to 
other  materials,  such  as  textiles,  to  make 
them resistant to bacteria. 

222 

of 

(0.0003-

(min  and 

Indication 
current 
concentrations  in 
surface water 
mean 
max) µg/L 
1.59 
24.49) 
0.00095 
0.0033) 
0.000882 
(0.00005-0.005) 
41.5 
3,145.38) 

(0.0003-

(0.01-

MS 
surface 
concentration data 

providing 
water 

CZ, ES 

CZ, RO 

CZ, RO 

CZ, ES 

15.4 (0.01-391) 

CZ, ES, DE 

17.2 (0.01-200) 

CZ, ES, DE 

0.053 (0.005-1.85)  CZ, DE, ES, LU, NL 

15.1 (0.005-3,998)  CZ, DE, ES, LU, RO 

0.0740 (0.005-10) 

CZ, DE 

0.0055  (0.000195 
– 0.0644) 

Data anonymised 

1.45 (0.005-25) 

CZ, ES, SE 

2.83 
400) 

(0.00005-

CZ,  DE,  ES,  IT,  NL, 
SE 

1.02 (0.0005-88) 

CZ, ES, FI, IT, SE 

0.0437  (0.0005  – 
2.7135) 
0.1125  (0.0338  – 
0.436) 
0.0535 
0.19) 
0.0430 
0.1495) 

(0.001  – 

(0.004 

- 

Data anonymised 

Data anonymised 

Data anonymised 

Data anonymised 

0.162 (0.0005-20) 

CZ, FI, FR, IT, SE 

0.525 (0.001-790) 

CZ,  DE,  ES,  FI,  FR, 
IE, IT, NL, SE, SK 

0.0160 
3) 

(0.00206-

DE 

0.0142 
0.458) 

(0.0001-

CZ, DE 

 
 
 
 
 
 
 
 
 
 
 
Substance 

Main uses / sources of pollution 

Bisphenol A 

PFOA  and  PFOS 
and 
its  derivatives 
(PFAS) 

Silver 

s
l
a
c
i
m
e
h
c

l
a
i
r
t
s
u
d
n
I

s
l
a
t
e

M

for 

activity, 

Used in the manufacture of various plastics, 
including 
shatterproof  windows, 
eyewear,  water  bottles,  and  epoxy  resins 
that coat some metal food cans, bottle tops, 
and water supply pipes. 
Used  in  stain-  and  water-resistant  fabrics 
and  carpeting,  cleaning  products,  paints, 
and fire-fighting foams. 
Nanosilver and other forms of (ionic) silver 
their 
are  widely  used  nowadays 
antibacterial 
silver 
containing  personal  care  products  (PCP), 
medical products and a wide range of other 
consumer  products. 
that 
currently,  products  that  contain  forms  of 
(nano)silver are difficult to track since they 
are marketed under numerous brand names, 
and,  with  a 
few  exceptions,  current 
labelling  regulations  do  not  specifically 
a 
require 
constituent. 
In  some  areas  silver  is  also  a  naturally 
occurring  substance  e.g.  around  metal 
mines.  

nanomaterials 

is  noted 

for 
in 

listing 

e.g. 

as 

It 

of 

Indication 
current 
concentrations  in 
surface water 
mean 
max) µg/L 

(min  and 

MS 
surface 
concentration data 

providing 
water 

0.623 
1,300) 

(0.0005-

CZ,  DE,  ES,  FI,  IT, 
LT, SK 

0.288 
120) 

(0.00003-

CZ, DE, ES, FR, IT 

0.524 (0.003-25) 

CZ,  DE,  FR,  IE,  IT, 
LU, NL, PL, RO 

223 

 
 
 
 
Table A11.2: Monitoring data for existing PS 

Substance 

Main  uses 
pollution 

/  sources  of 

Substances considered for EQS amendment 

Chlorpyr
ifos 

Cyperme
thrin 

Past  use  as  an  insecticide  to 
control  foliage  and  soil-borne 
insect  pests  on  a  variety  of 
food  and  feed  crops.  Not 
approved 
since  2019.  No 
ongoing commercial use. 
the  protection  of 
Used 
wood against wood-destroying 
insects, 
an 
applied 
insecticide  in  agriculture  and 
veterinary 
topically 
in 
Ongoing 
applications. 
commercial use. 

as 

in 

Dicofol 

Not  approved  since  2008.  No 
ongoing commercial use. 

paints. 

Past  use  as  a  pre-emergence 
herbicide  for  general  weed 
control  on  non-croplands,  in 
and  around  water  bodies  and 
as  a  component  of  marine 
anti-fouling 
Not 
approved  for  pesticide  use 
since  2020.  Still  used  within 
industrial chemicals. 
Past  use  as  an  insecticide  to 
control  various  insect  pests, 
seed 
soil 
and 
treatment,  wood  protection. 
Banned in the EU since 1984. 
No ongoing commercial use. 

and 

for 

Past  use  as  a  fungicide  for 
seed  treatment,  especially  on 
wheat  to  control  the  fungal 
disease  bunt.  Banned  in  the 
EU  since  the  early  1980s.  No 
ongoing commercial use. 

Diuron 

s
e
d
i
c
i
t
s
e
P

Heptachl
or 
/ 
Heptachl
or 
epoxide 

Hexachlo
ro-
benzene 

Tributylt
in 

Past  use  as  a  biocide  in  anti-
fouling  paints  on  ships  and 
boats.  Banned.  No  ongoing 
commercial use. 

s
e
d
i
c
i
t
s
e
P

Curre
nt 
EQS 
for 
inlan
d 
surfa
ce 
water
s 
µg/L 

AA: 
0.03 
MAC: 
0.1 

AA:  8 
10-5 
MAC: 
6 10-4 

AA: 
1.3 
10-3 
MAC: 
n/a 

AA: 
0.2 
MAC: 
1.8 

AA:  2 
10-7 
MAC: 
0.000
3 

AA: 
n/a 
MAC: 
0.05 

AA: 
0.000
2 
MAC: 
0.001
5 

142 Based on pass/fail data reported by MS under the 2nd RBMPs 

No.  of 
WBs 
with 
EQS 
excee
dance 

No. 
of 
MS  with 
at  least  1 
WB 
in 
exceedan
ce142(pass
/fail) 

MS 
reportin
g 
exceeda
nces  (as 
pass/fail 
status) 

of 

Indication 
current 
concentrations 
in 
water 
mean  (min  and 
max) µg/L 

surface 

MS  providing 
concentration 
data 

523 

9 

BE,  CY, 
CZ,  DE, 
ES,  FR, 
IT,  NL, 
SK 

0.187 (0-500)  

AT,  BE,  BG, 
CY,  CZ,  DE, 
ES, FI, FR, HR, 
IE, IT, LT, LU, 
MT,  NL,  PL, 
PT, RO, SK 

9 

1 

CZ 

(<LOQ  (0.01)  – 
0.0864) 

ES,  CZ,  DE, 
FR 

0 

0 

- 

All  below  LOQ 
(0.0004)  

CY,  CZ,  DE, 
ES, FR, IT 

0.390 (0-2,295)  

0.546 (0-20)  

0.123 (0-1,000)  

0.261 (0-100)  

AT,  BE,  CY, 
CZ,  DE,  DL, 
ES, FI, FR, HR, 
IE, IT, LT, LU, 
MT,  NL,  PL, 
PT,  RO,  SE, 
SK 

BE,  CY,  CZ, 
DE, EL, ES, FI, 
IT, 
FR,  HR, 
LT,  NL,  PT, 
SK 

AT,  BE,  CY, 
CZ, DE, ES, FI, 
FR, HR, IE, IT, 
LT,  LV,  LU, 
MT,  NL,  PL, 
PT, RO, SK 

BE,  CZ,  DE, 
ES,  FR,  LU, 
MT,  NL,  PL, 
SK 

BE,  CZ, 
DE,  EL, 
ES,  FR, 
HU,IT, 
NL,  NO, 
SK 

CY,  DE, 
ES,  FR, 
HR, IT 

AT,  CZ, 
DE, 
EL,ES, 
FR, 
IT, 
LT,  NL, 
NO,  PL, 
RO,  SE, 
SK 
AT,  BE, 
CZ,  DE, 
EL,  ES, 
FI,  FR, 
IT,  LT, 
LV,  NL, 
NO,  PL, 
PT,  SE, 
SI, SK 

1,509 

11 

39 

6 

868 

14 

1,988 

18 

224 

 
 
 
                                                           
Curre
nt 
EQS 
for 
inlan
d 
surfa
ce 
water
s 
µg/L 

AA: 
n/a 
MAC: 
n/a 

AA: 
0.006
3 
MAC: 
0.12 

AA: 
0.001
6 
MAC: 
0.5 

AA: 
n/a 
MAC: 
0.6 

AA: 
0.3 
MAC: 
2 

AA: 
0.001
7 
MAC: 
0.27 

Substance 

Main  uses 
pollution 

/  sources  of 

by-products 
practices, 

of 
Mainly 
industrial 
e.g. 
chlorine bleaching of pulp and 
paper.  Also  formed  during 
combustion 
processes 
smoking).  No 
(including 
commercial use. 
PAH  family  member  found  in 
crude  oil  and  distillates.  Use 
as a binding agent in industrial 
consumer 
in 
processes, 
products such as clay pigeons, 
and  activated  carbon,  and  in 
professional uses such as road 
Ongoing 
construction. 
commercial use. 

Used as flame-retardant within 
insulation  boarding,  plastics, 
and textiles. 

Unintentional  by-product  of 
the  chemicals  industry,  e.g. 
the manufacture of chlorinated 
solvents, 
magnesium 
production and incineration.  

Past use in industrial processes 
(e.g. for washing and dying of 
yarns  and  fabrics)  and 
in 
consumer  laundry  detergents, 
personal  hygiene,  automotive, 
latex  paints,  and  lawn  care 
and 
products. 
majority  of  uses  have  been 
restricted 
since  2003.  No 
ongoing  intentional  use  but 
imported textiles still an issue. 

Production 

Unintentional 
by-products 
from  incomplete  combustion 
of  organic  materials.  Oil 
residues  containing  PAHs  are 
added to rubber and plastics as 
a 
extender. 
Ongoing  commercial  use  and 
unintentional formation. 

softener 

or 

Dioxins 

Fluorant
hene 

Hexabro
mo-
cyclodod
ecane 

Hexachlo
ro-
butadien
e 

Nonyl 
phenol 

PAHs 

s
l
a
c
i
m
e
h
c

l
a
i
r
t
s
u
d
n
I

s
l
a
c
i
m
e
h
c

l
a
i
r
t
s
u
d
n
I

No.  of 
WBs 
with 
EQS 
excee
dance 

of 
No. 
MS  with 
at  least  1 
WB 
in 
exceedan
ce142(pass
/fail) 

MS 
reportin
g 
exceeda
nces  (as 
pass/fail 
status) 

of 

Indication 
current 
concentrations 
in 
water 
mean  (min  and 
max) µg/L 

surface 

Unkno
wn 

Unknown 

Unknow
n 

0.843 (0-580)  

2,367 

17 

BE,  CZ, 
DE,  EL, 
ES,  FR, 
HU,  IT, 
LT,  LU, 
MT,  NL, 
NO,  PL, 
RO,  SE, 
SK 

0.552 (0-5,350)  

MS  providing 
concentration 
data 

BE,  BG,  CY, 
DE,  EL,  ES, 
FR, HR, IT, IU, 
NL, RO, SK 

AT,  BE,  BG, 
CY,  CZ,  DE, 
EL, ES, FI, FR, 
HR, IE, IT, LT, 
LU,  LV,  MT, 
NL,  PL,  PT, 
RO, SK 

8 

2 

CZ, DE 

(<LOQ  (0.0001) 
– 0.056) 

CZ, DE 

0.530 (0-100)  

AT,  BE,  CY, 
CZ, DE, ES, FI, 
FR, HR, IE, IT, 
LT,  LU,  MT, 
NL,  PL,  RO, 
SK 

(0.005-

0.0863 
0.15)  
(based on only 4 
data entries by 1 
MS) 

DE 

0.221 (0-2,180)  

AT,  BE,  BG, 
CY,  CZ,  DE, 
ES, FI, FR, HR, 
IE, IT, LT, LU, 
LV,  MT,  NL, 
PL,  PT,  RO, 
SK 

BG,  CZ, 
DE,  EL, 
ES,  FR, 
IE, 
IT, 
NL,  NO, 
SK 

CZ,  DE, 
EL,  ES, 
FR,  HU, 
IT,  NO, 
PT,  SE, 
SK 

AT,  BE, 
CZ,  DE, 
EL,  ES, 
FR,  HU, 
IT, 
IE, 
LT,  LU, 
LV,  NL, 
NO,  PL, 
RO,  SE, 
SK 

811 

11 

986 

11 

3,926 

19 

225 

 
 
 
 
 
No.  of 
WBs 
with 
EQS 
excee
dance 

of 
No. 
MS  with 
at  least  1 
WB 
in 
exceedan
ce142(pass
/fail) 

MS 
reportin
g 
exceeda
nces  (as 
pass/fail 
status) 

of 

Indication 
current 
concentrations 
in 
water 
mean  (min  and 
max) µg/L 

surface 

MS  providing 
concentration 
data 

Curre
nt 
EQS 
for 
inlan
d 
surfa
ce 
water
s 
µg/L 

AA: 
n/a 
MAC: 
0.14 

23,800 

9 

AA: 
n/a 
MAC: 
0.07 

46,780 

25 

Substance 

Main  uses 
pollution 

/  sources  of 

PBDEs 

Mercury 

Used  as  flame-retardants  in 
plastics,  furniture,  upholstery, 
electrical 
equipment, 
electronic devices, textiles and 
other household products. Use 
of  lower  order  homologues 
was  banned  internationally  in 
2004  and  use  of  DecaBDE 
should  have  ceased  by  2021. 
Primarily a legacy issue for in-
use stock and landfill. 

Naturally occurring substance. 
Wide  range  of  uses,  e.g.  in 
barometers, 
thermometers, 
manometers,  blood  pressure 
meters,  float  valves,  mercury 
switches,  mercury 
relays, 
fluorescent  lamps  and  other 
devices.  Also  forms  during 
combustion  of  fossil  fuels. 
Ongoing  commercial  use  and 
unintentional formation. 

Naturally occurring substance. 
Used  to  make  stainless  steel 
and  other  alloys,  for  plating, 
foundry 
batteries. 
and 
Ongoing commercial use. 

AA: 4 
MAC: 
34 

1,840 

22 

Nickel 

s
l
a
t
e

M

Substances considered for deselection143 

Alachlor 

Past  use  as  an  herbicide  to 
control grasses and weeds. No 
longer approved for use in the 
EU. 

AA: 
0.3 
MAC: 
0.7 

488 

10 

Insecticide to control ticks and 
biting insects for protection of 
livestock. It has also been used 
as  an  insecticide  to  protect 
ground crops, such as potatoes 
longer 
and  vegetables.  No 
approved for use in the EU. 

AA: 
0.1 
MAC: 
0.3 

Chlorfen
-vinphos 

s
e
d
i
c
i
t
s
e
P

809 

7 

BE,  CZ, 
DE,  EL, 
IT, 
FR, 
LV,  SE, 
SK 

AT,  BE, 
BG,  CY, 
CZ,  DE, 
EE,  EL, 
ES,  FI, 
FR,  HU, 
IE, 
IT, 
LT,  LU, 
LV,  MT, 
NL,  NO, 
PL,  RO, 
SE,  SI, 
SK 
BE,  BG, 
CY,  CZ, 
DE,  EE, 
EL,  ES, 
FI,  FR, 
HU,  IE, 
IT,  LV, 
MT,  NL, 
NO,  PL, 
PT,  RO, 
SE, SK 

BE,  CY, 
CZ,  DE, 
EL,  ES, 
FR, 
IT, 
RO, SK 

EL,  ES, 
FR, 
IT, 
PL,  SE, 
SK 

0.0465 (0-5)  

DE,  ES,  FR, 
LU,  MT,  PL, 
SK 

3.54 (0-5,800)  

627 (0-2 106)  

0.0674 
100) 

(0.0003  

0.122 
500) 

(0.0005 

AT,  BE,  BG, 
CY,  CZ,  DE, 
EE, EL, ES, FI, 
FR,  HR,  HU, 
IE, IT, LT,  LU, 
LV,  MT,  NL, 
PL,  PT,  RO,  
SE, SK 

AT,  BE,  BG, 
CY,  CZ,  DE, 
EE, EL, ES, FI, 
FR,  HR,  HU, 
IE, IT, LT, LV, 
MT,  NL,  PL, 
PT,  RO,  SE, 
SK 

AT,  BE,  CY, 
CZ,  DE,ES,  FI, 
IT, 
FR,  HR, 
LU,  MT,  NL, 
PL,  PT,  RO, 
RS, SK 

BE,  CY,  CZ, 
DE, ES, FI, FR, 
HR, 
IT,  LU, 
MT,  NL,  PL, 
RO, RS, SK 

143 Information in columns on the ‘No. of WBs with EQS exceedances’ and ‘No. of MS with at least 1 WB in exceedance’ is based on information 
from the corresponding EEA dashboard(s) 

226 

 
 
 
                                                           
MS  providing 
concentration 
data 

AT,  BE,  BG, 
CY,  CZ,  DE, 
EL, ES, FI, FR, 
HR, IE, IT, LT, 
LU,  MT,  NL, 
PL,  RO,  RS, 
SK 

IT, PL, ES, DE, 
BE,  CY,  CZ, 
IE, 
FR,  HR, 
LU,  NL,  MT, 
SK,  

AT,  BE,  CY, 
CZ, 
DE,EL, 
ES,  FR,  HR, 
IT,  LU, 
IE, 
MT,  NL,  PL, 
RO, SK 

Substance 

Main  uses 
pollution 

/  sources  of 

Curre
nt 
EQS 
for 
inlan
d 
surfa
ce 
water
s 
µg/L 

No.  of 
WBs 
with 
EQS 
excee
dance 

of 
No. 
MS  with 
at  least  1 
WB 
in 
exceedan
ce142(pass
/fail) 

MS 
reportin
g 
exceeda
nces  (as 
pass/fail 
status) 

of 

Indication 
current 
concentrations 
in 
water 
mean  (min  and 
max) µg/L 

surface 

Simazine 

Past  use  as  an  herbicide  to 
control grasses and weeds. No 
longer approved for use in the 
EU. 

AA: 1 
MAC: 
4 

1,292 

5 

DE,  ES, 
FR, 
IT, 
SK 

0.106 (0.00001 - 
100) 

Carbon 
tetrachlo
ride 

Trichlor
o-
benzenes 

s
l
a
c
i
m
e
h
c

l
a
i
r
t
s
u
d
n
I

Primarily used as a solvent for 
oils, waxes, resins, and runner. 
Also  used  as  an  intermediate 
of 
the  manufacture 
in 
refrigerants  and  propellants 
for  aerosol  cans.  Ongoing 
commercial use. 
Family of chemicals primarily 
used  as  solvents  and  chemical 
intermediates 
other 
compounds.  Sectors  of  use 
include  as  solvent  degreaser 
(primarily for oils and waxes), 
and 
to  produce  dyes  and 
textiles.  Ongoing  commercial 
use. 

for 

AA: 
12 
MAC: 
n/a 

AA: 
0.4 
MAC: 
n/a 

1,206 

4 

DE,  FR, 
IT, SK 

1.206  (0.0002  - 
87.58) 

785 

6 

CZ,  DE, 
ES,  FR, 
IT, SK 

0.510  (0.0001  - 
100) 

227 

 
 
 
 
ANNEX 12: LITERATURE REFERENCES  

Main reports used across this staff working document: 

implementation  of 
(2016)  Reports  on 
European  Commission 
https://ec.europa.eu/info/sites/default/files/com_report_wfd_fd_2019_en_1.pdf 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021DC0970 

the 

the  WFD: 
and 

WOOD (2022) Study to support the Impact Assessment of the Revision of the EQSD, GWD 
and WFD. Not yet published. 

Supporting literature: 

1.  WHO.  Antimicrobial  Resistance.  [Online]  2021.  https://www.who.int/news-room/fact-
sheets/detail/antimicrobial-resistance. 

2.  OECD.  OECD  Workshop  on  Managing  Contaminants  of  Emerging  Concern  in  Surface 
Waters. 
2018. 
[Online] 
https://www.oecd.org/water/oecdworkshoponmanagingcontaminantsofemergingconcerninsur
facewaters.htm. 

3.  European  Chemicals  Agency.  Microplastics.  [Online]  2022.  https://echa.europa.eu/hot-
topics/microplastics. 

4. Occurrence and removal of organic micropollutants: An overview of the watch list of EU 
Decision 2015/495. Barbosa, M. O., et al. 2016, Water Research, Vol. 94, pp. 257-279. 

European 

5. 
https://www.eea.europa.eu/help/glossary/gemet-environmental-thesaurus/micropollutant. 

Agency.  Micropollutant. 

Environment 

[Online] 

2022. 

6.  US  Environment  Protection  Agency.  What 
https://www.epa.gov/minimum-risk-pesticides/what-pesticide. 

is  a  Pesticide?  [Online]  2022. 

7.  European  Chemicals  Agency.  PFAS.  [Online]  2022.  https://echa.europa.eu/hot-
topics/perfluoroalkyl-chemicals-pfas. 

8. European Commission. Status of implementation of the WFD in the MS. [Online] 2022. 
https://ec.europa.eu/environment/water/participation/map_mc/map.htm. 

9. Common Implementation Strategy for WFD and Floods Directive - Working Group 
Groundwater. Voluntary Groundwater Watch List Concept & Methodology. 2019. 

10.  European  Commission.  Commission  Staff  Working  Document  -  Fitness  Check  of  the 
Water  Framework  Directive,  Groundwater  Directive,  Environmental  Quality  Standards 
Directive and Floods Directive. 2019. SWD(2019) 440 final. 

11. European Environment Agency. Report on European waters - assessment of status and 
pressures. 2018. Report No 7/2018. 

12.  —.  EEA-Publications-State-of-Water.  European_Environment_Agency-Publications-
State-of-Water.  [Online]  European  Environment  Agency,  2018.  [Cited:  10  05  2022.] 
https://www.eea.europa.eu/publications/state-of-water. 

13. German Environment Agency. PFAS - came to stay.  What Matters - Magazine of the 
German Environment Agency. 2020, Vol. 1, p. 21. 

 
 
14. Tekman M. B., Walther B. A., Peter C., Gutow L., Bergmann M. Impacts of plastic 
pollution  in  the  oceans  on  marine  species,  biodiversity  and  ecosystems.  Berlin :  WWF 
Germany, 2022. pp. 1-221. 

15.  WFD  CIRCA:  "Implementing  the  Water  Framework  Directive  and  the  Floods 
Directive". 
https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-
9964bbe8312d/library/677b0752-676a-4a17-a60a-08a833fcc204. 

[Online] 

16. Groundwater Watch List (1st draft). 2019. 

17.  European  Commission.  Information  Platform  for  Chemical  Monitoring  -  Pharms-
UBA 
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