EurEau, the European Federation of National Associations of Water Services, advocates for a ban on the use of PFAS, widely used manmade chemicals that are also found in water. PFAS are known for being extremely persistent in the environment and for having potentially harmful effects on human health. We talked to EurEau’s Oliver Loebel and Sébastien Mouret about why ‘clean-up’ measures proposed in the new Water Resilience Strategy may not be enough to eliminate PFAS and about what they expect from the Strategy in general.
How do you assess the Water Resilience Strategy (WRS) and what are your expectations? What are your main objections?
It is very positive to see a truly holistic approach to water resilience in this Strategy. In the water sector, water resilience is our full-time job, but we cannot achieve it all on our own – households and services only account for 13% of water consumption, for example. The other 87% go to agriculture, industry and power generation. This is why we were expecting the Commission to respond to the need to mainstream water protection into all policy areas, not just water-focused legislation, and this is what we are seeing with the WRS.
The objective to improve water efficiency by 10% by 2030 is a step in the right direction, but it is regrettable that it wasn’t accompanied by a target to reduce overall freshwater use. Water efficiency should not be a goal in itself but a tool for reducing pressure on Europe’s increasingly stressed water resources.
The WRS also rightly emphasises the link between water quantity and water quality, recognising that we cannot solve water scarcity without addressing water pollution at the same time – but it outlines very few actions to follow up on this assessment. Most pollution-control policies listed in the Strategy are already in place, and on PFAS no control-at-source measures are mentioned at all. We fully support the Commission’s call for better implementing existing legislation, but more is needed.
Finally, it is good to see the water sector’s important investment needs recognised in the Strategy. The renewed emphasis on directing available EU funds towards water infrastructure is welcome, and raises our expectations for the place given to water in the next Multiannual Financial Framework.
In light of that, it is essential to ensure that the Extended Producer Responsibility (EPR) scheme under the revised Urban Wastewater Treatment Directive is fully established and delivered on schedule. Wastewater treatment operators need to plan investments well in advance and rely on both regulatory and financial certainty. Therefore, the newly announced assessment of EPR-related costs in the Water Resilience Strategy must not delay the scheme’s implementation. EPR is crucial for enabling the additional treatment required under the new directive. Polluters must pay for the pollution they cause. Otherwise, the Water Resilience Strategy will fail to support the needs of water services.
EurEau advocates for a prompt and far-reaching PFAS ban instead of ‘clean-up’ measures, such as those outlined by the WRS. Could you explain the importance of this ban for public health and the potential consequences of not implementing it?
PFAS are ‘forever pollutants’, most of which do not break down naturally. If we keep using them, the levels of contamination in the environment will keep increasing. What is problematic about the approach outlined in the WRS is that it strongly focuses on clean-up measures. It is unrealistic to think that we can decontaminate thousands of square kilometres of farmland to keep PFAS out of our food products. And it is virtually impossible to decontaminate our aquifers. It may take decades until a polluted groundwater body recovers from PFAS pollution.
Clean-up measures will not solve the PFAS problem and will expose our children and grandchildren to unacceptable pollution levels. The health risks related to this exposure are well documented and range from impacts on the immune system to cancer.
At least in theory, we have the technologies to remove all PFAS from raw drinking water, although this entails massive economic and environmental impacts. But how will we remove PFAS from our food? After all, the vast majority of human PFAS intake comes from sources other than drinking water – between 73% and 94%, according to figures from the Netherlands.
It may sound dystopic but due to PFAS pollution, certain health authorities advise against the consumption of eggs from chickens living in private backyards. They also advise parents not to let their children play with sea foam. This can’t be the future we all want.
While water operators will take all measures to protect public health and the environment, the only sustainable way to address the PFAS crisis is to stop using these substances. We are disappointed that the WRS does not mention the tremendous work of the European Chemicals Agency ECHA in the context of the Universal PFAS restriction proposal. Moreover, the WRS falls short of announcing a ban of all non-essential PFAS uses as stated in the Chemicals Strategy for Sustainability
On the other hand, PFAS are used because they offer specific properties. Replacing them can be challenging. Innovative European companies work on PFAS-free alternatives, and it is encouraging to see that many less hazardous substitutes have already been identified. A clear phase-out pathway will help these companies to bring their solutions to the European and to international markets.
We should also recognise that alternatives may not be available today for certain uses which are critical for society. In such cases, time-limited derogations could be envisaged, accompanied by strict risk management measures.
This exercise is currently underway at ECHA. We therefore hope the European Commission will restrict PFAS uses based on the ECHA recommendations.
The Forever Pollution project estimates that decontaminating Europe could cost up to €100 billion per year if PFAS are not banned. How does EurEau assess the economic impact of focusing on remediation instead of control-at-source measures?
These figures represent a worst-case scenario. However, such a scenario can no longer be excluded given the rapidly increasing TFA concentrations in soil and water, and the continued resistance against a rapid PFAS phase out.
The overwhelming part of this amount would fall upon the shoulders of water operators and the municipalities who own the infrastructure. Ultimately, these costs would need to be passed on to the water consumers, thus jeopardising the affordability of water services. With a view to avoiding such a situation, we call on decision makers to implement the polluter-pays principle for all continued PFAS emissions.
We are convinced that a PFAS phase-out is cheaper overall than trying to fix the problem ‘at the end of pipe’.
The strategy seems to overlook wide-spread soil pollution. What steps should be taken to address soil pollution comprehensively within the framework of the Water Resilience Strategy?
Healthy soils are a prerequisite for health drinking water reserves and sustainable food production. A couple of years ago, we had high expectations for what the Commission at that time said would be a European Soil Health Law to address this problem. In the end, what the Commission proposed was a Soil Monitoring Directive with a much reduced scope. The co-legislators are finalising its adoption now, having removed most of the few provisions in it that could have actively improved soil health, rather than just monitor its decline. Although EU-wide monitoring requirements are better than nothing, we see this text as a missed opportunity to tackle soil pollution.
As the Strategy points out, much could be achieved by fully implementing existing legislation including the Nitrates Directive and the Regulation concerning the placing of plant protection products on the market. It is unacceptable that we still find excessive contamination levels in the groundwater bodies of many European regions.
Soil pollution is also caused by contaminants contained in rainwater. According to the German environmental agency UBA, every litre of rainwater now contains on average 335 ng/L TFA, an ultrashort-chain PFAS, mainly stemming from fluorinated gases. As outlined above, no remediation measure can solve that problem.
Achieving water resilient societies is a complex endeavour that requires close cooperation and strong governance. The water sector is willing to step up its own efforts and work with all societal stakeholders to ensure that future generations will have access to sufficient quantities of clean water.
Oliver Loebel is Secretary General and Sébastien Mouret is Policy Officer at EurEau, the European Federation representing national drinking and wastewater service providers from 33 countries, spanning both public and private sectors. EurEau unites water professionals to shape European policies on water quality, resource efficiency, and access to water. EurEau took part in the EESC’s Consumer Day 2024 that focused on water.