UBA Position on EU minimum requirements for Water Reuse

Wasserwiederverwendung mit möglichen Risiken für die Umwelt und die menschliche Gesundheit einherClick to enlarge
Wasserwiederverwendung geht mit Risiken für die Umwelt und die menschliche Gesundheit einher.
Source: Jörg Rechenberg / UBA

The EU Commission is seeking to adopt EU wide minimum quality requirements for water reuse for agricultural irrigation and groundwater recharge by the end of 2017. As the current draft falls short to set standards that are rigorous enough to protect the environment and human health, UBA has published a Scientific Opinion Paper to express its concerns and recommendations.

The European Commission’s (COM) activities to foster the reuse of treated urban wastewater are stipulated in the EU action plan for the Circular Economy.

Water reuse is considered a beneficial option in situations of water scarcity after efficiency measures have been exhausted. However, reuse comes at a risk – depending on the source of the waste water and its level of treatment excessive nutrients, microbial and chemical contaminants can enter soils, groundwater, drinking water and food crops and thus being not only a concern for the environment but also for human health, including consumers of imported crops produced with reclaimed water.

The need for ambitious minimum requirements

The Joint Research Centre (JRC) has been commissioned by the European Commission to suggest standards that can serve as a basis for the legislative proposal planned for the end of 2017. So far, the drafted requirements hardly exceed already existing EU regulations and mostly remain too vague to set a common European approach and are thus not sufficient to minimize risks to a common tolerable risk level. 

Minimum quality requirements need to be based on a common systematic and comprehensive risk management approach that follows the precautionary principle. Standards need to include pathogens, nutrients, inorganic as well as organic chemicals while giving appropriate attention to contaminants of emerging concern, disinfection by-products and antibiotic resistances. In order to ensure that soils, groundwater, drinking water and food products are protected from contaminants and pathogens advanced treatment of urban waste water is needed. EU minimum quality requirements should clearly express that. 

It should further be reflected that the need for reuse highly differs within the EU. For Member States without water stress the risks, additional costs, energy and infrastructure requirements resulting from reuse are likely to outweigh the benefits. Therefore, any European instrument on this issue should leave flexibility to the Member States to refrain from practicing water reuse at all or to set more stringent standards. UBA opposes the idea of a binding EU regulation – instead we see a non-binding guidance document to be more suitable that complements the existing EU legislation.