Joint NGO analysis of the European Commission’s proposal for revised list of priority substances for surface and groundwater - Surface water

Elements to be improved The proposal does not fully address the effects of chemical cocktails, even if this was one of the key issues to be resolved by this initiative and despite the commitment of the Chemicals Strategy for Sustainability to “introduce or reinforce provisions to take account of the combination effects in other relevant legislation, such as legislation on water”. [...] This will prolong the review cycle by 2 years, while the fitness check of the WFD concluded that the lengthy process to update the lists of priority substances is one of the reasons the current framework is sub- optimal. [...] 4(5) GWD and comply with the groundwater-related requests in the resolution of the European Parliament concerning the implementation of the water legislation (17/12/2020). [...] This is a roll back as the new Annex III only lists the groundwater quality standards and omits the text of current Annex 1.3 GWD that requires more stringent threshold values to be established where groundwater quality standards could result in failure to achieve the environmental objectives of the WFD for associated surface water bodies. [...] While the EQS for the priority substances for surface water and groundwater come into force 18 months after the adoption of the Directive, member states have until 2033 to comply with the new Environmental Quality Standards.