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Have your say response to the consultation of the Water Framework Directive in April 2026

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The Chemical Industry Federation of Finland welcomes the opportunity to provide feedback on the targeted revision of the EU Water Framework Directive (WFD). We support a practical, proportionate and evidence-based review that maintains a high level of water protection while improving legal certainty, strengthening Europe’s resilience, and enhancing the predictability of the investment environment. Clean and sufficient water is of strategic importance for industrial production, innovation and the green transition. The chemical industry is both a major user of water and an important provider of solutions, including water-treatment chemicals, cleaner industrial processes and improved water recycling. At the same time, the sector is directly affected by the WFD through environmental permitting, emission limits and monitoring obligations. It is therefore essential that the Directive continues to safeguard water resources while also enabling sustainable investment and technological renewal across sectors.

In the context of this consultation, the Chemical Industry Federation of Finland therefore urges the Commission to consider the Water Framework Directive more broadly than solely from the perspective of the RESourceEU initiative. Sectors other than mining, minerals and refining also need to operate in or near water bodies and are therefore directly affected by what the Directive enables and what it restricts. The Federation also wishes to underline that it shares the EU’s objective of achieving good water status. Clean and sufficient water is a critical raw material and process medium for the chemical industry as well.

Below we describe some of the challenges we see with the current Water Framework Directive, and at the end of the document you find our solutions to these challenges.

1) Reduced permitting certainty

The non-deterioration principle under the Water Framework Directive may prevent a permit from being granted even where a company complies with all emission limit values. A company may be held responsible for the status of a water body even though that status is also affected by diffuse pollution and other operators. This undermines the predictability of investments, including projects related to the green transition.

Case Siilinjärvi: Yara Siilinjärvi, a member company of the Chemical Industry Federation of Finland, provides an example of the imbalance between diffuse pollution and permitted industrial activity. There are two classified water bodies within the area of influence of the site: Kuuslahti and Sulkavanjärvi. Kuuslahti is currently classified as being in good status, while Sulkavanjärvi is classified as being in moderate status, and its primary production has been assessed as being phosphorus-limited. According to water monitoring results, Yara Siilinjärvi’s phosphorus load to Sulkavanjärvi has in recent years been estimated at less than 10% (based on the water monitoring data from the extensive 2022 monitoring programme). Even if the site’s load to Sulkavanjärvi were to cease entirely, this alone would not improve the status of the lake. Improving the status of Sulkavanjärvi would require a joint project by operators in the catchment areas to reduce the phosphorus load entering the lake. Yara Siilinjärvi is the only major industrial operator in the catchment area that is subject to an environmental permit, but it cannot by itself influence the development of Sulkavanjärvi’s status. For this reason, increased cooperation among operators in the catchment areas would be desirable.

However, improving the status of the water body even through cooperation among operators would be a time-consuming undertaking, and the significant internal loading that has been identified slows recovery. At present, achieving the environmental objective by 2027 therefore appears unlikely in the case of Sulkavanjärvi. This may lead to an unreasonable allocation of responsibility to a single operator in a situation where agriculture and forestry are nevertheless considered to be the largest sources of phosphorus loading to the lake.

2) Tightening of environmental quality standards (EQS) and the use of substance groups
  • The list of priority substances has been expanded (PFAS, bisphenols, pharmaceuticals), and aggregate limits for groups of substances have been introduced, which may go beyond the company’s own sphere of influence. This creates a risk of regulation that is not proportionate to the local environmental risk.
  • With the broader application of the precautionary principle, substances that are not included on risk substance lists may also become obstacles to permitting, even where there is no scientific evidence demonstrating that they pose a risk.
    • The share and source of diffuse emissions in the overall pollution load remain unclear in situations where the total load nevertheless has a significant impact on the ability of permitted activities to operate near a given water body.
    • The recognition and treatment of background concentrations vary by region, and background concentrations should be taken into account consistently across different regions.
3) Overlapping regulation
  • The requirements of the Water Framework Directive overlap with those of the Industrial Emissions Directive (IED) and the REACH Regulation.
    • A company may comply with BAT requirements and still face additional obstacles due to interpretations of the Water Framework Directive (WFD).
    • The existing overlap between the IED, REACH and the WFD increases the administrative burden without delivering a clear environmental benefit.
4) Increasing monitoring and reporting obligations
  • As a result of the above-mentioned legislation, the number of substances to be monitored and the frequency of reporting are increasing. At the same time, monitoring methods are not yet fully standardised. This increases the cost burden, particularly for installations whose emissions are already very low.
    • At the same time, however, the growing monitoring and reporting obligations do not make it possible to identify the origin of substances entering water bodies through diffuse pollution, nor do they make it possible to reduce them. As a result, the total pollution load affects the industrial operator’s ability to operate with disproportionately high weight.
5) Insufficient transition periods and flexibilities
  • Although the Directive allows for derogations and deadline extensions, their application is inconsistent. This is challenging, as industrial investments require long time horizons and predictable rules.
6) Inconsistent interpretation and lack of guidance in permitting procedures
  • The interpretation of key concepts under the Water Framework Directive (for example, the significance of impacts and the status of a water body) varies between authorities and regions. Operators do not always have sufficient information about all the flexibilities and legal “tools” permitted under the Directive, such as the use of mixing zones or alternative definitions. At the same time, authorities often take the view that they cannot actively guide or advise operators on how to make use of the appropriate procedures, applications or legal options. This means that permit applications may fail to identify or make use of critical possibilities, even where these are permitted under the legislation. The result may be an unnecessarily negative permitting outcome or a prolonged process without any additional benefit for water protection.
    • It is essential to maintain a risk-based approach as the foundation of the assessment, taking diffuse emissions into account.
7) Reassessment of the producer responsibility system

The producer responsibility system proposed under the Urban Wastewater Treatment Directive is, in principle, based on incorrect information, and responsibility has been assigned to only two sectors: cosmetics and pharmaceuticals. In order for the producer responsibility system to operate in accordance with the polluter pays principle, and to be proportionate, fair and functional, it should still be reassessed. To this end, it is necessary to analyse which substances are actually found in urban wastewater after existing wastewater treatment processes, and then assess where those substances originate from before entering the water.

The chemical industry proposes that the targeted revision should:
  • Modernise the assessment of chemical status by making it more nuanced and more risk-based;
  • Clarify the application of the non-deterioration principle and the one-out, all-out (OOAO) principle in permitting procedures, including how benefits across different environmental media should be taken into account;
  • Broaden and streamline the use of derogations under Article 4(7) so that local conditions, background concentrations, diffuse pollution, technical feasibility and water-saving measures are better reflected in decision-making;
  • Allow proactive and procedural guidance by competent authorities during permitting procedures, so that operators can identify, already at the application stage, the solutions and flexibilities available under the legislation;
  • Assess the cumulative burden of water-related regulation, including the combined effects of the Water Framework Directive, the Industrial Emissions Directive and other water legislation, such as the Urban Wastewater Treatment Directive, which includes extended producer responsibility.

In conclusion, the Chemical Industry Federation of Finland considers that the targeted revision of the WFD should focus on improving workability, coherence and predictability without lowering environmental ambition. A well-functioning framework should make it possible to protect water resources effectively while also supporting innovation, circularity, industrial transformation and Europe’s long-term competitiveness.

We therefore encourage the Commission to ensure that the forthcoming revision strengthens both environmental outcomes and the practical implementation of the Directive across Member States.

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