On 14 October 2024, the General Secretariat of the Council circulated Germany's detailed comments on the European Parliament's proposed amendments to EU water legislation on priority substances, following a Working Party on the Environment meeting on 3 September 2024. Germany provided a table of positions on 130 amendments to the Water Framework Directive (2000/60/EC), Groundwater Directive (2006/118/EC), and Environmental Quality Standards Directive (2008/105/EC).
Germany broadly rejects amendments that would introduce delegated acts for setting environmental quality standards (EQS), citing concerns over outdated data and scope. Specifically, it opposes amendments 24, 35, 64, 97, 98, 101, 120, and 121, arguing that the Commission should not be empowered to adopt delegated acts for EQS without sufficient scientific basis. Germany also objects to amendments 4, 5, 6, 9, 13, 17, and 38, which it considers based on outdated data, and amendments 15, 16, 40, and 46, which it says exceed the directive's scope.
Conversely, Germany supports amendments that align with existing EU law or promote modernisation. It backs amendment 59, which links priority substances to the Drinking Water Directive, amendment 65 on digitalisation of environmental monitoring, amendment 78 to delete obsolete annexes, amendment 79 prioritising source measures for groundwater protection, and amendment 82 on public information. On several other amendments, Germany is partially supportive or neutral, including those on effect-based trigger values (58), watchlist mechanisms (85, 86), and reporting frequencies (114).
The comments reflect Germany's cautious approach to expanding EU regulatory powers via delegated acts, while endorsing targeted updates that improve efficiency and coherence with existing directives. The Council is expected to continue discussions on the file, with the European Parliament's position already adopted in first reading. The next steps will involve trilogue negotiations between the Council, Parliament, and Commission to reconcile positions on the priority substances package.