Environmental Omnibus Package - the EWM expresses its concerns to the EU Commission
To:
European Commission Vice-President Teresa Ribera, Executive Vice President for Clean, Just and Competitive Transition,
Commissioner Jessika Roswall, Commissioner for Environment, Water Resilience, and a Competitive Circular Economy,
Commissioner Valdis Dombrovskis, Commissioner for Economy and Productivity; Implementation and Simplification,
Ms Ilze Juhansone, Secretary-General - Secretariat-General (SG)
November 27, 2025
Subject: Opposition to the Environmental Omnibus Package and the Proposed Dismantling of EU Water Legislation
The European Water Movement (EWM) expresses its deep concern and firm opposition to the direction taken by the European Commission regarding the forthcoming environmental omnibus package, and in particular the proposed weakening or inclusion of the Water Framework Directive (WFD) and the Urban Wastewater Treatment Directive (UWWTD) in this deregulatory initiative.
The EWM is an open, inclusive and pluralistic network of more than fifty organisations from across the European continent. Our members include trade unions, environmental groups, scientists, engineers, researchers, local authorities and river basin managers, public water operators, citizens’ observatories, think tanks and human rights organisations. Collectively, we work toward the recognition of water as a part of the commons, its access as a fundamental universal right, and a resource that must be democratically and transparently managed with strong and efficient public oversight for the benefit of all. The EWM is also part of the international platform The People’s Water Forum, which works closely with the UN Special Rapporteurs on Water and Sanitation, previously Léo Heller and currently Pedro Arrojo-Agudo.
Our position builds on rights recognised at international level by the UN and where the EU is still lagging behind:
- the Human Right to Water and Sanitation (UN, 2010/2015), based on the principles of affordability, safety, sufficiency, acceptability and physical accessibility;
- the same Human Right stated in the very successful European Citizens’ Initiative “Right2Water” (EU, 2012-13) together with the exclusion of water from commodification, liberalization processes and trade and investment agreements;
- the Human Right to a clean, healthy and sustainable environment (UN, 2022);
- and the recognition of the rights of nature to strive for itself.
Despite progress in Europe, access to safe water remains uneven. Fourteen million people in the EU still lack access to safe drinking water, and multiple scandals - whether linked to industrial livestock pollution in Spain, widespread PFAS contamination (France, Italy or Belgium), or other localised crises - underscore serious vulnerabilities. Globally, 2.2 billion people remain without safe drinking water, and the EU has a role to play by paving the way for water protection. At a time of accelerating climate change, Europe cannot afford to undermine the legal foundations that ensure water protection, public health, environmental integrity and social stability.
Human rights and environmental protection are interdependent and it’s the responsibility of elected officials and public servants to guarantee them.
The Environmental Omnibus Package: a regressive step backward and the expression of a democratic backlash
We deplore the on-going train of omnibuses aimed at dismantling social and environmental safeguards, undermining the EU's leader role for more environmental and social justice. The newly adopted Omnibus I degrades corporate due diligence, despite fair and serious doubts of compliance with “Better Regulation guidelines” have been raised by different CSOs/NGOs to the Ombudswoman, who confirmed today maladministration from the EU Commission in the preparation of the legislative proposal.
The on-going dismantling of environmental law under the proposed Environmental Omnibus Package is a worrying departure from the European Green Deal and from long-standing EU environmental principles. Reopening and weakening the Water Framework Directive (WFD) or the Urban Wastewater Treatment Directive (UWWTD) would not modernise EU environmental law: it would roll back decades of progress and diminish Europe’s water resilience, competitiveness, strategic autonomy, food security and defence preparedness - none of which can be achieved without healthy people and healthy ecosystems.
The call for evidence on environmental simplification gathered nearly 200,000 feedback from EU citizens raising their clear opposition against environmental safeguards’ weakening. EU Institutions must respect and listen to citizens’ voices and concerns.
The Water Framework Directive – Cornerstone of water protection and water resilience in the EU
After nearly 25 years of implementation, Europe’s surface and groundwater status shows insufficient improvement, not because the WFD is unfit for purpose, but because of chronic under-implementation and under-enforcement. The 2019 Fitness Check confirmed unequivocally that the WFD is fit-for-purpose and requires better implementation, not deregulation.
Recital 1 of the WFD states clearly that water is not a commercial product like any other, rather a heritage, which must be protected, defended and treated as such. This principle remains essential today and highlights further the need to recognise it as part of the commons (as mentioned several times by the EU Commission itself). The WFD is the cornerstone of freshwater and coastal protection in the EU; without it, the protection of drinking water sources, ecosystems, and clean water for any kind of economic activities would be significantly weakened. Europe’s water resilience - as promoted in the European Water Resilience Strategy - depends on a robust WFD.
Water security is also a factor of peace and social stability. Weakening the EU’s main water law in times of climate-driven droughts, floods and contamination is not only ill-advised: it is irresponsible.
Two core principles of the WFD, in particular, must remain intact:
- The non-deterioration principle: a foundational safeguard preventing further degradation of water bodies. Existing exemptions are already widely used; weakening this principle would enable systemic backsliding.
- The “One-Out-All-Out” principle: an essential expression of the precautionary principle. Downgrading it would mask environmental problems instead of addressing them, and expose people’s and ecosystems’ health.
Diluting these principles would dismantle the WFD’s very essence, and simply means abolishing this regulatory framework and retaining only the paperwork.
The Extended Producer Responsibility (EPR) under the UWWTD must be enforced
The updated UWWTD introduces Extended Producer Responsibility (EPR) for micropollutants - a crucial tool to incentivise addressing chemical pollution at its source and ensure that the responsibles of pollution pay the fair price for the remediation. The Commission’s own assessments show minimal financial impacts on pharmaceutical and cosmetics industries. Yet disinformation campaigns, including misleading claims about essential medicines such as amoxicillin, have been allowed to spread.
The EU must stand firm on the polluter pays principle and on the Treaty obligation to prevent and rectify pollution at source. Rolling back EPR would shift the burden of pollution to citizens and public utilities and contradict fundamental EU environmental law and the EU Charter of Fundamental Human Rights (for instance, art. 37).
We therefore urge the European Commission to:
- Remove the Water Framework Directive and the Urban Wastewater Treatment Directive from the Environmental Omnibus Package;
- Prohibit any regulatory changes (e.g. under the IED, the Nitrates Directive or on permitting) that could impact water protection;
- Uphold and enforce the non-deterioration and one-out-all-out principles;
- Safeguard Extended Producer Responsibility in the UWWT;
- Reaffirm the EU’s commitments under the Green Deal, the Human Rights to Water and Sanitation; and to a Safe, Healthy and Sustainable Environment, along with the protection of water as a commons.
Dismantling Europe’s most important water laws will neither strengthen competitiveness nor support strategic autonomy or food security. It will expose Europe to greater climate risks, environmental degradation, social inequities and public health threats.
Europe needs stronger environmental legislation, not weaker. We call on the Commission to act responsibly, respect scientific evidence, and protect the rights of people and nature.