Submission to the European Commission Call for Evidence on the Revision of the Water Framework Directive (WFD)

ClientEarth welcomes the opportunity to provide input on the potential revision of the Water Framework Directive (Directive 2000/60/EC, WFD), a cornerstone of EU environmental law and a central instrument for the protection of freshwater ecosystems as well as the resilience of the economy of the European Union. As set out in the attached document, we consider that revising the directive in the absence of clear evidence risks undermining legal certainty, weakening environmental protection and compromising the achievement of the directives objectives.

The Water Framework Directive remains one of the most important instruments for protecting Europes water resources and ensuring long-term economic resilience. Reopening it disregards the current scientific evidence and would shift environmental, social and economic costs onto society. The priority should therefore be clear: to implement, enforce, and strengthen rather than reopen and weaken the existing framework. Support should be provided to Member States and local authorities responsible for water management through targeted EU funding, technical guidance, and capacity-building. If any legislative action is pursued, it should be strictly limited to:

• clarifying existing provisions;
• ensuring coherence with sectoral legislation, such as providing clarity on how CRMA provisions may impact the Water Framework Directive;
• and reinforcing environmental safeguards to support implementation.

ClientEarth calls on the Commission to ensure full compliance with the Better Regulation Guidelines by carrying out a comprehensive and transparent impact assessment that rigorously analyses the environmental, social and economic consequences of any potential revision, as well as ensures meaningful and balanced stakeholder participation throughout the process.