On 26 October 2022, the Commission published a legal proposal for the revision of the List of Groundwater and Surface Water Pollutants, thereby also setting surface water threshold values for glyphosate.
In the meantime, the process for the review of the Environmental Quality Standards (EQS) for glyphosate is still ongoing, as provided in the Water Framework Directive (WFD; 2000/60/EC).
The glyphosate EQS has been reviewed by the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) following a mandate by the Commission. The SCHEER published its preliminary opinion on 30 September 2022, following which the GRG submitted its comments, available to download via this link.
The final opinion, which would form the basis for the Commission proposal, has not yet been published by SCHEER.
Publishing the proposal for the revision of the List of Groundwater and Surface Water Pollutants and setting threshold values for glyphosate while the process for the review of the EQS for glyphosate is still ongoing is considered by the Glyphosate Renewal Group (GRG) as procedurally flawed.
Furthermore, the Commission proposes two additional values for glyphosate of i) 0.1 ug/L “for freshwater used for the abstraction and preparation of drinking water” and ii) 86.7 ug/L “for freshwater not used for the abstraction and preparation of drinking water”.
The value of 0.1 ug/L in surface water is unique to Glyphosate and the first case of its kind.
The point of compliance (the point at which a threshold of 0.1 ug/L for freshwater is applicable) is defined under the EU Drinking Water Directive ((EU) 2020/2184, Art. 6) as the point at which the water emerges from the tap of the consumer.
Not only is this proposed value lacking the necessary science base, and the point of compliance established under the WFD, but it also ignores the proven high removal efficiency of Glyphosate during standard European water treatment by applying it to raw water for which EQS are set.
As such, the GRG believes that the value of 0.1 ug/L threshold should be deleted from line 60 of the EQS table for Glyphosate. The setting of a QSdw,hh for glyphosate sets an unnecessary precedent for priority substances, which will lead to ambiguity and additional costs for water management in Member States (MS).
Where MS do not abstract drinking water from surface water, a *QSdw,hh for glyphosate will not be required at all. Where abstraction of surface water for the production of drinking water takes place, a water treatment factor should be applied to the derivation of any QSdw,hh.
For glyphosate, this can be set at **10.0 µg/L, given the very high efficiency of treatment methods in place, and as it is allowable for MS to reduce the treatment factor as appropriate to their local water treatment plant conditions.
The very high compliance of real-world drinking water monitoring data strongly suggests that it is unnecessary to set a QSdw,hh for glyphosate for the abstraction of surface water for the generation of drinking water. There is a strong risk that this new requirement would unnecessarily increase workload and costs for water management in MS with no added benefit to the consumer or the environment.
*A specific threshold QSdw,hh is proposed by the EU COM for surface freshwater used for the abstraction and preparation of drinking water.
**This value of 10.0 µg/L for glyphosate in surface water is based a treatment efficiency of 99% (for chemical methods like chlorination). Compliance with 10.0 µg/L at the point of drinking water abstraction would thus allow for compliance with the threshold of 0.1 µg/L in finished tap water as defined under the EU Drinking Water Directive.