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UNESDA responds to an EU consultation on a roadmap on the EU environmental law implementation review

UNESDA, jointly with Natural Mineral Waters Europe (NMWE) and the European Fruit Juice Association (AIJN), responded to the European Commission’s consultation on a roadmap on the EU environmental law implementation review.

UNESDA’s comments focus on specific aspects of waste and packaging legislation, including the implementation of the Single-Use Plastics Directive.

We raised concerns about an increasing number of diverging and disproportionate national measures that are being adopted to transpose EU environmental laws. Some of those measures go way beyond the scope of EU legislation, without proper environmental justification, and risk undermining the beverage industry’s transition to a more sustainable and circular economy.

With this contribution, UNESDA calls on the European Commission to address diverging and disproportionate implementing measures in its 2022 environmental law implementation review.

Ambition alone is not enough: Industry needs real measures that support packaging circularity and innovation

June 29, 2026

Ambition alone is not enough: Industry needs real measures that support packaging circularity and innovation

June 29, 2026

Joint statement on harmonised packaging labels

June 14, 2026

Current water challenges

We cannot deny the current water challenges our world is facing. We are experiencing increased water scarcity, with demands for safe, usable water exceeding supply in many areas, including in Europe.

Freshwater use has been growing by about 1% per year since the 1980s and as water demand is expected to continue increasing at a similar rate until 2050, this will account for an increase of 20 to 30% above the current level of water use¹.
This increase in water demand is leading to a reduction of renewable water resources of 24% per capita in Europe².

Around 30% of the European population lives in areas with permanent water stress and up to 70% live in areas with seasonal water stress during summer³.
Europe’s aquatic ecosystems are severely degraded: only 17% of protected river, lake, alluvial, and riparian habitats are in good conservation status and 90% of protected wetland habitats are classified as poor or bad⁴.
Globally, 85% of wetlands have been lost in the last 300 years, with more than 50% lost since 1990⁵. This is particularly critical as wetlands play an important role in filtering water and removing pollutants, as well as providing shelter to wildlife and capturing carbon.

This situation entails severe risks for the world’s population.

For the last decade, the World Economic Forum has placed water-related risks among the world’s top five in its annual Global Risks Report.
Water-related disasters have also dominated the list of disasters over the past 50 years and account for 70% of all deaths related to natural disasters⁶.
Nearly 95% of infrastructure loss and damage reported between 2010 to 2019 were due to water-related disasters⁷.
More frequent and intensive flooding has cost lives and livelihoods across Europe, while at the same time, more than 50% of the continent has, in recent years, been affected by extreme drought conditions, which also breed a range of negative social, economic and human outcomes⁸.

A situation driven by a combination of factors

The deterioration of the natural water cycle stems from a confluence of factors: growing urbanisation, growing populations, increased consumption, poor management, pollution, lack of or damaged infrastructure, and climate change.

Agriculture was responsible for 59% of total freshwater use in Europe in 2017⁹, while industrial and domestic uses are the main drivers of increasing water demand. Indeed, as economies industrialise, populations urbanise and water supply and sanitation systems expand.

Additionally, rising temperatures and more extreme weather patterns are causing more droughts and flooding. Climate variability is also bringing more uncertainty as to the availability, predictability and geographical distribution of water. Water and climate change are inextricably linked. From unpredictable rainfall patterns to shrinking ice sheets, rising sea levels, floods and droughts – most impacts of climate change come down to water (UN Water).

¹ Chart of Global Fresh Water Use 1901-2014 – The Global Education Project

² Water use in Europe — Quantity and quality face big challenges — European Environment Agency (europa.eu)Chart of Global Fresh Water Use 1901-2014 – The Global Education Project

³ Water stress is a major and growing concern in Europe — European Environment Agency (europa.eu)

⁴ Europe’s state of water 2024: the need for improved water resilience | European Environment Agency’s home page (europa.eu)Water stress is a major and growing concern in Europe — European Environment Agency (europa.eu)

⁵ Innovative Solutions Needed for Wetlands in Crisis – SDG Knowledge Hub (iisd.org)

⁶ Water Resources Management Overview: Development news, research, data | World Bank Innovative Solutions Needed for Wetlands in Crisis – SDG Knowledge Hub (iisd.org)

⁷ Water risks and resilience (undrr.org)

⁸ Risks and solutions: how climate change is impacting our water and health | European Environment Agency’s home page (europa.eu)

⁹ Water scarcity conditions in Europe (Water exploitation index plus) | European Environment Agency’s home page (europa.eu)Risks and solutions: how climate change is impacting our water and health | European Environment Agency’s home page (europa.eu)