Domingo Zarzo Martínez
Sacyr Water Director of Strategic Projects, Communications, and Institutional Relations
Sacyr Agua
Directive (EU) 2024/3019 on urban wastewater treatment was published in the Official Journal of the European Union on December 12, 2024. It requires Member States to transpose the new rules into national legislation within 30 months, by July 2027. In Spain, the first steps are already underway through a draft law submitted for consultation in June 2026.
The Directive marks a major shift for wastewater treatment. It promotes water reuse, sets a 2045 decarbonization target for the sector, and expands the requirements of the previous 1991 directive, both in terms of the size of municipalities covered (>1,000 inhabitants) and the quality standards they must meet. It also introduces advanced treatment processes, known as quaternary treatment, to remove contaminants of emerging concern (CECs), including pharmaceutical residues, personal care products, drugs and other substances, with part of the cost to be covered by the producers of those products.
This is where the Directive introduces the concept of Extended Producer Responsibility (EPR). Under this approach, the pharmaceutical and personal care product industries will be required to finance at least 80% of the cost of implementing treatments designed to remove CECs, in line with the “polluter pays” principle.
Each EU Member State will have to design and implement its own EPR scheme for this purpose. In practice, this means there will not be a single Europe-wide model; each country will adapt the system to its own legal and administrative framework.
The funds collected will be earmarked to cover the capital and operating costs associated with installing and maintaining quaternary treatment systems at wastewater treatment plants. The Directive also encourages these fees to be “modulated,” meaning they may vary according to the hazard, persistence or volume of micropollutants contained in each product. This should encourage producers to design and market products with a lower environmental impact.
Several pharmaceutical companies have challenged the EPR regime, arguing that it unfairly penalizes the sector and lacks sufficient empirical rigor and proportionality. Over the coming months and years, we will see how these responsibilities are defined in practice and how Spain shapes and implements its own EPR framework. It is also likely that industry will pass part of these costs on to the final price of products, although the EU’s objective is for any impact to be proportionate and to encourage innovation toward more sustainable products.
A similar concept, although in a different area of water management, can be found in Spain’s new Royal Decree 1085/2024 on water reuse. For the first time, it opens the legal door for industries and private companies in Spain to finance water treatment or reuse infrastructure to offset their water footprint and move toward the concept of being Water Positive. It could also create new opportunities for public-private partnership models in water infrastructure, which, unlike in other countries, remain relatively uncommon in Spain.
Water Positive
Many of the world’s largest corporations—including Amazon, Microsoft, Google, Coca-Cola and Tesla—have committed to becoming Water Positive by 2030. Technology companies, among the largest consumers of water because of their data centers, are already making significant investments in this area.
For example, Amazon Web Services has committed €17 million to the Government of Aragon to offset the water footprint of its new data centers under construction, while Microsoft is also financing irrigation improvements for farmers in Spain and projects to reduce losses in municipal drinking water networks.
Sacyr Group is already Water Positive. Since 2022, our water footprint has been measured and certified under ISO 14046. Thanks to our production of desalinated and reused water, we have a positive net water balance across the Group, in every country where we operate and across all our activities: we produce more water than we consume.
Together, these new regulations open up significant investment and business opportunities for Sacyr in Spain and across Europe. In Spain alone, the Ministry for the Ecological Transition and the sector’s main associations estimate that €24.5 billion in investment will be needed to comply with the new Urban Wastewater Treatment Directive.
Sacyr is well positioned to take on these challenges and investments. As early as 2015, Sacyr Agua built the advanced treatment system at the La Gavia wastewater treatment plant in Madrid, which we also operate today. With a capacity of 1 m³ per second, it is one of the largest facilities of its kind in Spain. We have also carried out numerous innovation projects, including pilot tests of different technologies to remove emerging contaminants and microplastics.
In the same way, Sacyr Agua has promoted the Water Positive approach from the outset and has defined a strategy to address this emerging market, identifying potential internal offset projects that can be offered to companies and industrial clients.
