Opportunities to tackle antibiotic resistance development in the aquatic environment through the Water Framework Directive

Antibiotics are critical components of modern health care. Protecting their efficacy through managing the rise in antibiotic resistance is therefore a global concern. It is not known to what extent environmental pollution from antibiotics contributes to the development of resistance, but encountered concentrations are frequently above concentrations predicted to select for resistance. Hence, measures are needed to manage risks. Here, we analyse if the indirect health risks from antibiotics in the aquatic environment can be considered in the context of the EU Water Framework Directive and the setting of environmental quality standards (EQS). By scrutinising current legislation, we conclude that it is possible to take the indirect health risks from antimicrobial resistance into account when deriving EQS for substances with antibiotic activity. We base this on the following conclusions: (1) human health concerns can be the main driver when setting an EQS, (2) an EQS can be based on data not specified in the guidance document, and (3) there are no restrictions against establishing EQS using data on antimicrobial resistance properties. In addition, since antimicrobial resistance travel across borders, we see strong reasons to prioritise setting these EQS on the EU level over the national level. Even though there is no agreed-upon method for how to develop EQS protective against resistance selection, there are several suggestions available in the literature and a couple of examples of regulatory initiatives. Also, addressing antimicrobial resistance through the Water Framework Directive can act as a driving force for other applicable legislation where such risks are not considered. We end by providing a set of recommendations for the European Commission and the Members States' future work on addressing aquatic pollution and antimicrobial resistance.