A shift in focus on water reuse based on risk management, quality, and adaptation to each use.

Royal Decree 1085/2024: new water reuse regulation
in Spain

The Royal Decree 1085/2024, published on October 22, 2024, replaces the previous Royal Decree 1620/2007 and redefines the regulatory framework for reuse in Spain.

Beyond a technical update, the new regulation introduces a shift in approach: moving from a model based on fixed quality parameters to an approach supported by risk management, aligned with the Regulation (EU) 2020/741 and with a more integrated vision of the efficient use of water resources.

From quality to risk: the central axis of the regulation

The main novelty of the decree is the mandatory incorporation of the Reclaimed Water Risk Management Plan (PGRAR), which becomes the central element to ensure the safety of reclaimed water use.

This approach obliges the evaluation not only of the water quality itself but also of actual use conditions, exposure, potential environmental impacts, and necessary control barriers for each application.

• Health risks: evaluation of exposure and necessary controls to protect health.
• Environmental impacts: analysis of the application environment and potential effects on the environment.
• Specific usage conditions: each purpose requires different requirements and management measures.
• Barriers and control measures: the system must be designed and managed to continuously reduce risk.

In practice, reuse is no longer interpreted as a simple analytical compliance and becomes understood as a managed system, where design, operation, control, and monitoring are closely related.

New quality classification and adaptation to uses

RD 1085/2024 introduces a more detailed classification of the quality of reclaimed water, with different classes linked to the intended use and associated exposure level.

Quality classes: A+, A, B, C, D

Each class is related to factors such as:

• Level of human exposure
• Type of user
• Risk associated with the final use

This allows for a more tailored application to each case, avoiding uniform approaches and favoring technical solutions more consistent with the destination of reclaimed water.

Strengthening of controls and responsibilities

The new regulatory framework strengthens traceability and control throughout the reuse chain, defining more clearly the involved agents and their responsibilities.

• Clear definition of responsibilities: producer, supplier, and end user.
• More demanding analytical control programs: with requirements linked to use and quality class, also incorporating continuous controls of parameters such as flow and turbidity.
• Accredited laboratories: analyses must be conducted in laboratories accredited according to the UNE-EN ISO/IEC 17025 standard.
• Continuous monitoring and validation: control ceases to be occasional and becomes part of the system's management.

Additionally, closer coordination between the various agents is required, increasing operational complexity but also reinforcing the health and environmental guarantees of reclaimed use.

Expansion and consolidation of uses

The decree maintains and develops the previously contemplated uses, incorporating greater technical precision depending on the final destination of the reclaimed water.

• Agricultural uses: especially linked to the European reuse framework for irrigation.
• Urban uses: irrigation, cleaning, and certain non-potable municipal uses.
• Industrial uses: processes and technical applications compatible with the required quality.
• Recreational uses: application in golf courses, sports facilities, and other recreational areas for non-potable uses like irrigation and maintenance of green spaces.
• Environmental uses: applications aimed at aquifer recharge or contribution to wetlands and other aquatic ecosystems.

Restrictions remain for uses intended for direct human consumption and for those applications where health risks cannot be adequately controlled.

A more demanding and technical framework

RD 1085/2024 not only expands reuse possibilities but also raises the level of technical and documentation requirements necessary to implement such solutions with guarantees.

• Preventive approach: management anticipates risk, instead of acting only when issues arise.
• Technical justification of use: each application must be evaluated and documented specifically.
• Greater specialization: compliance demands technical knowledge, operational control, and an integrated vision of the project.

This means that reuse stops being a one-time measure to become a strategic technical decision, linked to system design, use context, and continuous risk management.

Implications for the sector

This new regulatory framework generates a double reading for the water sector and for projects seeking to incorporate regeneration and reuse solutions.

Opportunity

• Drives new reuse projects.
• Promotes optimization of water resources.
• Strengthens criteria of sustainability and resilience in different environments.

Technical complexity

• Higher documentary burden.
• Need for risk analysis and validation.
• Coordinated participation of several agents in the reuse chain.

Technical approach: from regulation to solution

• Resource availability analysis: source, quality, and variability of the water to be reclaimed.
• Assessment of final use: real needs, exposure, and quality requirements.
• Treatment design: selection of suitable barriers and technologies for each application.
• Integration of PGRAR from the start: as part of the project's technical approach and not as a subsequent procedure.

Here is where reuse transitions from being a regulatory obligation to a strategic technical decision, with direct implications on the system's viability, safety, and operation.

Regeneration solutions at Envirotecnics

At Envirotecnics, we approach each regeneration and reuse project from a technical perspective, adapting the solution to the available resource, intended use, and the control and safety requirements imposed by the regulation.

Our approach includes:

• Resource and use context analysis: to define the most suitable strategy from the start.
• Design of adapted solutions: dimensioned according to technical, operational, and regulatory needs.
• Integration of treatment technologies: according to the required quality, water destination, and site conditions.
• Implementation and commissioning: with a practical vision of operation and system continuity:
  • Authorization for using reclaimed water with ACA, Public Health, and competent entities
  • Follow-up, operational control, and system quality compliance with the analytical control program and the Reclaimed Water Risk Management Plan (PGRAR).
• Monitoring and technical support: focused on maintaining project performance and safety.