Brussels, October 2025
The cosmetics industry fully understands the importance of ensuring clean urban wastewater in Europe. Therefore, we support the objectives of the Urban Wastewater Treatment Directive (UWWTD) as well as the Extended Producer Responsibility (EPR) scheme principle, where it is for all producers of products which contain micropollutants to contribute to the cost of necessary improvements to the wastewater facilities in accordance with the Polluter Pays Principle.
Contrary to what the European Federation of National Associations of Water Services, EurEau, seems to suggest in their recent position paper, we have always been and still are ready to pay our fair share. We do not expect any other stakeholder to pay our contribution, when fairly calculated. However, what we cannot accept is that that the Directive manifestly overestimates the contribution of cosmetics to the toxic load in urban wastewater by at least 15 times. When the Commission’s own data is correctly assessed, cosmetics account for only 1.54% of the total toxic load, not 26%.
The Commission’s impact assessment on which the UWWTD re-cast has been based on attributes to our sector a number of substances that are either not used in cosmetics or even banned for such use. Some substances have also been attributed exclusively to our industry, while they are widely used by other sectors too (see the CE analysis here).
For the EPR system to work properly, it needs to rely on correct data and a fair application of the Polluter Pays Principle. As this is not the case today, we urge the European Commission to reassess the current EPR scheme. We cannot be incentivised to reduce the emission of substances that we in fact do not emit. We call for a substance-based and sector-agnostic model with an EU harmonized and positive list of micropollutants.
Tackling urban water pollution effectively requires addressing everybody who contributes to it. Therefore, developing an EPR scheme that includes ALL the relevant industries and incentivises them all to eco-design, is absolutely critical. If the EU is serious about fighting water pollution, the change is needed swiftly, otherwise the efforts undertaken will lack desired impact.