Cosmetics Europe is profoundly disappointed that the European Commission has once again overlooked the critical need to address the flawed data and disproportionate approach underpinning the Urban Wastewater Treatment Directive (UWWTD). This oversight represents a significant missed opportunity to establish a truly fair and effective EPR framework, jeopardizing the Directive’s effectiveness and its overarching goal to combat water pollution.
In parallel to the Omnibus package, the European Commission released today the updated study on the costs of the EPR system under the recast UWWTD and its potential impact on the concerned sectors. Our initial analysis of the study confirms significant discrepancies between the Commission’s estimates – systematically much lower – and existing assessments from Member States and industry experts.
The study does not rectify or even address the manifest error in assessing the cosmetics sector’s contribution to the toxic load in urban wastewater, which is overestimated 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%. This is consistent with independent analyses from ECT Oekotoxikologie GmbH and the Danish Hydrological Institute (DHI), which also indicate the contribution is less than 2%.
The urgent correction of these significant data flaws and a fair application of the Polluter Pays Principle are critical for an effective and workable EPR scheme that incentivises eco-design for all contributors to urban wastewater pollution.
The cosmetics sector urgently calls for corrective measures to ensure data accuracy and create a fair, effective system to tackle water pollution. Our commitment remains to contribute our fair share under a framework that accurately reflects the cosmetic industry’s impact.