Unpacking Flawed Data behind UWWTD
The revised Urban Wastewater Treatment Directive (UWWTD), which entered into force on 1 January 2025, aims to protect human health and the environment from the effects of untreated urban wastewater. It requires Member States to ensure that towns and cities properly collect and treat wastewater cost-effectively.
UWWTD assigns the entire financial burden of upgrading urban wastewater treatment plants to only two sectors, pharmaceuticals and cosmetics. This is based on the European Commission’s Impact Assessment, which evaluates the contribution of the cosmetics industry to urban wastewater micro-pollution at 26%.
However, this figure simply does not stand up to scrutiny once the underlying data is reviewed. The Commission’s Impact Assessment wrongly allocates to the cosmetics industry:
- substances banned in cosmetics, such as nonylphenol diethoxylate;
- substances not used in cosmetics, such as the insecticide permethrin;
- ubiquitous substances allocated exclusively to cosmetics, for example palmitic acid, a common dietary fat found in dairy, meat, and many vegetable oils.
On top of that, the Impact Assessment uses an overly simplistic method, assigning each substance’s entire toxic load to just one sector, even when it is used in several.
Once these data flaws are corrected, the estimated contribution drops by orders of magnitude.
Independent analyses by DHI, ECT Oekotoxikologie, Ricardo, and Cosmetics Europe’s own verification consistently show that cosmetics are a minor source of toxic load in urban wastewater. Under realistic “main‑use” assumptions, the contribution of cosmetics is typically around 1-2% – roughly 15 times lower than 26%. ECT’s review points to about 0.2%, i.e., close to a hundred times lower than the original figure. Even a very conservative upper‑bound scenario by Ricardo, which still gives cosmetics half of the impact of every reviewed multi‑use substance, comes out at about 4.29% – still several times lower than 26%.
None of these analyses comes even close to the original Commission’s estimation which is a substantial overestimate of the industry’s contribution to the urban wastewater pollution, off by at least an order of magnitude under realistic assumptions.
All evidence indicates that cosmetics account for a very small share of the toxic load from micropollutants in urban wastewater – likely around, or below, 1-2%. If the Polluter Pays Principle is to be applied correctly under the UWWTD, EPR should therefore be substance‑based and sector‑agnostic, not built on a flawed allocation that blatantly overstates the contribution from cosmetics.
