Brussels, 21 May 2025 – In the light of new data released by the European Commission following a request for access to information, Cosmetics Europe re-affirms that the revised Urban Wastewater Treatment Directive (UWWTD) manifestly overestimates the contribution of cosmetics to the toxic load in urban wastewater by at least 15 times.
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Cosmetics Europe calls for UWWTD to be re-assessed in the light of new evidence provided by the European Commission
- Last updated: May 21, 2025
Cosmetics industry stresses the need for a substance-based and sector agnostic Extended Producer Responsibility (EPR) scheme.
“Our industry fully supports the overall objective of the directive and the EPR principle proposed. We want to pay our share. We cannot, however, accept such a blatant miscalculation of our contribution to the toxic load. The documentation provided to us by the European Commission clearly shows that the Impact Assessment based on the JRC list, wrongly allocates to our sector a number of substances that are either not used in cosmetics (e.g. permethrin, an insecticide killing lice and mites), or in some cases are even banned for such use (e.g. nonylfenoldiethoxylaat). Other substances have been attributed to exclusively our industry, while they are widely used by other sectors too. Palmitic acid commonly found in animal and vegetable fats like butter or olive oil, is one example of this” – said John Chave, Director General of Cosmetics Europe. “When correctly assessed, cosmetics account for only 1.54% of the total toxic load not 26%. Legislation cannot be based on mistakes of this magnitude, mistakes that have also seriously damaged our industry’s reputation” – he added.
Cosmetics Europe strongly calls for a re-assessment of the EPR scheme financing the upgrading of the wastewater treatments plants in Europe, based on accurate data and a fair application of the polluter pays principle. The introduction of a substance-based and sector agnostic model through an EU harmonized and positive list of micropollutants, combined with harmonized implementation methodologies, would incentivize all companies to eco-design.
The EPR scheme as defined today leaves no scope for correcting the contribution from cosmetics. This is because the current EPR scheme is not substance, but sector based and identifies only two sectors.
The recast of the UWWTD, which entered into force on 1 January 2025, aims to tackle water pollution and guarantee cleaner water to European citizens. The new rules agreed introduce an EPR scheme for only two sectors, pharmaceuticals and cosmetics, that are called upon to financially contribute at least 80% of the costs of the upgrade of wastewater facilities to quaternary treatment stage.
The European Commission’s Impact Assessment has been based on the Joint Research Center (JRC) database of substances found in urban wastewater as referenced in the EPR feasibility report1. On 17 April 2025, the European Commission provided Cosmetics Europe with new elements on the methodology used in their assessment and granted access to the JRC database of substances found in urban wastewater. You can find the full Cosmetics Europe analysis of the JRC list as used in the EPR feasibility report, here.
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1 “Feasibility of an EPR system for micro-pollutants” (Bio Innovation Study, link to Final Report, 4th March 2022)
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Background information:
About Cosmetics Europe
Cosmetics Europe is the European trade association for the cosmetics and personal care industry. For more than 60 years, Cosmetics Europe has been the voice of the cosmetics and personal care industry in Europe. Our members include cosmetics and personal care manufacturers as well as associations representing our industry at national level, right across Europe. For more information, please consult Cosmetics Europe website.
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