European Parliament roundtable brings scientific perspective on micropollutant emissions and the design of UWWTD EPR

Scientists, experts and policymakers discussed how the latest research on micropollutant emissions can inform a fair, effective and evidence-based Extended Producer Responsibility (EPR) scheme under the Urban Wastewater Treatment Directive (UWWTD).

The event that took place on 30 September, was jointly hosted by MEP Elżbieta Łukacijewska and MEP Maria Grapini.

The discussion featured:

• Warich Leekitratanapisan, postdoctoral researcher in environmental toxicology at Ghent University;
• Esther Zorzano Walker, Consulting Manager, Energy & Utilities at PwC Spain;
• Simón Gutiérrez, Associate Director and Chemical Safety and Toxicology Manager at WSP;
• Joachim Quoden, Managing Director of EXPRA – Extended Producer Responsibility Alliance; and
• Gerald Renner, Cosmetics Europe Director for Technical Regulatory and International Affairs.

Shared ambition, need for science-based and fair EPR

Opening the discussion, MEP Elżbieta Łukacijewska stressed: “An EPR scheme is a financing tool. It will only work if it rests on sound science about what is in our wastewater, on a clear understanding of where it comes from, and on a fair allocation of costs among those who actually contribute to the pollution.”

MEP Maria Grapini underlined the common objective behind the debate: “We all share the objective of cleaner water and a healthier environment. The question before us is therefore not about the level of our environmental ambition, but about ensuring that the measures we put in place are fair, proportionate and based on sound evidence.”

The discussion that followed highlighted three key takeaways:

• The objective of cleaner urban wastewater is widely shared. The key challenge is to implement the UWWTD in a way that is scientifically sound, legally robust and environmentally effective.
• Scientific evidence demonstrates that micropollutants in urban wastewater come from multiple sources. This must be carefully considered when attributing responsibility.
• The EPR scheme design and implementation must support the Directive’s key objective to improve water quality and protect citizens while following the principles of sound EU policymaking. Respecting the Polluter Pays Principle and grounding the EPR scheme in robust scientific evidence are essential to making it effective, workable and fair.

A timely policy discussion

The roundtable took place amid renewed scrutiny of the evidence underpinning the UWWTD EPR scheme. Advocate General Kokott’s recent Opinion pointed to manifest errors in the assessment behind the scheme, while several Member States raised concerns at the latest Competitiveness Council meeting and called for a reassessment.

Why the underlying data must be reassessed

The European cosmetics industry fully supports the objective of cleaner urban wastewater and remains committed to contributing its fair share. However, we continue to advocate for an EPR framework based on accurate data, a comprehensive understanding of pollution sources and a fair application of the Polluter Pays Principle.

The industry has long pointed out that the UWWTD EPR scheme as it currently stands is based on a flawed methodology that attributes micropollutants in a way that does not accurately reflect real-world emissions. 

A growing body of independent evidence, including studies by DHI, ECT Oekotoxikologie, Ricardo, and Cosmetics Europe’s own verification, already consistently shows that cosmetics’ contribution is minor, likely around 1–2% or less. A recent peer-reviewed study published in Environmental Sciences Europe  journal points to the same conclusion. The 26% figure cited in the European Commission’s Impact Assessment is based on flawed data, including banned substances, substances not used in cosmetics, such as the insecticide permethrin, and ubiquitous substances, such as common dietary fats, wrongly attributed to only one sector. 

Learn more here about Cosmetics Europe position and its analysis of the data underpinning the EPR scheme.