Cosmetics Europe welcomes the motion for oral question on the Urban Wastewater Treatment Directive (UWWTD) put forward by the European People’s Party (EPP) to be discussed in the European Parliament at the occasion of the Plenary session this week in Brussels.
“This initiative is an important and timely opportunity to raise yet again serious concerns on the substance of the Extended Producer Responsibility (EPR) scheme and its implementation. We appreciate the willingness of Members of the European Parliament to encourage an open discussion with the European Commission on an issue which has a huge impact on the cosmetics sector.” – said John Chave, Director General of Cosmetics Europe.
At the heart of the discussion lies a fundamental problem: the current EPR scheme is based on flawed methodology attributing micropollutants in a way that does not accurately reflect real-world emissions. As a result, the cosmetics sector is being held responsible for urban wastewater micro-pollution we do not generate, while other relevant sources are left outside the scope of the scheme.
This matters because the failure to follow the basic tenet of the EU law, the polluter pays principle, jeopardizes the ability of the Directive to deliver on its environmental objectives. Placing the responsibility for 80% of the cost of the quaternary treatment system upgrade on two sectors only means that in practice all other contributors to micro-pollution in urban wastewater will have no incentive to eco-design.
The cosmetics industry is supportive of the Directive’s objectives and reiterates its commitment to paying its fair share. The EPR scheme must, however, be based on a correct assessment, not the one that attributes to our sector substances that either are banned in cosmetics (e.g., nonylphenol diethoxylate), not used in cosmetics (e.g., permethrin) or ubiquitous substances allocated exclusively to cosmetics (e.g., palmitic acid), leading to an overestimation of the sectors contribution by at least 15 times1.
A fair and evidence-based EPR system that follows the polluter pays principle is essential to meeting the objectives of the Directive. The European Parliament’s engagement on the matter, through this oral question, is therefore a welcome step towards addressing the remaining issues, reassessing the current approach, correcting methodological errors, and ensuring that the UWWTD delivers real environmental benefits without placing unjustified burdens on specific sectors.
Cosmetics Europe stands ready to contribute to finding constructive solutions that restore confidence in the EPR framework and ensure a fair, workable, and effective implementation to reach the Directive’s environmental goals.
For a detailed overview of our position on the UWWTD, including our analysis of the significant data flaws underpinning the EPR scheme, please visit: https://cosmeticseurope.eu/news-events/stop-the-clock-cosmetics-industry-urges-the-european-commission-to-correct-flawed-data-and-apply-polluter-pays-principle-in-the-uwwtd/
1 Cosmetics Europe assessment is available here UWWTD-CE-Analysis-List-of-substances-used-in-the-EPRfeasibility-report-April-2025.pdf. A review of Cosmetics Europe’s analysis of the contribution of the cosmetic industry to the extended producer responsibility in the context of (EU) 2024/3019, has been commissioned by Cosmetics Europe to ECT Oekotoxikologie GmbH, and released in December 2025.