News

Over the past year, European policymakers have grown increasingly concerned about EU competitiveness and the risk of lagging behind the US and China. This topic has become a major focus of the new European Commission which aims to address overbearing or misguided policies, to better support European industry. 

The vast majority of the cost – billions of euros – will fall only on two sectors of European industry: the pharmaceutical sector and our own cosmetics sector. While we support the goals of the UWWTD and the Extended Producer Responsibility (EPR) principle proposed, this cost allocation significantly misrepresents our sector’s contribution to the pollution problem we would all like to solve.  

As with most new legislation, the European Commission gets input from its own experts and from external consultants.  In this case, a study initially conducted by the Commission's experts at the Joint Research Centre (JRC) was followed by an Impact Assessment by consultants.  

Based on the JRC study, Cosmetics Europe’s analysis of the contribution of the cosmetics sector to urban wastewater pollution is around 1%, with a range of other sectors involved.  

However, this data was inexplicably disregarded in the Impact Assessment, which suggested the cosmetics sector was responsible not for 1% but approximately 26% of the problem. Every other sector was also left out, meaning that only the cosmetics and pharmaceutical sectors will have to cover clean-up costs for pollution, despite clearly not being the only users of substances that end up in wastewater. 

At the same time, with every passing week, it is becoming apparent that the total cost of water treatment upgrades was woefully underestimated. The European Commission estimated the cost at €1.2 billion per year for the whole EU, but as individual countries begin to calculate their national costs, some are finding that the actual cost is at least 4 times higher – with even higher estimates likely to emerge.  

To be clear, the cosmetics sector is ready to pay our fair share.  We believe in the importance of clean water in Europe; we believe in the 'polluter pays' principle.  Where we strongly object to is the significant miscalculations in the Impact Assessment; the hesitancy of policymakers to go back and recheck these; and the disproportionate burden placed on our industry while other sectors pay nothing. It is illogical that we’re being asked to pay a staggeringly higher amount than our fair share to cover the pollution of others.   

We all recognise the importance of supporting European industry. The cosmetics sector is a European success story – with both larger European companies competing globally, and a backbone of thousands of SMEs across the continent. For some SMEs in our sector, this one new law alone could force them to close, impacting jobs and local economies throughout Europe. 

We continue to voice our concerns, but feel we are not being heard. We are asking for costs of cleaning European urban wastewater to be based on the substances involved rather than based on sectors; we are asking for clean-up costs to be fairly distributed across more sectors according to share of pollution; and we are asking for policymakers to revisit the Impact Assessment to properly calculate the contribution of our sector compared to others, as well as the total cost of wastewater treatment upgrades. A fair application of the polluter pays principle will also incentivise other sectors to reduce their emissions. 

Cosmetics Europe has just filed an action with the EU General Court to seek clarity on this issue. We believe the seriousness of the situation merits a judicial review.  

This situation needs to be addressed or else this will be the next case study of another European industry needlessly harmed by well-intentioned but damaging policymaking.