Stop the clock: Cosmetics industry urges the European Commission to correct flawed data and apply Polluter Pays Principle in the UWWTD 

As the European Commission prepares to release its updated study of costs of the Extended Producer Responsibility (EPR) system under the Urban Wastewater Treatment Directive (UWWTD), the cosmetics industry demands an immediate pause in the scheme’s implementation to rectify significant data flaws and ensure a fair, effective system to fight against water pollution. 

“To have a fair and effective EPR system, it is critical to stop the clock now and re-assess the data behind it. The initial costs of the EPR scheme have been significantly underestimated, while our sector’s contribution has been overestimated by at least 15 times. Such inaccuracies cannot form the basis of any legislation. The urgent correction of these errors and the implementation of the true Polluter Pays Principle will lead to a workable Directive that effectively incentivises eco-design for all contributors to urban wastewater pollution.” – said John Chave, Director General of Cosmetics Europe. “Our industry acknowledges the importance of urban wastewater management and is ready to contribute its fair share, but we cannot be incentivised to reduce emissions of substances we do not emit.” – he added.

The EU Commission’s initial cost assessment projected an EU-wide cost of €1.2 billion per year, to be borne solely by the cosmetics and pharmaceutical industries. However, analyses from the German Environment Agency [1] and PwC [2] suggest that the actual financial impact could be 3 to 5 times higher, even by the most conservative estimates. The French Federation of Beauty Companies (FEBEA) recently reports [3] that wastewater treatment upgrades could cost between €516 and 633 million annually in France alone, which significantly differs from the Commission’s estimation of €130 million for France. These findings suggest that the Commission’s initial estimates were considerably underestimated, posing substantial financial and competitiveness challenges to the sector.

This significant financial underestimation adds to the manifest error in assessing the cosmetics sector’s contribution to the toxic load in urban wastewater.

The analyses of the Impact Assessment data behind the Directive by independent experts at ECT Oekotoxikologie GmbH[4] and the Danish Hydrological Institute (DHI) [5] demonstrate that the cosmetic sector’s contribution to micropollutants’ release is less than 2%. This is consistent with the industry’s own analysis, which estimates the sector’s contribution at 1.54%, compared to the 26% estimated by the Commission.

This significant overestimation arises from the misallocation of several key substances to the cosmetics sector. For instance, permethrin, an insecticide killing lice and mites not used in cosmetics, and nonylphenol diethoxylate, a banned substance, were wrongly attributed to the cosmetics industry. Additionally, substances like palmitic acid, commonly found in everyday use products or even food such as butter and olive oil, were incorrectly attributed exclusively to cosmetics [6].

Requiring the cosmetics sector to contribute beyond its fair share contradicts the Polluter Pays Principle and could render the EPR implementation unworkable in the Member States.  

Therefore, the cosmetics industry calls for a prompt “stop the clock” approach. This pause will allow the European Commission time to complete the updated study on the EPR implementation costs and conduct a new assessment of the toxic load across all sectors to ensure effectiveness and fairness in the UWWTD EPR scheme.  

[1] German Environment Agency, “Moving forward: The European Commission’s Proposal for a Recast Urban Wastewater Treatment Directive”, April 2023

[2] EPR cost calculation tool developed by PwC, commissioned by cosmetics and pharmaceutical industries

[3] Cost of Introducing Quaternary Treatments in France as Part of the Review of the UWWTD 2024, (RE)SET, commissioned by FEBEA, GEMME, LEEM and Neres, May 2025

[4] 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, ECT Oekotoxikologie GmbH, commissioned by Cosmetics Europe, December 2025

[5] Extended producer responsibility of Cosmetic ingredients in wastewater, Danish Hydrological Institute (DHI), commissioned by L’Oréal, April 2025

[6] Cosmetics Europe analysis of the JRC database as used in the EPR feasibility report, link here