Key takeaways on EC’s latest report
- The European Commission’s Environmental Omnibus aims to simplify EU environmental laws.
- Updated study estimates EPR costs at €1.56 billion/year by 2025.
- Cosmetics Europe disputes data accuracy, claiming its sector’s impact is overstated by 15 times.
- Industry calls for fair application of the Polluter Pays Principle and a workable EPR scheme.
- Concerns remain over disproportionate burden on cosmetics and pharmaceuticals.
On 10 December, the European Commission presented its Environmental Omnibus package, designed to simplify EU environmental legislation.
The cosmetics industry, alongside the pharmaceutical sector, has been closely monitoring the Extended Producer Responsibility (EPR) obligations under the Urban Wastewater Treatment Directive (UWWTD). Both industries argue that the Directive disproportionately targets them and fails to consider other contributors to micropollutants in water, such as the chemical industry and agriculture.
The Commission has released a Q&A that was accompanied by an updated study from the Joint Research Centre (JRC). This study estimates that implementation costs remain in line with those in the 2022 impact assessment, once inflation, new cost data, and differences between the final Directive and the original proposal are taken into account. This ignores claims from the industries that the original study relied on flawed evidence and underestimated cost projections.
The JRC now estimates that treatment costs have risen from €1.2bn per year by 2040, which was anticipated in 2021, to €1.56bn per year in 2025 prices.
Cosmetics Europe challenges data accuracy in UWWTD framework
European cosmetics industry trade association Cosmetics Europe has expressed disappointment that the European Commission has once again overlooked the need to address flawed data, as well as the disproportionate approach underpinning the UWWTD.
“This oversight represents a significant missed opportunity to establish a truly fair and effective EPR framework, jeopardising the Directive’s effectiveness and its overarching goal to combat water pollution,” said John Chave, Director General at Cosmetics Europe.
Speaking about the updated study on EPR system costs under the new UWWTD, Chave said Cosmetics Europe’s initial analysis confirms significant discrepancies between the Commission’s estimates – systematically much lower – and existing assessments from Member States and industry experts.
“The study does not rectify or even address the manifest error in assessing the cosmetics sector’s contribution to the toxic load in urban wastewater, which is overestimated by at least 15 times,” he said.
He explained that when the Commission’s own data is correctly assessed, cosmetics accounted for only 1.54% of the total toxic load, not 26%.
“This is consistent with independent analyses from ECT Oekotoxikologie GmbH and the Danish Hydrological Institute (DHI), which also indicate the contribution is less than 2%,” he said.
Chave stressed the urgent need for a correction of what Cosmetics Europe believes to be significant data flaws. “The cosmetics sector urgently calls for corrective measures to ensure data accuracy and create a fair, effective system to tackle water pollution,” he said. “Our commitment remains to contribute our fair share under a framework that accurately reflects the cosmetic industry’s impact.”
