Key takeaways on EU wastewater rules
- Industry backlash: Cosmetics bodies FEBEA and Cosmetics Europe oppose the EU’s Urban Wastewater Treatment Directive.
- Flawed assumptions: Data errors overestimate cosmetics’ contribution to micropollutants by up to 15 times.
- Cost concerns: Upgrading treatment plants could cost €513–633 million annually in France alone.
- Call for fairness: Industry demands EPR contributions based on actual emissions, not sector bias.
- Next steps: Pressure mounts on EU authorities to correct data and create a sustainable, science-based framework.
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.
Flawed data and rising costs: FEBEA’s key concerns
French cosmetics industry body FEBEA has joined other industry experts to speak out and say that the major shortcomings contained in the Directive on urban wastewater treatment are still not being addressed. “We regret that an opportunity has thus been missed to correct a regulation which, as it stands, does not comply with the polluter pays principle,” said the industry body.
“FEBEA reiterates its view that the Urban Wastewater Treatment Directive is based on flawed assumptions and calls for the implementation of an Extended Producer Responsibility (EPR) scheme dedicated to micropollutants that is effective and sustainable.”
The organisation added that while the cosmetics sector strongly supports the objective of cleaning up urban water and is fully prepared to participate in this through an EPR dedicated to micropollutants and deeply committed to the polluter pays principle, it doesn’t believe that an effective and sustainable EPR for water can be based solely on the cosmetics and pharmaceutical sectors.
FEBEA’s General Secretary Emmanuel Guichard did not mince his words in speaking out against the situation. “To think that the effort to clean up urban water pollution is limited to just two sectors is not only simplistic, but it jeopardises the very achievement of this legitimate objective,” he said. “We call on national authorities to mobilise in support of robust legislation and an industry that is a strong contributor and committed to the transition.”
The French cosmetics industry body is advocating that contributions must be scientifically based on the micropollutants actually discharged, regardless of the industrial sector responsible, and in proportion to their emissions.
It said it believed the Commission has based its decision on a database that incorrectly attributed micropollutant substances to the cosmetics sector. “Cosmetics account for less than 2% of the total, not 26%,” it said.
Perceived errors include attribution of substances not used in cosmetics such as the insecticide permethrin, which is used to treat lice; substances used only marginally in cosmetics (such as caffeine, or palmitic acid, which is found in butter or olive oil); prohibited substances and substances that are prohibited for use in cosmetics (eg nonylphenol diethoxylate).
FEBEA also drew attention to the conclusions of the study entrusted to independent firm (RE)SET and commissioned jointly with pharmaceutical associations: upgrading wastewater treatment plants to treat micropollutants, as required by the Directive, would cost companies in France between €513 and €633 million per year on average (i.e., between four and five times more than the initial estimates of the European Commission). “The Commission’s clearly underestimated assessment of the costs of the Directive has not been duly corrected,” it stated.
Cosmetics Design-Europe has reached out to the EU’s press office but had not received a comment at the time of publication.
Cosmetics Europe calls for fair and accurate EPR framework
Meanwhile, 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.
“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.”