On 10 March 2025, Cosmetics Europe, just like EFPIA (European Federation of Pharmaceutical Industries and Associations), announced that it had filed an action with the EU General Court against the recast of the Urban Wastewater Treatment Directive. The reason: the disproportionate application of the polluter pays principle to the pharmaceutical and cosmetics industries alone.
The recast of Directive (EU) 2024/3019 concerning urban waste water treatment was published by the European Commission on 12 December 2024.
Based on the principle that pharmaceuticals and cosmetic residues currently represent the main sources of micropollutants found in urban wastewater requiring quaternary treatment, and that the potential increase of costs of products or the potential reduction of the profit margins of the industries placing products on the Union market due to the application of extended producer responsibility would be marginal, The European Commission has therefore decided in favour of an EPR system for these two sectors.
And it is against this principle that the two industries are acting today.
For the cosmetics industry, the message comes from John Chave, Managing Director of Cosmetics Europe.
His argument can be summed up in a few points:
• The European Commission has estimated that the cosmetics industry contributes 26% to urban water pollution, whereas an initial study by the JRC (Joint Research Centre) had quantified it at around 1%
• At the same time, the Commission has estimated the cost of water treatment for the EU as a whole at 1.2 billion a year, but as each country begins to calculate …
