In mid-December, FEBEA (French Federation of Beauty Companies), Cosmetics Europe, and EFPIA (European Federation of Pharmaceutical Industries and Associations) once again expressed their regret that their arguments highlighting major shortcomings in the Urban Wastewater Treatment Directive (UWWTD) had not been taken into account.
Indeed, Member States and the European Parliament declined to include the text in the latest omnibus directive aimed at simplifying European legislation. A “significant missed opportunity,” according to FEBEA and Cosmetics Europe, to “establish a truly fair and effective Extended Producer Responsibility (EPR).”
Flawed data
While reaffirming their commitment to the polluter-pays principle and their support for the goal of cleaning up urban wastewater, industry representatives criticized the Urban Wastewater Treatment Directive as being based on flawed assumptions that they argue render it particularly unfair.
FEBEA argues that the European Commission relied on a flawed database that wrongly attributes micropollutants to the cosmetics sector, inflating its estimated contribution to 26%, versus 1.54% according to industry calculations.
The industry’s analysis aligns with findings from experts at ECT Oekotoxikologie GmbH [1] and the Danish Hydrological Institute (DHI) [2], whose review of the directive’s Impact Assessment data places the cosmetics sector’s contribution to micropollutant releases at less than 2%.
FEBEA and Cosmetics Europe claim the data used by the Commission wrongly allocated to the cosmetics sector several substances that are not used in its products. 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 or caffeine, commonly found in everyday use products or even food such as butter and olive oil, were incorrectly attributed exclusively to cosmetic products.
However, the European Commission did not factor in any of these elements in its latest update of the UWWTD pollution clean-up cost study, published on December 10, 2025.
"These omissions are incomprehensible and increase our deep-rooted concern (...) regarding the Commission’s approach to evidence-based policymaking," commented EFPIA.
“Prompt stop the clock” approach
The cosmetics and pharmaceutical industries argue that the directive is based on “erroneous assumptions,” making it unfair by placing the bulk of pollution clean-up costs on two sectors whose actual contribution to pollution is minimal.
“Our sector’s contribution has been overestimated by at least 15 times. Such inaccuracies cannot form the basis of any legislation. 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,” highlighted John Chave, Director General of Cosmetics Europe.
“Contributions must be based on the actual release of micropollutants, irrespective of the industrial sector, and proportionate to their emissions. Let us emphasize that this is not about making the consumer pay, but about ensuring a comprehensive roundtable of upstream contributors,” added FEBEA’s General Delegate, Emmanuel Guichard.
Furthermore, industry representatives say that the costs of pollution clean-up have been largely underestimated by European institutions. Therefore, they call for a prompt “stop the clock” approach; a pause in the implementation of the text that would 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.”
But does the issue lie with the European institutions? If the simplification of the UWWTD was excluded from the latest omnibus directive, it would largely be because Germany opposed the calculation method advocated by France.
