The revised Urban Wastewater Treatment Directive (UWWTD; Directive 2024/3019) requires the implementation of quaternary treatment at large wastewater treatment plants to remove micropollutants from wastewater. To cover the associated costs, the Directive introduces an Extended Producer Responsibility (EPR) system. According to a feasibility report commissioned by the European Commission, pharmaceuticals and cosmetics were identified as main sources of micropollutants in wastewater. Therefore, these two sectors shall mainly contribute to the EPR.
In a new policy brief published in Environmental Sciences Europe by Karen Duis, Thomas Junker and Anja Coors, researchers at ECT Oekotoxikologie, part of the SynTech Research Group, analyze the scientific evidence underlying that feasibility report. The researchers critically review the data, methodologies and conclusions presented in the feasibility report, with a focus on the contribution of the cosmetics sector to the total load of micropollutants and the total toxic load in wastewater.
The authors identify and report in detail numerous scientifically serious shortcomings that invalidate the conclusions of the feasibility report and, in consequence, of the planned cost distribution. The policy brief contributes to the ongoing discussion on the need for a science- and evidence-based decision-making towards an ERP system that reflects the actual contributions to the total micropollutant load and toxicity in urban wastewater.
Reference
Duis, K., Junker, T. & Coors, A. The EU’s recast of the Urban Wastewater Treatment Directive: analysis of the scientific basis for identifying the cosmetic industry’s contribution to the extended producer responsibility. Environmental Sciences Europe 38:175 (2026).
Read the full open-access article: https://link.springer.com/content/pdf/10.1186/s12302-026-01497-3.pdf