APE and a broad coalition of stakeholders call on the European Commission to firmly uphold the EPR scheme in the recast UWWTD
Aqua Publica Europea and a large group of stakeholders representing drinking water and wastewater service providers, local public utilities, local and regional governments, civil society organisations, social partners, and water-related technology providers, call on the European Commission to firmly uphold the Extended Producer Responsibility (EPR) scheme in the recast Urban Wastewater Treatment Directive (UWWTD).
On 6 May 2025, Bernard Van Nuffel, President of Aqua Publica Europea, together with the senior representatives of 11 organisations representing drinking water and wastewater service providers, local public utilities, local and regional governments, civil society organisations, social partners, and water-related technology providers, wrote a joint letter to President Ursula von der Leyen to call on the European Commission to safeguard the Extended Producer Responsibility (EPR) scheme in the recast Urban Wastewater Treatment Directive (UWWTD).
The recast UWWTD, which entered into force on 1st January 2025, introduces ambitious new requirements to remove micropollutants from wastewater, reach energy neutrality, strengthen the circular economy, promote water reuse as well as improve transparency and access to sanitation. As such, it marks a significant milestone for the protection of public health and water resources in Europe.
A cornerstone of this legislation is the EPR scheme, which ensures that the two most polluting sectors, the pharmaceutical and cosmetic industries – jointly responsible for 92% of micropollutants in wastewater according to the European Commission’s impact assessment – cover at least 80% of the costs of the ‘quaternary treatment’ needed to remove micropollutants.
The letter's co-signatories urged the European Commission to push back against any pressures to revise or weaken this core provision of the recast Directive, reminding that the EPR scheme is the result of a carefully negotiated and balanced compromise achieved during the interinstitutional negotiations and that reopening this debate would create serious legal and financial uncertainties, which would postpone the rollout of quaternary treatment and delay the overall implementation of the recast Directive.
The scheme, based on the polluter-pays principle enshrined in Article 191(2) of the TFEU, allows for an equitable distribution of wastewater treatment costs between polluting industries and urban water users. It is essential to the implementation of quaternary treatment requirements as it ensures that the financial burden does not fall disproportionately on public water services and protects water affordability for European households in line with SDG 6’s right to safe and affordable water and sanitation services.
The EPR scheme also creates a level playing field across the EU and is a driver for eco-innovation and sustainable product design, thereby enhancing the competitiveness of Europe’s economy. Having less polluting products and substances entering wastewater also supports the circular economy by facilitating wastewater reuse and resources recovery as well as enhancing sludge quality.
According to the impact assessment published together with the European Commission’s proposal, the EPR scheme is expected to have a limited financial impact on the pharmaceutical and cosmetic sectors. In addition, the recast Directive gives room for Member States to add to the EPR scheme other sectors producing micropollutants that can be found in urban wastewater.
Claims that the scheme would undermine the competitiveness of companies established in the EU are misleading. The EPR scheme needs to be funded by all economic actors that put cosmetics and pharmaceuticals on the EU internal market, no matter whether these products are made within the EU or in a third country.
