Ms. Yoko ALENDER
Minister of Climate
Suur-Ameerika 1
10122 Tallinn
Estonia
Mr. Erkki KELDO
Minister of Economy and Industry
Suur-Ameerika 1
10122 Tallinn
Estonia
Ms. Riina SIKKUT
Minister of Health
Paldiski mnt 81
10614 Tallinn
Estonia
8 October 2024
Subject: Concerns over Urban Wastewater Treatment Directive (UWWTD) having an impact on
Europe’s competitiveness and the availability and affordability of essential products
Dear Minister Yoko Alender, Minister Erkki Keldo, Minister Riina Sikkut,
On behalf of AESGP, EFPIA, Medicines for Europe, representing the pharmaceutical industry, and
Cosmetics Europe, representing the cosmetics industry, we would like to express our
concerns regarding the provisional agreement on the recast of the Urban Wastewater Treatment
Directive (UWWTD) 91/271/EEC. We urge delaying its adoption until a thorough assessment of its real
impact on these key sectors for Europe’s economy and society is conducted, and the polluter-pays
principle is adequately addressed.
While we support the UWWTD’s goal of tackling water pollution, we object to the arbitrary decision
to select the human pharmaceutical and cosmetic industries alone to pay for the clean-up of
micropollutants from all sectors. While the European Commission attributes 92% of micropollutant
toxicity to pharmaceuticals and cosmetics, independent research suggests a much lower figure of
around 10%1. The latter would indicate a decision that runs counter to key principles of EU Treaties,
namely polluter pays, proportionality and non-discrimination.
1Water Solutions (2020) Fund-based solution for trace element reduction. Available at:
https://www.bdew.de/media/documents/gwf_engl_final_Research_Czichy_Oelmann_Schitthelm_Fund-
based_solution_Druck_PDF.pdf.
Alberto Pistocchi, Nikiforos A. Alygizakis, Werner Brack, Alistair Boxall, Ian T. Cousins, Jörg E. Drewes, Saskia Finckh, Tom Gallé,
Marie A. Launay, Michael S. McLachlan, Mira Petrovic, Tobias Schulze, Jaroslav Slobodnik, Thomas Ternes, Annemarie Van
Wezel, Paola Verlicchi, Caroline Whalley, (2022) European scale assessment of the potential of ozonation and activated carbon
treatment to reduce micropollutant emissions with wastewater, Science of The Total Environment, Volume 848, 2022,
157124, ISSN 0048-9697, https://doi.org/10.1016/j.scitotenv.2022.157124.
Additionally, we believe that the Commission’s cost estimates are significantly underestimated, which
could lead to serious consequences for the availability and the affordability of several essential
products. For instance, Germany2’s Environment Agency estimates for quaternary treatment costs
range from €885 to €1,025 million annually – four times higher than the Commission’s figure of
€238 million. Similar concerns arise in the Netherlands3, where the costs for implementing the
legislation are up to six times more than the Commission’s estimations. Estimates from EurEau, the
European Federation of National Associations of Water Services, indicate costs ranging from three to
over nine times higher than the Commission’s numbers (between €3.6 and €11.3 billion per year).4
Our industries are committed to reducing water pollution and call for a non-discriminatory system that
fairly encompasses all sectors contributing to micropollutants and considers the economic impact
based on accurate cost estimates. A disproportionate approach will fail to incentivise greener product
development of all polluters and could jeopardise the supply of essential products for
society, undermining the European Green Deal and our Open Strategic Autonomy goals.
Given these considerations and the Commission’s focus on bolstering Europe’s competitiveness, we
strongly call for an urgent review of the provisional agreement on the UWWTD to prevent harm to
Europe’s broader development ambitions. Delaying the Council’s approval of the directive until the
above uncertainties are duly considered and addressed by fully respecting all European laws and
principles is crucial to ensure these concerns.
We remain available for any further question you might have and thank you for your careful
consideration.
Yours respectfully,
Nathalie Moll Jurate Svarcaite John Chave Adrian van den Hoven
Director General Director General Director General Director General
EFPIA AESGP Cosmetics Europe Medicines for Europe
2 Scientific Opinion Paper, Moving forward: The European Commission’s Proposal for a Recast Urban Wastewater Treatment
Directive, April 2023.
3 Netherlands estimation: over 400 million for the initial/start-up costs, figure from the Ministry of Infrastructure and Water
Management.
4 EurEau, Position Paper on the Proposal for a Directive concerning urban wastewater treatment (recast), February 2023, p.
5, available here.
Saatja: SM kantselei info <
[email protected]>
Saadetud: 09.10.2024 10:45
Adressaat: <
[email protected]>
Teema: FW: Concerns over Urban Wastewater Treatment Directive (UWWTD)
having an impact on Europe’s competitiveness and the availability and
affordability of essential products
From: <> On Behalf Of Nathalie MollSent: Tuesday, October 8, 2024
5:27 PMTo: ; Erkki Keldo - MKM <>; Riina Sikkut - SOM <>Cc: ;
; ; Adrian van den Hoven - Medicines for Europe <>; Jurate
Svarcaite <>; Chave John - Cosmetics Europe <>Subject:
Concerns over Urban Wastewater Treatment Directive (UWWTD) having an
impact on Europes competitiveness and the availability and affordability
of essential products
Dear Ministers,
On behalf of AESGP, EFPIA, Medicines for Europe, representing the
pharmaceutical industry, and Cosmetics Europe, representing the cosmetics
industry, we would like to express our concerns regarding the provisional
agreement on the recast of the Urban Wastewater Treatment Directive
(UWWTD) 91/271/EEC.
We urge delaying its adoption until a thorough assessment of its real
impact on these key sectors for Europes economy and society is conducted,
and the polluter-pays principle is adequately addressed.
See attached the joint industry letter co-signed by all four trade
associations.
We remain available for any further questions you might have and thank
you for your careful consideration.
Yours respectfully,
Nathalie Moll
Director General
EFPIA - European Federation of Pharmaceutical Industries and Associations
Neo BuildingRue Montoyer 51, box 31000 Brussels
Belgium
Tel: +3226262540 (Direct Line)
Tel: +3226262555 (Switchboard)
Email:
EU Transparency Register No: 38526121292-88