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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: &lt;&gt; On Behalf Of Nathalie MollSent: Tuesday, October 8, 2024 5:27 PMTo: ; Erkki Keldo - MKM &lt;&gt;; Riina Sikkut - SOM &lt;&gt;Cc: ; ; ; Adrian van den Hoven - Medicines for Europe &lt;&gt;; Jurate Svarcaite &lt;&gt;; Chave John - Cosmetics Europe &lt;&gt;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: &#43;3226262540 (Direct Line) Tel: &#43;3226262555 (Switchboard) Email: EU Transparency Register No: 38526121292-88