Across Europe, citizens rightly expect clean water, healthy rivers, and affordable water services. Yet, every day, micropollutants flow from our homes into wastewater systems. These substances are biologically active, persistent, and costly to remove. The EU recast Urban Wastewater Treatment Directive (rUWWTD – (EU) 2024/3019) confronts this challenge with a forward-looking solution: Extended Producer Responsibility (EPR). EPR is a tool to implement the Polluter-Pays Principle (PPP), one of the founding pillars of EU environmental law, enshrined in Article 191(2) of the Treaty on the Functioning of the EU and reaffirmed by the European Court of Auditors. Together, these mechanisms ensure that those who cause pollution bear the costs of remedying it, safeguarding the environment, Europe’s most vital resource – water, and the affordability of essential water services.
Why EPR is needed
Access to safe, affordable water and sanitation are human rights and a foundation of Europe’s prosperity. Urban wastewater treatment plants (UWWTPs) have long been central to this mission, protecting public health and the environment. Yet, today’s challenge goes beyond bacteria and nutrients: it is about removing micropollutants.
The rUWWTD sets targets for quaternary treatment — advanced processes to remove micropollutants, essential to protect aquatic ecosystems and drinking water resources, but it comes with significant costs. The Directive requires producers of pharmaceuticals and cosmetics to finance at least 80% of the costs for such treatment, reflecting their contribution to the pollution load.
This is not punitive; it is corrective. For decades, water operators have borne the growing costs of removing substances they did not produce. Most utilities are small or medium-sized public entities, serving communities that depend on them for affordable water and sanitation. Without EPR, these operators would bear the financial burden for removal of pollution created upstream.
EPR shifts the responsibility back to the source of the problem and creates a level playing field. Every producer placing pharmaceuticals or cosmetics on the EU market, whether manufactured in Europe or abroad, contributes their share.
The risks of going without EPR
Failing to implement EPR would have serious environmental, economic, and social consequences.
- Higher water tariffs and social unfairness. If producers are exempt from covering micropollutant removal costs, wastewater utilities will have to pass these expenses onto user: households, small businesses, and farmers — who do not profit from these substances — would pay more for essential water services. The impact would be regressive, disproportionately affecting low-income families and small enterprises.
- Reduced investment capacity of water operators. The Water Resilience Strategy identifies an investment gap of EUR 23 billion per year to implement existing water legislation (not including the recast Drinking Water Directive nor the rUWWTD). Without EPR funding, investments in innovation, digitalisation, climate mitigation and adaptation, and circular economy could be delayed or cancelled, resulting in weaker resilience of Europe’s critical water infrastructure and slower progress towards a competitive circular economy.
- Threats to SMEs and local competitiveness. Water-dependent small and medium-sized enterprises (SME) — including food producers, beverage manufacturers, and farmers — would face higher operating costs if water tariffs increase, eroding their competitiveness compared to sectors responsible for micropollutant emissions.
- Slower innovation and persistent pollution. EPR should incentivise cleaner design: producers have a financial reason to develop substances that are less polluting. Without it, there is no economic driver to change. This will result in a continued flow of persistent pollutants into water bodies, forcing operators to install costly treatments indefinitely while pollution at the source remains unchecked.
A proportionate and forward-looking approach to ensure sustainable financing
EPR ensures:
- Sustainable financing model and financial predictability: producers’ contributions — based on the quantity and hazardousness of their substances — will guarantee cost recovery and provide long-term planning security for the water sector
- Fair cost allocation: those responsible for pollution bear its clean-up costs.
- Innovation incentives: the more producers innovate to reduce toxicity and emissions, the lower their future financial contribution will be; EPR aligns economic incentives with environmental performance.
- Shared responsibility: costs are distributed across all entities placing products on the EU market, including non-EU manufacturers.
Moreover, the system is flexible. Member States can expand EPR to additional sectors, and smaller UWWTPs will only be required to implement micropollutant removal where risk assessments justify it.
Safeguarding a sustainable water future for Europe
Europe’s water operators are committed to delivering the ambition of the rUWWTD: cleaner waters, resilient infrastructure, and a sustainable future. This requires adequate, fair financing. EPR provides precisely that — aligning environmental responsibility with economic logic.
Without EPR, the financial and environmental burden would shift from polluters to public services and, ultimately, to all water consumers. Water utilities would divert resources from innovation and climate resilience toward micropollutant removal, slowing Europe’s transition to a sustainable and circular water economy. Small businesses would lose competitiveness. Pollution at the source would continue unchecked, and the PPP would be violated.
With EPR, Europe establishes a virtuous cycle: producers innovate to reduce pollution, wastewater operators receive the means to protect water bodies, and citizens enjoy affordable, safe, and sustainable water services.
Clean water is everyone’s right, but it also must be everyone’s responsibility.
Gari Villa-Landa Sokolova
Senior Policy Advisor
EurEau (European Federation of Water Services)
Belgium
gari.villa-landa@eureau.org
