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EFPIA position on the Urban Wastewater Treatment Directive

The Urban Wastewater Treatment Directive will run counter to the Commission’s and Member States’ work on competitiveness and critical medicines, says EFPIA and calls for an urgent review.

EFPIA, its member companies and national associations are concerned by the impact that the Urban Wastewater Treatment Directive will have on European patients and the competitiveness of the pharmaceutical industry, one of Europe’s key strategic sectors.  

Our industry is committed to addressing water pollution, having already put in place an extensive Eco-Pharmaco-Stewardship programme, which over the past 15 years has made great progress in minimising the effects of pharmaceuticals on the environment.  

Our companies are willing to pay their fair share. However, the arbitrary decision to select only the pharmaceutical and cosmetic industries to pay for the clean-up of micro pollutants of all sectors runs counter to key principles of EU Treaties: polluter pays, proportionality and non-discrimination. It completely ignores the impact of other sectors, which the Commission’s own study identified as  sources of micro-pollutants. Such a disproportionate approach will fail to incentivise greener product development of all polluters and could exacerbate the risk of supply disruptions of critical medicines, particularly in the off-patent sector.  

While the European Commission attributes 92% of micropollutant toxic load to pharmaceuticals and cosmetics, they have failed to provide us with the methodology which determined this figure. Independent research suggests a much lower figure of around 10%. Furthermore, the Commission’s cost estimates are significantly underestimated. Germany’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 Netherlands, 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).

Given the new Commission’s commitment to policy coherence, competitiveness checks on legislation and ensuring the safe supply of critical medicines, an urgent review of the UWWTD is required before approval by the Council to properly address water pollution and prevent the harm the Directive would cause to patients and to Europe’s life science ambitions.   

It is imperative that a proportionate and evidence-based solution can be found. It should encompass all sectors that contribute to micro-pollutants based on the EU polluter pays principle and help us move forward to collectively addressing the important issue of water pollution.  

Nathalie Moll, Director General, EFPIA, said: “The industry is 100% behind the ambition to tackle water pollution. Pharmaceutical companies are already leading in taking steps to reduce or stop processes which negatively impact the environment, and the industry is ready to pay its contribution for pollution mitigation. 

However, putting the entire responsibility of European water pollution on the shoulders of two sectors is neither logical nor fair; it will send research to more even-handed parts of the world, taking even more innovation and new medicines away from patients living in Europe.”