Have your say 14.3.2023: Urban Wastewater Treatment Directive

The Chemical Industry Federation of Finland (CIFF) is a trade association for the chemical industry and its closely related sectors such as the Pharma Industry Finland and the Finnish Cosmetic and Hygiene Industry Association.

We have set a target of being Nature Positive Climate Neutral Chemical Industry by 2045 and salute the target of making European water bodies better with the suggested revision of the Urban Wastewater Treatment Directive (UWWTD). We agree there is work to be done regarding effluents and enabling less stress on water bodies. However, we are concerned the suggested methods for reaching these environmental targets are not well planned, efficient, and fair. In this suggestion an element for an Extended Producer Responsibility (EPR) is presented and pointed to two industry sectors: the pharmaceuticals and the cosmetics. We resist the element of tossing overall society impacts and their cleaning costs only to the industry, and here only for two sectors.  In one hand we see the waters are a common topic and in the other hand pharma & cosmetics are products all citizens need to enjoy a healthy and clean life.

We expect EU regulation to be fair, just, and proportionate, leading to efficient actions and improvements for the nature. In our view the suggestion lacks in specific definitions for what substances and micropollutants really are, what really exists in the wastewater effluents and where do these substances really originate from. Additionally, we see some of the investment needs as exaggerated in regard the overall impact on nature. Sometimes additional cleaning of effluents will increase energy consumption as well as waste, and usually also increases the carbon footprint. We emphasize the big picture in analyzing all effects on nature.

Scientific analysis on what exists in the effluents currently, and what are hazardous to aquatic ecosystems on national level should be the basis for this regulation. If the EPR system was established, it should cover all economic operators, whose products release these harmful substances into wastewater. EU legislation should be based on a clear list of substances, instead of an open reference to CLP hazard classifications to ensure a harmonized implementation across the EU.

We are worried that the suggested EPR would have a negative impact on the product availability and market offering especially in small markets such as Finland because of the cost burden.

We hope this regulation will be develop into a fairer and science-based direction so that it will truly have a positive effect on nature while maintaining a wide product offering at each of the European markets and incentivizing companies to continuously develop better products for the environment through out their lifecycle.