TEGEWA-KosRo Position Paper on Extended Producer Responsibility of EU Urban Waste Water Treatment Directive
In the context of the Extended Producer Responsibility (EPR) provided for in Article 9, 10 and Annex III of the EU Urban Waste Water Treatment Directive (UWWTD), TEGEWA represents industrial companies that manufacture cosmetic raw materials and which – even if these substance manufacturers are not themselves subject to EPR – may be affected by the classification of substances as potential micropollutants in cosmetic products: This is because, once EPR is implemented into national law, the continued use of substances classified as micropollutants in cosmetic products to be placed on the market will trigger an EPR payment obligation on the part of the relevant product manufacturers or importers of cosmetic (end) products.