The new EU Urban Wastewater Treatment Directive (EU) 2024/3019 has entered the preparatory stage for implementation by member states. Article 9 requires member states to establish producer responsibility measures for the products listed in Annex III by December 31, 2028. The industries currently listed in Annex III are pharmaceuticals and cosmetics; this does not mean that all detergents and household cleaning products are included within the same scope of responsibility.
The core of this system is to have the relevant producers bear at least 80% of the costs of tertiary and quaternary urban wastewater treatment, while also covering expenses such as product data collection and verification. The European Commission's public statement summarized this arrangement as 'the polluter pays': the pharmaceutical and cosmetics industries bear the main costs, avoiding transferring all expenses to the public budget or residents' water bills.
For personal care products, the first preparation is to organize the annual quantity of substances entering different EU markets. The regulation focuses not only on the number of finished products but also on the annual amount of relevant substances in the products. Brands, formulation teams, and manufacturers should be able to correlate the market, product, formulation version, production batch, and annual quantity to avoid sales data and formulation data being independent of each other.
The second preparation is to complete the information on the hazards and ultimate degradability of substances in urban sewage. The directive requires producers to provide the producer responsibility organization with data on quantity, hazard, and degradability every year, using quantity and hazard as an important basis for cost allocation. Therefore, supplier documents, ingredient lists, assessment methods, and version dates need to remain consistent.
EPHYON's daily chemical and personal care OEM/ODM services cover needs communication, formula solutions, samples, packaging, production, inspection, and delivery. For personal care projects targeting the European Union, the target country, formula version, supplier information, estimated launch quantity, and subsequent data responsibilities can be confirmed simultaneously at the project initiation stage, allowing the brand and manufacturer to collaborate around the same set of project information from the very beginning.
The regulations also set limited exemptions. Producers can be exempted by member states if they can prove that the annual release of the relevant substances is less than 1 ton, or that the relevant substances can be rapidly biodegradable in wastewater and ultimately do not produce micropollutants. However, 'eligibility to apply for exemption' does not equal automatic exemption; it is still necessary to prepare quantity and technical data that can be accepted by the competent authority.
The EU Joint Research Centre recently updated the study on the cost of four-level treatment. The report points out that the scope of facilities required to implement the four-level treatment under the final directive is not exactly the same as in the earlier impact assessment, and both inflation and actual operational experience have also changed the cost estimates. For companies, this means that future expenses should not be assumed in advance as a fixed percentage or a fixed unit price; instead, they should continuously track the systems of member states, producer responsibility organizations, and cost calculation rules.
OECD's research on producer responsibility also reminds us that the fee system not only needs to raise funds for treatment but also affects product design. If the fees can more precisely reflect the quantity of materials, their hazards, and biodegradability, then formula choices, supplier management, and data quality will directly impact the long-term costs of projects. Only when charges, data, and design incentives correspond with each other can the system promote improvements at the source.
In practice, a project list can be created first: in which countries the product is sold, which version of the formula is used, which suppliers provide the relevant substances, how annual input volumes are calculated, who maintains the hazard and degradability data, how packaging corresponds to product labeling, and who tracks the implementation progress in member states. Doing so not only facilitates subsequent submissions but also helps reduce discrepancies in formulas, labels, and market data.
The implementation of the 2028 system still depends on the arrangements and subsequent detailed rules of the member states. When making judgments regarding applicability, exemptions, or fees, enterprises should rely on official regulations, member state rules, and professional opinions. The value of starting to organize data now is to preserve a reliable basis for future judgments, rather than to prematurely label any specific product as "compliant" or "exempt."