Key takeaway
What This Development Means
Poland and six supporting EU states have called for a fresh assessment of wastewater producer-responsibility costs and possible coordinated deadline changes. Their Council note does not amend the directive. Medicines and cosmetics producers should continue preparing for the existing requirements.
Has the joint request postponed wastewater EPR?
No. The Council note asks the Commission to assess whether coordinated deadline adjustments are needed if the reassessment identifies significant shortcomings or serious consequences. The note itself changes no legal deadline.
Which producers can qualify for an exemption?
Article 9 requires Member States to exempt producers that demonstrate that substances in their products placed on the Union market total less than one tonne a year, or that those substances are rapidly biodegradable in wastewater or do not generate micropollutants at the end of their life. Evidence is required.
Source basis: Council note 14204/26 and Directive (EU) 2024/3019
Joint Request Seeks A New Cost Assessment
Poland, supported by Bulgaria, Estonia, Greece, Italy, Lithuania and Slovakia, has asked the European Commission to reassess extended producer responsibility under the Urban Wastewater Treatment Directive. Their Council note dated 8 October 2026 was prepared for the 12 October Environment Council.
The states want a new independent assessment and a transparent method for attributing micropollutants to sectors. They raise concerns about proportionality, medicine supply and the allocation of treatment costs to pharmaceuticals and cosmetics. They also reaffirm support for advanced treatment and an EPR system.
A Conditional Request Does Not Pause The Law
The note asks the Commission to assess temporary adjustments or suspension of relevant deadlines if reassessment identifies significant shortcomings or serious economic and social consequences. Any pause should cover both EPR and related quaternary-treatment requirements to prevent a funding gap.
The note does not suspend or amend the directive. Under Directive (EU) 2024/3019, national transposition is due by 31 July 2027. Member States must ensure that affected producers have EPR arrangements by 31 December 2028.
Cost Shares And Exemptions Need Careful Reading
Annex III covers human medicinal products and cosmetics within the specified EU legislation. Article 9 requires affected producers to cover at least 80% of the specified quaternary-treatment and micropollutant-monitoring costs. It separately requires coverage of product-data gathering and verification costs and other costs of exercising EPR. These are financing obligations, not penalties.
Member States must exempt producers that demonstrate that substances in their products placed on the Union market total less than one tonne annually. An alternative exemption applies where those substances are rapidly biodegradable in wastewater or do not generate micropollutants at the end of their life.
For producers in scope, contributions are determined using the quantities and hazardousness in wastewater of substances in products placed on the market. The directive requires annual information on quantities, hazardousness, biodegradability and relevant exemptions.
Keep Product Data Work Moving
Foresight analysis. Regulatory and finance teams should continue preparing national implementation plans while monitoring the Commission's response. Build evidence for product quantities and any claimed exemption. Treat the joint request as a reason to track policy developments, rather than a basis for removing expected EPR costs from planning.
Related Articles
Draft EU End-Of-Waste Criteria Set New Conditions For Recycled Plastics
The Commission has notified draft EU end-of-waste criteria for recycled thermoplastics, with proposed quality, assurance and documentation conditions.
EU Environmental Omnibus Simplification Gains EESC Backing With Guardrails
EESC backs simpler EU environmental reporting while warning against weaker protection standards.
WEEE Directive Revision Pushes EU Electronics Sector Towards Tougher Circularity Rules
WEEE Directive revision proposals call for tougher e-waste prevention, reuse, recycling and producer responsibility rules.
