The implementation of Directive (EU) 2024/3019 has generated intense debate within the Spanish business community, particularly among manufacturers of beauty and personal care products. While the objective of protecting the environment and improving the quality of our rivers and seas is shared by all, the proposed financing method for the modernization of wastewater treatment plants has caused considerable controversy. The main industry associations, most notably Stanpa, have called for the implementation of this legislation in Spain to be handled with extreme caution and without jeopardizing the competitiveness of an industry that is key to the national economy.
The sticking point lies in the so-called Extended Producer Responsibility (EPR), a system that obliges cosmetics and pharmaceutical companies to pay for the removal of micropollutants from urban waterways. This represents a change in the rules of the game that, according to experts, could bring with it economic and regulatory uncertainty that many companies will find difficult to accept. After all, these sectors are being directly singled out as the main culprits for pollution that, in the opinion of industry associations, has a much more varied and complex origin than the European regulation suggests.
An economic impact that keeps you up at night.
To put figures on the table, industry organizations have turned to external technical reports that reveal quite worrying data about the cost of this thorough cleaning of our waters. It is estimated that the annual bill for Spanish companies will range between 134 and 346 million euros, which would represent an astronomical outlay of up to 7.000 billion euros over the next two decades . This situation is especially delicate because it has not yet been clearly defined which substances will be exempt or how the collective payment systems will work exactly.
Given this situation, the industry is urging the Spanish government not to overreact when adapting the law and to limit itself to the minimum requirements set by Brussels. The companies' proposal is clear: that producers assume 80% of the costs, while the remaining 20% ​​be covered by public funds, since sanitation is a service that benefits all of society. It's important to remember that, to this day, Spain still has a long way to go in implementing quaternary treatment technologies in its wastewater treatment plants , which are essential for filtering out cosmetic actives used in skincare and other micro-pollutants.
Legal doubts in the heart of Europe
It's not just about money; the battle is also being fought in the courts. The current model has been challenged by several member states, with Poland filing appeals with the Court of Justice of the European Union and Ireland raising doubts about whether this liability system is truly fair. The European Parliament itself has recently taken action, requesting new studies to more accurately identify who is actually polluting the water before billing the cosmetics and pharmaceutical sectors, seeking to ensure that the "polluter pays" principle is truly and proportionally applied.
For this reason, industry representatives insist that irreversible decisions should not be made while the EU legal framework remains so unstable. It is crucial that the future Spanish law be flexible enough to adapt to the rulings of European judges in the coming months. Meanwhile, companies continue to defend their commitment to sustainability, but demand that the transposition of the directive be balanced and legally sound to prevent investment and employment in the cosmetics sector from being negatively impacted by rushed regulation.
The future of water management in Spain is now entering a crucial phase where collaboration between the Ministry for Ecological Transition and the private sector will be vital. It is essential to find a balance that allows us to meet the European Union's environmental ambitions without economically stifling the cosmetics industry. Creating a revisable funding system based on solid scientific evidence appears to be the only way to guarantee clean water without placing an unbearable burden on innovation and industrial development in our country.