AESGP: “The General Court’s procedural decision does not resolve the UWWTD’s fundamental flaws”

Brussels, 20 February 2026The Association of the European Self‑Care Industry (AESGP) acknowledges the General Court of the European Union’s decision to dismiss EFPIA’s legal action (Case T‑158/25) against the Urban Wastewater Treatment Directive (UWWTD) as inadmissible.

The Court concluded that EFPIA had not demonstrated that it was individually concerned by the contested provisions. Direct and individual concern are two cumulative legal conditions that applicants must meet to have legal standing before the General Court of the European Union. The ruling focuses solely on admissibility and does not address the substantive legal arguments that the Directive arguably breaches general principles of EU law, such as the principles of proportionality, legal certainty, and the “polluter-pays” principle.

As a result, AESGP’s request to intervene in the case will, therefore, not be adjudicated.

 

AESGP and its members fully support the environmental ambitions of the UWWTD and share the EU’s goal of protecting water quality and biodiversity. However, the Directive’s current approach remains disproportionate, discriminatory, and scientifically unsupported, placing an excessive burden on only two sectors – pharmaceuticals and cosmetics – while other contributors to micropollutants are left unaddressed.

Micropollutants in urban wastewater originate from numerous sources, including pesticides, PFAS, household chemicals, industrial discharges (also connected to UWW), microplastics, dyes, solvents, lifestyle substances (such as nicotine and caffeine), and non‑traceable pollutants. Even the European Commission’s own assessments acknowledged the lack of robust data to attribute pollution to specific product groups. Singling out two industries, therefore, contradicts the polluter‑pays principle and risks letting other polluters “off the hook.”

AESGP is confident that the substantive legal arguments regarding proportionality, non‑discrimination, and polluter‑pays will be assessed by the Court in other ongoing proceedings, notably in Poland’s legal action against the UWWTD (Case C‑193/25).

Jurate Svarcaite, Director General of AESGP, said: “While the General Court’s ruling closes one procedural avenue, it does not address the underlying problem: the Directive remains scientifically unbalanced and unfair in how it allocates responsibility. AESGP will continue advocating for a proportionate, evidencebased implementation that protects both Europes environment and access to essential selfcare solutions.

AESGP urges the European Commission and Member States to correct course

Effective implementation of the UWWTD must ensure that:

  • all contributing sectors share responsibility fairly,
  • cost allocations reflect the real distribution of pollution sources, and
  • measures remain proportionate, science‑based, and economically viable.

 

Real risks for access to medicines and sustainable competitiveness

Revised national estimates show that the true costs of quaternary wastewater treatment are three to eight times higher than initially predicted. Concentrating these costs exclusively on pharmaceuticals and cosmetics could:

  • reduce the availability of low‑priced and economically vulnerable medicines,
  • create pressure on SMEs in the self‑care sector,
  • limit investments in innovation and sustainability, and
  • undermine Europe’s competitiveness and patients’ access to affordable medicinal products.

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