WAREG has published a new study “Extended Producer Responsibility (EPR) Schemes in Europe: Lessons and recommendations for their application in the wastewater sector.”
The study examines how Extended Producer Responsibility schemes currently applied in the European waste sector can inform the design and implementation of the new EPR mechanism introduced by the revised Urban Wastewater Treatment Directive for the removal of micropollutants from urban wastewater.
The revised Directive represents a major development in EU water policy. For the first time, it introduces an EPR scheme specifically dedicated to wastewater treatment. Producers in the pharmaceutical and cosmetics sectors will be required to contribute to the costs of quaternary treatment, covering at least 80% of the relevant costs, including investment, operational, monitoring, data-gathering and verification costs.
The study confirms that EPR is a relevant instrument to apply the polluter-pays principle and to support the financing of advanced treatment requirements. At the same time, it stresses that wastewater services differ structurally from waste management. Wastewater treatment is a regulated, infrastructure-intensive natural monopoly, geographically bound and subject to national planning and authorisation frameworks. For this reason, EPR models developed in the waste sector cannot be mechanically transferred to the water sector.
A central finding of the report concerns the role of economic regulators. Where present, regulators can contribute to the implementation of EPR by supporting the definition of eligible costs, strengthening accounting unbundling for quaternary treatment, integrating EPR flows into tariff methodologies, monitoring investment and operating costs, verifying the allocation of resources, and safeguarding affordability for end users.
The study also highlights the need for stable and guaranteed financial flows. Wastewater treatment utilities will need to plan, finance and implement significant investments in quaternary treatment. This requires predictable EPR contributions, clear compliance rules, effective mechanisms to address non-payment, and transparent monitoring and audit arrangements.
Affordability remains a key concern. Although producers are expected to cover at least 80% of the costs of quaternary treatment, the remaining share may fall on tariffs or public funding. The study therefore underlines the importance of strengthening affordability instruments, including social tariffs, targeted subsidies and other redistributive measures, particularly in light of the broader investment pressure arising from the revised Directive.
The implementation timeline is demanding. Member States must transpose the Directive by 31 July 2027, prepare National Implementation Programmes by 1 January 2028, and ensure that EPR schemes become operational by 31 December 2028. The study stresses that early preparatory work will be essential to define responsibilities, financial flows, cost recognition rules, reporting procedures and investment priorities.
Through this publication, WAREG aims to support evidence-based dialogue on the implementation of the revised Urban Wastewater Treatment Directive and to contribute to the development of effective, transparent and affordable EPR governance arrangements across Europe.
WAREG will continue working with its members, EU institutions, Member States and stakeholders to ensure that the implementation of EPR in the wastewater sector strengthens water quality, protects consumers, supports cost efficiency and contributes to the long-term resilience of European water services.