The Directive 3019/2024 UWWTD (recast) includes a new obligation on Extended Producer Responsibility (“EPR”) for producers who place medicinal products for human use and cosmetic products on the market, to cover the costs of quaternary treatment of urban wastewater to remove micropollutants resulting from such products. By July 31, 2027 Member States must transpose into national legislation the UWWTD (recast) and apply the EPR obligations by December 31, 2028.
While the details of the EPR initiative are left up to the Member States, according to the UWWTD producers (including importers and distributors) would be required to form/join producer responsibility organizations.
As Member States begin to take steps to implement the EPR schemes within the established deadline, several questions arise on how to set up an effective, inclusive and well-balanced governance system.
Will one PRO per Member State implement the new EPR responsibility? If so, how to make it effective and efficient and how the different relevant stakeholders (at least those mentioned in Art. 9.4(a)) should be involved?
