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A Deloitte study on producers’ responsibility to prevent micropollutants from entering the environment finds that the EU should better implement existing legislation to keep our water affordable for everyone.

The study, commissioned by EurEau, the European Federation of National Associations of Water Services, confirms that control-at-source measures are not fully implemented in the EU despite clear requirements set out in Article 191.2 of the EU Treaty. Products releasing hazardous substances continue to be placed on the market, despite their potentially harmful effects.

Consequently, water service providers may have to implement additional costly treatments in order to remove micropollutants and microplastics. The cost of this is ultimately passed on to the water consumer, affecting affordability.

But why should water consumers pay for costly treatments they are not responsible for?

The study findings show that existing legislation provides clear opportunities to implement the Polluter Pays Principle through Extended Producer Responsibility (EPR) if control-at-source measures alone are not enough to effectively reduce micropollutants and microplastics emitted from products during their life-cycle.

While EPR holds significant potential to ensure producers take on full physical and financial responsibility of their products, the study concludes that EPR alone is not the magic solution to solving Europe’s water challenges. Instead, only a combination of both upstream (control-at-source) and downstream measures financed through EPR will be able to adequately tackle the full extent and scope of the problem.

The report’s recommendations include defining the legal and financial responsibility for the products placed on the market;applying an appropriate levy on polluting products that reflects the costs of treatment; conduct a cost-benefit analysis of mitigation measures; and promoting eco-design.

The EU needs to take action, enforce existing legislation and adjust it, where necessary, so that water will remain affordable, as well as safe, clean and healthy.


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Extended producer responsibility or product stewardship is a policy approach that aims to increase waste recovery and recycling. Extended producer responsibility (EPR) systems aim to make producers responsible for the environmental impacts of their products throughout the product chain, from design to the end-of-life phase. With about 400 EPR systems currently in operation across the globe, most of them in OECD member countries, these policies have become one of the key approaches in this area. While these systems have helped to increase recycling andcollection rates, as well as generating financial resources to pay for these activities, governments are grappling with a number of issues that hinder their effectiveness and efficiency. This report focuses on free-riding of producers or retailers, which the fast expansion of online sales in recent years has been exacerbating. Online sales are creating new free-riding opportunities as consumers are able to buy more easily from sellers in other countries. These sellers often have no physical, legal entityin the country where the consumer resides, and are not registered with national or local EPR schemes. The consequence is that they avoid producer and retailer/distributor obligations and costs, thereby undermining EPR systems. This report identifies some of the measures that governments and other stakeholders could consider in order to address this issue, including awareness raising, better enforcement of existing rules and the introduction of new regulatory measures.

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