The European Commission's assessment of pharmaceutical contribution to urban wastewater toxic load is scientifically flawed due to insufficient data and methodological errors. The key issues include:
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Overestimation of Pharmaceutical Toxicity: The Commission relies on computer-simulated toxicity estimations while ignoring reliable measured data, leading to an overestimation of pharmaceutical toxicity by up to 90,000 times for certain drugs like telmisartan. This inflates the perceived toxic load from pharmaceuticals by up to 3 times.
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Biased Sector Allocation: Each micropollutant is assigned to a single sector, an overly simplistic approach that falsely attributes some micropollutants (e.g., Chloroxylenol, benzethonium chloride) exclusively to pharmaceuticals, despite their broader usage.
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Ignoring Tertiary Treatment and Data Gaps: The assessment neglects the impact of tertiary treatment, which could reduce micropollutant toxicity, and fails to account for data gaps in 40% of analyzed micropollutants, further skewing the results in favor of pharmaceuticals.
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Inadequate Data Handling: Data gaps for 40% of micropollutants were filled only for pharmaceuticals, inflating their toxic load compared to other substances. Some micropollutants are incorrectly assigned to the pharmaceutical sector.
Recommendations:
- Pause the implementation of sector-specific Extended Producer Responsibility (EPR) provisions.
- Conduct a thorough, transparent reassessment of toxic load contributions using unbiased, science-based methods.
- Develop alternative EPR solutions that are proportionate, science-based, and comply with the Polluter Pays Principle without compromising patient access to medicines.
- Apply measured toxicity data for all substances, refining estimates for those without measured concentrations.
The Commission's approach undermines the objectives of the Urban Wastewater Treatment Directive (UWWTD) by failing to ensure proportionate, science-based, and fair regulatory measures.
