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Zoé Bertrand

Zoé Bertrand is an associate in the Sustainability and Life Sciences Practice Groups, where her practice covers ESG, sustainability, environmental, food, and pharmaceutical regulation. She has experience in a wide range of regulatory and compliance issues with a focus on EU, Belgian, and French regulatory advice.

She advises on compliance with EU ESG regulations, encompassing the CSRD, the CSDDD, and the EUDR, covering aspects as scope, timeline, implementation, and enforcement. As part of her practice, Zoé also covers environmental matters including the urban wastewater treatment directive, extended producer responsibility, chemicals regulations, and greenwashing.

Zoé also assists clients with the implementation of the Nagoya Protocol and the access and benefit sharing rules of a number of jurisdictions. Zoé closely follows international developments on biodiversity.

Yesterday, the European Parliament approved a new (recast) Urban Wastewater Treatment Directive (“UWWTD”) that will impose new additional costs on producers marketing pharmaceutical and cosmetic products in the European Economic Area by the end of 2027.  Some studies suggest that the costs that producers would have to collectively pay could be around €1 billion per Member State.  This is well above the figures published in the Commission’s impact assessment, which estimated the annual cost of implementing the various requirements of the UWWTD in all Member States at €3.8 billion, including €1.2 billion for micro-pollutants treatment.

The upcoming UWWTD lays down rules on the collection, treatment, and discharge of urban wastewater, and puts particular emphasis on the implementation of the polluter pays principle.  The Directive aims to address the environmental and health concerns resulting from the presence of micro-pollutants, other pollutants (e.g., heavy metals, PFAS), microplastics and antimicrobial resistant (“AMR”) bacteria in European waters.  It introduces new measures for the treatment of wastewater, including quaternary treatment for micro-pollutants, and makes producers of pharmaceutical and cosmetic producers pay for such treatment.

Continue Reading New EU Wastewater Treatment Fees on Producers of Pharmaceutical and Cosmetic Products