The discussions between the Pharmaceutical and Cosmetics industry (polluter) and the Commission (regulator) are heated. Depending on who you listen to, the cost of upgrading Europe’s wastewater facilities changes. One side says it’s manageable; the other says it’s a financial burden. So, what is actually happening here?

The Science is Robust

The European Commission’s latest cost-estimation model is outstanding. By any scholarly measure, it is a robust piece of work. It’s grounded in evidence, it accounts for inflation, and it exploits well the tech: PAC, GAC, and ozonation. It correctly identifies the hierarchy we need: from basic sedimentation to the quaternary removal of micropollutants.

We have Europe’s premier research institutions trying to quantify a “wicked problem.” They are providing the initial boundaries, or the data points, we need to start a real dialogue.

The Operational Reality

However, as we move from a spreadsheet to a construction site, we have to admit the limits of technical projections. The Commission’s data is factual, but it reflects “perfect-case” scenarios. Supply chain friction is real. Local engineering constraints are real. When a model reaches real-world, for example in less-resourced regions where even secondary treatment is a struggle, the costs may, inevitably, rise.

The Pharma and Cosmetics industry isn’t just “complaining”. They are mapping risk. They are trying to figure out how much of this cost they can actually absorb.

A “Mission Impossible” in Isolation

The final cost won’t be determined solely by modeling; it will be determined in the crucible of tenders, shipping machinery, and commissioning. This is as complex as calculating Scope 3 carbon credits. It is a “mission impossible” if everyone stays in their silos.

Right now, I see a landscape of friction: angry stakeholders and yet difficult jargon. We have a trust deficit.

The goal is clear: cleaner EU waters. No PFAS, no antimicrobial resistance, no endocrine disruptors. I want my paracetamol price to stay low, but I also want to swim in the Mediterranean without worrying about chemical toxicity. We are on the same side.

The Choice

I am a facilitator of the conversations that need to happen. I help teams collaborate. We need a level of information sharing never seen before in the EU. For my friends in CleanTech, this is a beautiful opportunity for innovation.

Or, we can all just fend for ourselves. But should we? I don’t think so.

This article was inspired by the work of my colleague Prof. Paul Coughlan (Professor of Operations Management, Trinity College Dublin), who has contributed immensely to the fields of Action Learning and Innovation Management, particularly Network Action Learning and Collaborative Strategic Improvement.