The Center for International Environmental Law (CIEL) welcomes the possibility to provide comments on the European Commission Roadmap for the Fitness Check on Endocrine Disruptors (EDCs).
Comments on section A of the Roadmap, on the purpose and scope of the evaluation:
The Commission explains that the fitness check on EDCs “will feed into the reflection [on] whether legislative changes are necessary”. However, the need to introduce legislative changes is a long-overdue commitment. The 7th Environment Action Programme (EAP), which dates back to 2013, mandates the EU to “develop harmonised hazard-based criteria for the identification of endocrine disruptors". The existing criteria to identify EDCs are intended and designed for pesticides and biocides only. The Commission announced in 2017 that it will work on a new strategy to minimize exposure to EDCs in toys, cosmetics and food packaging (EC Press Release, 7 July 2017), and it reiterated its commitment in its communication “Towards a comprehensive European Union framework on endocrine disruptors”, stating that “the Commission considers that there should be a coherent approach to the identification of endocrine disruptors across all relevant Union legislation, based on the broadly accepted definition of the World Health Organisation” (EC Communication, 7 November 2018, and also "Findings of the Fitness Check of the most relevant chemicals legislation (excluding REACH)", part 1, 25 June 2019). Therefore, instead of delaying legislative action by investigating the opportunity to regulate EDCs, the Commission should rather focus on how to address the gaps, how new specific provisions should be framed, and how human health and environmental protection be achieved. In this regard, we would like to reiterate our suggestions in the report “Disrupted Criteria. The criteria to identify endocrine disruptors: implications beyond pesticides and biocides” (CIEL, ClientEarth, 2017).
The Roadmap announces that the fitness check will compare the current situation with 1999, when the first EDC strategy was adopted. However, while comparing the current situation with that of 20 years ago can contribute to assessing past progress, a proper updated EDC strategy with specific measures and actions (including a timeline, budget, and targets) is still lacking.
The Roadmap also mentions the assessment of the international dimension, referring in particular to imported products. We suggest that this section include not only market impacts but also human health and environmental impacts. In addition, the EU has taken international commitments to act on hazardous chemicals, and it has the opportunity to play a leading role in strengthening protection from EDCs at the global level (e.g. at UNEA and SAICM).
Finally, the fitness check should contribute to ensuring that new provisions on EDCs will be in line with a toxic-free circular economy.
Comments on section B of the Roadmap, on the consultation of citizens and stakeholders and data collection and methodology:
The Roadmap mentions an upcoming consultation of key stakeholders and public authorities. However, it does not give more information on how these stakeholders will be identified, which issues will be addressed in this targeted consultation or when this will take place.
CIEL is part of the EDC-Free Europe coalition, which brings together public interest groups representing 70 environmental, health, women’s and consumer groups across Europe who share a concern about EDCs and their impact on our health and wildlife. Our comments are complementary to those submitted by EDC-Free Europe.
We remain available for any clarification. We look forward to participating in the fitness check to help the EU achieve its commitments on EDCs.
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