PAN Europe welcomes the European Commission’s scope to have EU-wide legislative measures that ensure a high level of protection of human health and the environment from all hazardous substances including endocrine disruptors (EDs).
However, the ED-related legislative measures have been slow, and have hardly been implemented or in some cases even established. Therefore, investing resources towards a fitness check at this stage not only seems premature, but also poses a risk of additional and unnecessary delays in implementing EU law provisions, while human beings and the environment continue to be exposed to these dangerous chemicals. Resources should be spent on the implementation of the current EU law measures that address EDs, application of available OECD ED testing for dangerous chemicals in the market (pesticides and biocides), development and endorsement of new scientific methods to identify EDs, establishment of an assessment method to address chemical mixtures (required by EU law since 2005) and development of non-chemical, safe alternatives.
In the case of pesticides and biocides - two chemical classes with biological activity, hence the risk they may interfere with the endocrine system is high - the Regulations call for substances that meet certain ED scientific criteria not to be authorised, with some exceptions on restricted use (e.g. negligible exposure or if needed to protect serious damage to human/plant health). These criteria were due in 2013 but entered into force recently (June 2018 for biocides, November 2018 for pesticides) and only address certain classes of EDs. Only one biocide substance has been recognised so far as an ED (cholecalciferol) and its use has been restricted. For pesticides, during the Commission's 2016 Impact assessment exercise, 32 legal pesticides were identified to be EDs, but so far none of these have been classified as such. Even with this set of rather narrow scientific criteria, it remains to be seen whether any of these pesticides will be identified as EDs at all. For the moment, testing pesticides using the available ED tests (OECD) is not mandatory and in most cases ED analysis is based on non-ED specific tests and speculations. Therefore, the regulatory measures in place are not implemented and humans and the environment keep being exposed to ED pesticides and biocides.
PAN Europe agrees with the horizontal approach for the scientific identification of EDs across EU legislations; scientifically, a substance cannot be classified as an ED under one legislation but not under another. The Commission should create another class of potential EDs in line with WHO [State of the Science of Endocrine Disrupting Chemicals (WHO, 2002)]. This will allow for the identification of potential EDs which are of concern that should be excluded from uses that come in contact with humans and the environment. PAN Europe calls to expand the ED definition for biocides and pesticides as well, potential EDs should also be regulated and should never be considered low-risk substances.
The EU should have different regulatory approaches in the different pieces of chemicals legislation. Chemicals have divergent properties and applications and should be regulated accordingly. The higher the chance of human and environmental exposure to dangerous substances, the stricter the regulation should be. Pesticides that are biologically active and used on open fields - exposing not only farmers but also residents, bystanders, consumers (through residues in food), the environment and its species - must not be EDs, as such chemicals should pose no human health or environmental risk.
Priority should always be given to human health and the environment - the pivotal factors for human well being - and the focus should remain on the implementation of EU legislative measures aiming to ensure a high level of protection for humans and the environment.
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