Thank you for giving the opportunity to comment on the Roadmap. The Fitness Check on EDCs presents another delay in the process to provide protection from EDCs for environment and health, especially for vulnerable groups. The current Commission has failed to deliver protective measures as described in the 7th EU Environment Action Programme (7th EAP) from 2013, which already aims to ensure minimization of exposure to EDCs. Several Commission reports have already pointed out the gaps in various pieces of EU legislation regarding these harmful hormone disruptors .
As emphasized by the European Parliament Resolution on EDCs, adopted on 18 April 2019 , and by the 26 June 2019 Environment Council conclusions "Towards a sustainable chemicals policy for the Union" , it is now urgent for the European Commission to uphold its commitments as per the 7th EAP and effectively reduce people’s exposure to EDCs in a comprehensive way throughout Europe.
The 2018 European Commission Communication "Towards a comprehensive European Union framework on endocrine disruptors" should in no way be considered as an update of the 1999 Community Strategy for EDCs. This eleven-page document fails to provide any proposal for specific measures, a timeline, targets, an action plan, or a budget.
To achieve a real added value, the Fitness Check should focus on assessing how to strengthen protection against EDCs through improved and new EU regulations. In this way, the EU can deliver on its objectives to protect human health and the environment from endocrine disruptors, and in particular vulnerable groups.
This approach should include international dimension of the Fitness Check exercise. Effective control of EDCs to ensure a high level of health and environment protection is not only essential for the purpose of imported products in the EU, but also in respect to the positions the EU is taking in multilateral initiatives for safer chemicals .
Finally, the Fitness Check must also ensure that future provisions on EDCs will be fit for purpose to guarantee a clean circular economy and a non-toxic environment.
The approach of hazard identification is key for regulations on endocrine disrupting chemicals and will lead to better control of these substances.
The Fitness Check on endocrine disruptors should thoroughly take into consideration the analysis and conclusions from the report commissioned by the European Parliament: “Endocrine Disruptors from Scientific Evidence to Human Health Protection” March 2019 .
On the horizontal approach and criteria for the identification of endocrine disruptors:
The 7th EAP requires in particular the EU to “develop harmonised hazard-based criteria for the identification of endocrine disruptors." These criteria must be based on the definition from the World Health Organization (WHO). In addition, full consideration of the differences in data availability is essential in order to ensure that substances are not being considered as safe just because not enough data are available to classify them as EDCs. It is also essential to ensure a higher level of transparency to indicate which substance has been assessed or in the process of being so.
The inadequacy of the criteria adopted for the identification of EDCs under the Plant Protection Products regulation and the Biocidal Products regulation must be addressed. EDC-Free Europe has repeatedly warned that these criteria are not sufficient to protect human health and the environment.
On regulatory consequences for endocrine disruptors:
The different regulatory approaches for ED substances depending on the different pieces of legislation should not necessarily be taken as a problem or an indication of incoherence, as the text of the Roadmap seems to suggest. The deliberate choice of the EU.... full paper see attachment.
The views and opinions expressed here are entirely those of the author(s) and do not reflect the official opinion of the European Commission. The Commission cannot guarantee the accuracy of the information contained in them. Neither the Commission, nor any person acting on the Commission’s behalf, may be held responsible for the content or the information posted here. Views and opinions that violate the Commission’s feedback rules will be removed from the site.