CHEM Trust welcomes the opportunity to provide comment on the European Commission roadmap for the fitness check on endocrine disruptors. We welcome the focus on protection of vulnerable population groups that are particularly sensitive to endocrine disruptors, and the particular attention to legislation that does not contain specific provisions for EDCs e.g. legislation of toys, cosmetics and food contact materials.
At the same time, we are very concerned that this new ED fitness check will result in an additional delay in the protection of the European citizens and the environment from harmful effects due to exposure to endocrine disruptors. This is even more concerning as the European Commission has failed to deliver the protective measures as defined by the 7th European Environment Action Programme (7th EAP) in order to ensure minimisation of exposure to endocrine disruptors.
CHEM Trust want to emphasize that gaps in various pieces of EU legislation regarding endocrine disruptors have already be pointed out in several EU Commission reports, roadmaps etc., and by MS and stakeholders already in the process of establishing criteria and providing inputs to a new and updated EU strategy on Endocrine Disruptors during the work under DG Environment 2010-2013. It is therefore unclear whether this fitness check will identify new important issues to take into account other than already identified by the different evaluations referred to in Section B and the “State of the Art Assessment of Endocrine Disrupters" from 2011 .
It is high time that the EU Commission takes immediate action and reflects that European citizens are increasingly and justified concerned because scientific research over many years has revealed increasing evidence that EDC exposure can adversely affect wildlife (as was already known over 20 years ago) and can contribute to several serious human diseases and disorders. These actions to reduce exposure to EDCs can be based on already available scientific literature as described in a recent report commissioned by the European Parliament .
In order not to further delay the process, it is therefore extremely important that the EDC fitness check includes a thorough analysis of all relevant EU legislation as regards protection against endocrine disruptors, including for all types of consumer products, and on this basis set up a horizontal approach for identifying and controlling endocrine disruptors across all relevant legislations with detailed proposals for revision of provisions or new legislation. The new approach should also ensure that future provisions on EDCs will be fit for purpose for supporting the goal of a non-toxic environment and a clean circular economy. Only then can a high level of protection for health and environment be achieved.
See also attached file for more comments and details.
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