Health Care Without Harm (HCWH) Europe welcomes the opportunity to comment on this Roadmap.
The measures taken so far by the EU to ensure a high level of protection of human health and the environment from endocrine disrupting chemicals (EDCs) are not sufficient. The 2018 European Commission Communication "Towards a comprehensive European Union framework on endocrine disruptors" should in no way be considered an update of the 1999 Community Strategy for EDCs. This 11-page document fails to provide any proposal for specific measures, a timeline, targets, an action plan, or a budget.
Concrete action to prepare the next European strategy on endocrine disrupting chemicals (EDCs) is long overdue and urgently needed. The EU chemicals legislation must govern all types of EDCs to minimise the overall exposure to endocrine disruptors. Protecting specific population groups that are particularly vulnerable to EDCs such as unborn children and adolescents should be a focal point.
The Fitness Check should also ensure that all provisions on EDCs are fit for purpose to guarantee a clean circular economy and a non-toxic environment.
Our detailed contribution can be found in the PDF attached.
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