Thank you for giving the opportunity to comment to the European Commission Roadmap for the Fitness Check on EDCs. WECF is an NGO network working since more than 20 years on EDCs on national (Germany, France, the Netherlands), EU and international level. WECF is member of the EDC-free Europe Coalition. In our work we focus on the health impact from the exposure to EDCs on women, pregnant women and their foetus and children. Our comments on European Commission Roadmap for the Fitness Check on Endocrine Disrupting Chemicals go along with and refer to the comments of EDC-Free Europe.
WECF is concerned with the additional delay resulting from this procedure, especially considering that the current Commission has failed to deliver the protective measures as defined by the 7th EU Environment Action Programme (7th EAP). Released in 2013, the 7th EAP aims to ensure minimisation of exposure to endocrine disruptors. Several Commission reports have already pointed out the gaps in various pieces of EU legislation regarding these harmful hormone disruptors .
As emphasised 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.
In order to have a real added value, and given the magnitude of the health and environment concerns at stake as well as the many fitness checks on EU chemicals regulations undertaken over the last few years, it is essential the EDC Fitness Check focuses 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, such as pregnant women and children.
This approach should also be reflected in the international dimension foreseen in this 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.
Our detailed contribution can be found in the PDF attached.
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