The Danish Ecological Council welcomes the opportunity to provide comments to the European Commission road map 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. However, we are concerned that this new initiative with an ED fitness check will result in a further delay of the protection of the European citizens and the environment from harmful effects due to exposure to endocrine disruptors. This is especially 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.
The Danish Ecological Council is part of the EDC-Free Europe coalition, bringing together public interest groups representing 70 environmental, health, women’s and consumer groups across Europe who share a concern about hormone-disrupting chemicals (EDCs) and their impact on our health and wildlife. We therefore fully support the comments submitted by the EDC-Free Europe campaign.
In addition to the evaluations mentioned in the section “Data collection and Methodology”, we will recommend that the fitness check also considers various reports published by the Danish Centre on Endocrine Disrupters, in particular the reports “Information/testing strategy for identification of substances with endocrine disrupting properties” ( http://www.cend.dk/files/EDtestingstrategy.pdf); “Report on Interpretation of knowledge on endocrine disrupting substances (EDs) – what is the risk?” (http://cend.dk/files/ED_Risk_report-final-2019.pdf); and “Input for the REACH-review in 2013 on endocrine disrupters” (https://mst.dk/media/mst/9106721/rapport_input_for_the_reach-review.pdf).
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