A new year provides an opportunity to reflect on achievements in the past year, and to prioritise actions in the year ahead. In CHEM Trust’s analysis, one vital objective is for the EU to improve the protection of people and wildlife from endocrine disrupting chemicals (EDCs).
Of the many serious and irreversible effects EDCs may have on important body functions, CHEM Trust is particularly concerned about effects on the developing brain, and impacts on the immune system, as well as the reproduction of people and wildlife. Human biomonitoring studies show that the general population is continuously exposed to many substances with endocrine disrupting properties, including bisphenols, fragrances, plasticisers and PFAS, so we know our concerns are well justified.
In 2020 the European Commission made some important promises on how it was planning to increase protection from EDCs. In 2021 these promises need to be delivered – but what are they and what will this mean?
EDCs: a priority in Europe’s Green Deal and Chemicals Strategy for Sustainability
CHEM Trust welcomed the European Commission’s Chemicals Strategy for Sustainability (CSS), published in October 2020, which includes promises for regulatory measures to minimise exposures to EDCs for people and the environment. A summary of the main commitments can be found in an article by the NGO coalition EDCFree Europe, which CHEM Trust is a member of.
Specifically we welcome that the Commission has promised to :
- Set up new horizontal identification of EDCs and present a proposal for hazard identification under the Classification and Labelling (CLP) Regulation in 2021
- Update information requirements and continue work to ensure that sufficient and appropriate information on endocrine disruption is available for the legislation covering industrial chemicals, biocides, pesticides, cosmetics, and food contact materials.
- Accelerate methods for identification of EDCs to generate more information on chemicals’ endocrine disrupting properties by screening and testing.
- Ban EDCs in consumer products as soon as they are identified, with derogations only for essential use.
At the 2nd Annual Forum on Endocrine Disruptors in December 2020 the European Commission presented the outcome of the Commission’s evaluation of the current regulation of EDCs (see CHEM Trust response to Fitness Check) as well as the future way forward. CHEM Trust was pleased to hear from Environment Commissioner Sinkevicius who emphasised that the entire Commission and the EU Council of Ministers acknowledge the urgency for protection from EDCs, and their commitments to act now.
As part of several contributions from the EDCFree coalition during the event, CHEM Trust outlined three urgent and crucial actions based on the results from the EDC fitness check:
1) Use existing tools such as group restrictions under REACH for immediate protection against EDCs
2) Improve EDC identification by expanded information requirements and identification of suspected EDCs
3) Minimise EDC exposure by treating EDCs as non-threshold substances
Three key processes on EU EDC policy in 2021
In CHEM Trust’s view, the following three EU EDC-related processes are crucial in 2021:
Priority 1: A new horizontal approach for identifying EDCs
- The Commission will present a new proposal for EDC identification under the Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP Regulation). Discussions will continue in a Commission expert group subgroup on EDCs (CASG ED) which CHEM Trust attends as a stakeholder organisation.
- As we pointed out in a policy paper, using CLP as the basis for hazard classification, similar to CMR substances, will be an important step forward to establish categories for EDCs reflecting the different level of evidence available. The creation of a category for suspected EDCs will be crucial for increased protection of health and the environment, for example through regulatory action to control dispersive and consumer uses. A suspected EDCs category will ensure that substances with endocrine disrupting properties are identified in a transparent way, and give a steer to companies as well as consumers.
- Only around 20 substances have been officially identified as EDCs in the EU since 2007. However several analyses have led to over 1000 substances being listed as potential EDCs.
- In CHEM Trust’s analysis, a categorisation for suspected EDCs is essential and we welcome the increasing support for this idea from EU Member State Governments as expressed at the 2nd Annual Forum on Endocrine Disruptors.
- A final Commission proposal amending the CLP Regulation to introduce new hazard classes for EDC identification is expected by the end of 2021, this will then be discussed and finalised by EU Member State governments and the European Parliament.
Priority 2: A ‘roadmap’ for accelerating restrictions
- The Commission has promised in its Chemicals Strategy for Sustainability that they will strengthen the existing regulatory framework by presenting a road map to prioritise EDCs for group restrictions under REACH
- CHEM Trust has repeatedly called for more use of group restrictions of EDCs to increase the level of protection and to avoid regrettable substitution, including in our report three years ago, “From BPA to BPZ: a toxic soup?
- The Commission is due to publish this ‘roadmap’ in 2021, and CHEM Trust will be maintaining pressure to ensure that these group restrictions are created in order to control the use of whole groups of similar substances with endocrine disrupting properties.
Priority 3: More data and methods supporting identification of EDCs
- A discussion on updating the REACH information requirements to ensure appropriate information about endocrine disrupting properties is already in progress. In our submission to the Commission expert group CASG ED we highlighted the need to improve the basis for identifying EDCs and expand information requirements; including by introducing a comprehensive literature search. We also advocate for a better integration of human and environmental data in the EDC assessments.
- When it comes to developing new tests for identification, CHEM Trust sees an urgent need to focus on effects on the developing brain due to thyroid disruption (as highlighted in our ‘No Brainer’ report in 2017). The OECD is working on the development of in vitro tests for thyroid disruption and there has been some promising progress and new test methods are under way.
- CHEM Trust also supports the quick uptake of new methods and knowledge in the EDC identification processes, including from the ongoing EU research initiative EURION.
It is clear that 2021 is a key year for advancing environment and health protection from EDCs in the EU. CHEM Trust will actively push for swift implementation of the Commission’s commitments to minimise exposure to EDCs together with our coalition partners in the EDC-Free Europe Coalition.
Pia Juul Nielsen, CHEM Trust EDC science and policy expert said:
“It is very positive to see the European Commission commitments to act now to protect EU citizens and the environment from exposure to EDCs – it is high time!
However, it will take many years to obtain the needed protection; regulatory measures need to be in place, identification methods need to be improved, and there is still a huge lack of knowledge on substances’ endocrine disrupting properties. Therefore, it is crucial to act on the current level of evidence by also identifying and regulating suspected EDCs.
It’s vital that the EU moves forward rapidly to turn these promises into action that will lead to a reduction in our exposure to endocrine disrupting chemicals.”