On Monday March 22nd, CHEM Trust participated in a Commission meeting which discussed the next steps on EU action on endocrine disruptors. As we described in our recent blog, the question on how endocrine disrupting chemicals (EDCs) can be better identified in the context of EU regulation for classification, labelling and packaging (CLP) is one of the important upcoming decisions in 2021.
The inclusion of legally binding identification criteria for EDCs in the CLP Regulation for application across all legislation was one of the Commission commitments set out by new European Chemicals Strategy for Sustainability. It aims to establish the horizontal classification and labelling of endocrine disruptors as is the case with other hazardous substances like carcinogens.
CHEM Trust has called for regulatory action on EDCs to be strengthened urgently for many years, and in July 2020 we presented a paper on what a new approach to protect people and wildlife in the EU from EDCs could look like.
Building on this, CHEM Trust, together with the NGOs HEAL and ClientEarth, has outlined how horizontal identification of EDCs should be included in the CLP Regulation. The new proposal was sent as an input to the expert meeting, on Monday, of the REACH and CLP competent authorities.
Identification of Suspected EDCs
Until now only around 20 substances have been identified as EDCs since the REACH legislation entered into force in 2007. Mainly due to the lack of sufficient data on chemicals, and the very strict criteria for identification under the biocides and pesticides legislation.
However, endocrine disruption is especially harmful to the developing foetus leading to deleterious effects after birth or later in life or even in the next generation. Thus, the identification of, and regulatory action on, substances that are suspected to be endocrine disruptors is crucial to ensure increased protection from exposure to these chemicals.
Our criteria proposal, including for identifying suspected EDCs, is based on the current EU criteria for endocrine disrupting biocides and pesticides. It also builds on lessons learnt from current identification processes in the EU such as from the ECHA ED expert group, which CHEM Trust attends as a stakeholder. It will be important to align the horizontal criteria for EDCs with the criteria for substances that are carcinogenic, mutagenic, or toxic to reproduction, meaning that substances are identified according to the level of evidence. Thus, substances will be identified as:
- Category 1: Endocrine disruptor (Known Cat. 1A and Presumed Cat. 1 B based on the source of evidence)
- Category 2: Suspected endocrine disruptor (Substances for which there is some evidence but not sufficient to meet the Category 1 criteria)
In addition, we make the suggestion to classify substances that are shown to have endocrine activity, as this together with adverse effects is defining for endocrine disruption.
- Category 3: Substance showing endocrine activity (Substances that show endocrine activity in specified in vitro tests)
The Commission will soon publish an early consultation on the way forward for the legal changes and will also present a proposal with changes to the legal text by the end of 2021; as set out in the EU Chemicals Strategy for Sustainability.
Pia Juul Nielsen, CHEM Trust EDC science and policy expert, said
The crucial issue for increasing the protection of the most vulnerable, such as the developing child, from exposure to endocrine disrupting chemicals is to also identify and adopt regulatory measures on suspected endocrine disruptors. These chemicals also need to be removed from everyday products to protect our health and the environment.