CHEM Trust has raised the alarm about the endocrine (hormone) disrupting properties of the chemical bisphenol A (BPA) for many years, highlighting that it is found in people and the environment. Unfortunately BPA is still in widespread use, as it is only banned in the EU in a few products such as baby bottles and thermal paper. But what is equally concerning is the increase in use of similar bisphenols, often replacing BPA, which create an additional threat to human health and the environment.
CHEM Trust have now submitted comments on a draft restriction dossier prepared by Germany, and sent to EU chemicals agency ECHA, which proposes to restrict the use of BPA and other bisphenols of similar concern, because of their effects on the environment.
We have previously highlighted the EU’s slow and piecemeal approach to the regulation of BPA and similar chemicals, and the need to draw lessons from this in the upcoming reform of EU chemicals law; including grouping chemicals together for regulation and application of a generic risk assessment approach, where the most harmful chemicals are banned from consumer uses.
The German proposal: too narrow a scope
In their draft restriction Germany proposes to ban five bisphenols, all of which have been officially identified as endocrine disrupters for the environment. The restriction proposes to ban all additive uses of BPA as well as polymeric uses under certain conditions, but it has many derogations which would allow continued use.
We very much agree with the need to restrict a group of bisphenols, to increase protection and avoid regrettable substitution of bisphenols. We have argued for many years that a group restriction for BPA and structurally related bisphenols is long overdue. In 2018 CHEM Trust published the report “From BPA to BPZ – a toxic soup?”, which highlighted the fact that companies are replacing BPA with other bisphenols with that have a similar hazard profile.
However, our analysis is that the German proposal needs to be stronger, expanding the scope of the group of bisphenols, and creating a better extension mechanism. In addition, derogations need to be more limited in order to achieve a more significant impact on reducing the emissions into the environment of BPA and bisphenols of similar concern. Any derogations should only be granted in exceptional cases based on well-documented reasons and with a time-limit.
Dr Ninja Reineke, Head of Science at CHEM Trust said:
It is very welcome that we are seeing a grouping approach proposed for the regulation of bisphenols in the EU. However, the group needs to be larger to cover all relevant bisphenols which may be used as regrettable substitutes. Group controls should be used as a tool for early action, even if the full hazard data to meet ED identification is not yet available.
It is vitally important to increase the effectiveness of this restriction, so that it supports the aims of the EU’s Chemicals Strategy for Sustainability, which commits to a ban on EDCs in consumer products.
Minimising human exposure: EU Commission needs to act
Although the intention of Germany’s proposed restriction is to minimise the emissions to the environment, bisphenols are also frequently found in people.
Recent human biomonitoring data from the EU research programme HBM4EU has again demonstrated the scale of human exposure to BPA as well as to other bisphenols. Data on bisphenol S and bisphenol F in urine shows that median levels of these BPA alternatives are increasing in all European regions.
We call on the European Commission to follow up on its commitment in the Restrictions roadmap to act on the concerns for human health from BPA and other bisphenols, and to ask ECHA to develop additional restrictions in order to better protect human health.