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Commission proposal on EDC criteria means human harm almost certainly needed before action

The European Commission has finally presented its long delayed criteria for identifying endocrine disrupting chemicals (EDCs) today. CHEM Trust is shocked by the proposal, which in effect means that there must almost certainly be harm to humans before a chemical can be identified as human EDC.

The Commission proposes a very scientifically demanding wording for identification of EDCs, calling for evidence to show that it is ‘known to cause an adverse effect’. This is in spite of the fact that the pesticides legislation currently refers to “endocrine disrupting properties that may cause adverse effect in humans“, a wording that is also proposed to be abandoned.  In contrast, the identification of a chemical as cancer causing (a carcinogen) is based on “presumed carcinogenic potential”.

The proposed criteria mean that though it is theoretically possible to identify a chemical as an EDC for humans without proof of humans already being harmed by the chemical, this is in reality extremely difficult. The time required to generate sufficient non-human evidence would be most likely to mean humans being harmed from ongoing exposures, even if the demanding experiments necessary to prove human adverse effects had not been done.

In addition to presenting criteria which will make identification extremely difficult without harm to humans and the environment, the Commission have proposed to weaken pesticides legislation. This weakening not only deletes the wording regarding “endocrine disrupting properties that may cause adverse effect in humans“, but also proposes changing a safety standard of ‘negligible exposure’ into ‘negligible risk’, which will mean more exposure of the environment and people to pesticides, even if they have been identified as EDCs.

Ninja Reineke, senior policy advisor at CHEM Trust, said:

“This cynical proposal is not going to protect people and wildlife from endocrine disrupting chemicals. By the time all the requirements for identification are met, it will already be too late and human harm is likely to have happened.

The EU is supposed to provide the public and environment with a ‘high level of protection’, but this proposal totally fails to do this. The proposal is unacceptable and must be radically improved by Member States otherwise the European Parliament should veto it.”

In CHEM Trust’s view the most effective – and scientifically realistic – way to identify EDCs is through a three category approach, as is already used for Carcinogens, Mutagens and Reproductive toxins. This approach has been supported by endocrinologists in a recent opinion piece in The Lancet Endocrinology & Diabetes.

Today’s announcement follows a consensus statement from a recent meeting where scientists agreed that the inclusion of potency should not play a role in the identification of EDCs, see CHEM Trust’s new analysis of this statement. In today’s proposal the Commission does not include a potency cut off, but instead makes the level of evidence required so high that it will, in most cases, prevent action on EDC chemicals.