The European Union is currently relying on a 19 year old strategy for much of its work on Endocrine (Hormone) Disrupting Chemicals (EDCs), chemicals that can disrupt the sensitive endocrine system of people and wildlife. The European Commission is now consulting on a ‘Roadmap’ “Towards a more comprehensive EU framework on endocrine disrupters”, which is part of the development of a renewed approach. In CHEM Trust’s response we are calling for a stronger focus on policies to reduce exposures to EDCs.
The EU´s Community Strategy on endocrine disruptors dates back to 1999 and so is rather outdated. Previous attempts to update it have failed due to internal Commission disagreements following intense lobbying from some parts of industry.
The 1999 Strategy had two main objectives:
- To identify the problem of endocrine disruption, its causes and consequences.
- To identify appropriate policy action on the basis of the precautionary principle in order to respond quickly and effectively to the problem, thereby alleviating public concern.
The document subsequently laid out a set of actions in the areas of research, international co-ordination, communication to the public and policy action including key instruments for risk management.
In contrast, the Commission’s proposed Roadmap mainly aims to provide a comprehensive picture and at taking stock where the EU stands today. It states that further action may include fostering research activities, implementing EU laws and cooperating globally, e.g. with OECD.
However, the Roadmap does not specify how current inconsistencies in EDC risk management will be solved, including the fact that EDCs are addressed in some areas of EU chemicals policy but not in others. For example, rules on industrial chemicals and pesticides have specific provisions for endocrine disrupters, but there are none in rules for chemicals used in food packaging.
In CHEM Trust response to the consultation we highlight three key issues for a future EU EDC Strategy:
- establishing measures with timelines for achieving the target of the 7th Environment Action programme to minimise exposures to EDCs
- giving a specific focus on actions to address the problem of combination effects of exposure to mixtures of EDCs from various sources
- speeding up the identification of EDCs. This will include updating test requirements with new screens and tests
Ninja Reineke from CHEM Trust said:
This Commission initiative looks backwards rather than forwards, like a Roadmap to where we started from. It is vital that the new EDC framework includes specific actions and timelines to ensure that a rapid reduction of exposures will be achieved
We are particularly concerned that major gaps in EU regulation, such as the lack of effective regulation of EDCs in food contact materials including packaging are not even mentioned in the Roadmap.
The EDC Free network, of which CHEM Trust is a member, had earlier published a position paper in May 2018 listing eight essential elements for a new European EDC Strategy.
At a recent European Parliament event co-organised by HEAL and MEP Pavel Poc, Denmark, Belgium and France all presented their own national EDC initiatives.
The Ministry of Environment and Food in Denmark argued in their comments on the Roadmap that it:
`does not reflect on the calls in the December 2016 Council Council conclusions on the sound management of chemicals for an Update of the EU Endocrine Disruptors Strategy and in the 7th Environmental Action Plan for a minimisation of exposure to EDs.´
- All the comments submitted to the Commission on the Roadmap are available at the Commission’s feedback page.
New UNEP reports highlight EDC worldwide initiatives
In other EDC news, the United Nations Environment Program (UNEP) recently published three reports providing a global overview of the initiatives, policies and scientific knowledge around identifying EDCs.
These reports have been welcomed by the Centre for International Environmental Law, but they also consider that the reports are only a first step.
- Our comments have been reported by Food Packaging Forum and in two stories in Chemical Watch – here and here.