Today, CHEM Trust published a policy proposal on a new path to protect people and wildlife across Europe from endocrine disruptors (EDs).
The proposal, if implemented, would lead to:
- Rapid and improved identification of substances with ED properties.
- Strict control of substances with ED properties to avoid or minimize exposure.
- Full transparency and easily accessible public information on EDs .
Europe is in the process of developing a new Chemicals Strategy for Sustainability as part of the European Green Deal. The promised strategy`s aim, to minimise exposures to EDs, is a key component for a better environment and for health protection. Just last week the European Parliament adopted a resolution on the Chemicals Strategy and reaffirmed its call for a comprehensive European Union framework on EDs.
Why we need a new approach
The harmful impact of EDs on our health and the environment has been known for more than 20 years. Despite the adoption of a Community Strategy for EDs in 1999 and the 7th Environment Action Programme in 2013, that envisaged protective measures to minimise the exposure to EDs, the implementation of protective measures is proceeding very slowly.
In November 2018, the EU Commission released a Communication ‘Towards a comprehensive European Union Framework on endocrine disruptors’, however, this lacked concrete actions and measures. Instead of adopting immediate measures to minimise exposures to EDs, the EU Commission proposed yet another fitness check. The ED Fitness Check (which is still ongoing) aims to look at the coherence of different regulatory approaches to the assessment and management of EDs; asking if the current legislation delivers its objectives to protect human health and the environment.
In fact, the existing EU regulation to protect us from exposure to EDs remains patchy and is not consistent. For some few uses EDs are strictly regulated; for other uses only partly restricted and for many uses there are no control measures at all.
For example, criteria to identify EDs in biocidal products (BP) and plant protection products (PPP) have recently been established, however, these cannot easily be applied to chemicals in other regulatory sectors. In fact, no PPPs, only 2 biocides and only 17 substances under REACH have so far been identified as EDs. Thus, it is obvious that we need a new way forward to protect human health and the environment from exposure to these chemicals.
Key components of the new approach
The aim of the new proposal is to ensure that regulation of EDs is implemented in all relevant EU legislation; to better protect our health and the environment from these chemicals.
1. Overarching ED legislation
CHEM Trust proposes a new horizontal (cross-sectoral) ED approach that ensures that EDs will be adequately addressed by all relevant EU legislation referring to chemical substances and products. This approach makes use of the well-functioning parts of the existing regulation and combines these with a new overarching ED legislation followed by the necessary revisions/adaptions of the existing regulation.
2. One identification system: including a new category for Suspected EDs
New horizontal ED criteria should be based both on the full WHO definition of EDs, including for a potential ED, and the current criteria for endocrine disrupting BPs and PPPs. This would therefore include:
- Category 1: EDs – in line with the criteria for BPs and PPPs (which requires a high level of evidence for endocrine disrupting properties);
- Category 2: Suspected EDs (which there is a lower, but still substantial level of evidence for endocrine disrupting properties).
When a substance has been identified as an ED/Suspected ED this identification will automatically apply to all EU legislation.
3. Improved identification
More detailed information about the endocrine disrupting properties of substances needs to be provided during:
- the registration process under REACH;
- the authorisation for use as a plant protection product or biocidal product.
More detailed information should also be included in the context of the safety evaluation of cosmetics and personal care products.
By including a systematic procedure for information and data screening, an increased number of EDs and Suspected EDs will be identified.
4. Bans in consumer products
CHEM Trust proposes as a general principle that EDs (category 1 as described above) should not be allowed for sensitive uses, i.e. consumer use and widespread environmental use.
Suspected EDs (category 2 above) should be banned in consumer products, for example in food contact materials, toys, cosmetics and medical devices for consumer use. This will avoid the many inconsistencies in the way chemicals are currently identified and controlled with regard to endocrine disrupting properties across sectors, as seen for example with bans on health harming phthalates in some consumer products, but not all.
5. Speeding up the system: transition period for immediate protection
Interim ED criteria need to be set up to swiftly identify and control EDs until the new horizontal ED approach is implemented and functioning. The interim criteria would be based on current regulation, knowledge from well-established databases, and various EU and Member States work confirming strong suspicion for ED properties of a substance.
6. Full transparency and easily accessible information
There should be full transparency and easy access to information, i.e. publication of official EU lists of identified EDs and Suspected EDs. This will enable the public to make informed choices, will guide authorities in the prioritization of work and will guide companies in the substitution of EDs with safer alternatives. A specific labelling of chemical products to inform about the content of EDs or Suspected EDs should also be introduced.
Finally, CHEM Trust proposes that EDs should as default be considered as non-threshold chemicals and of particular concern. The seriousness of effects, including the issues of sensitive windows of exposure, low dose effects, non-monotonic dose responses and the irreversibility of effects, should all be taken into account in the assessment of substances with ED properties.
In conclusion
To minimise exposure to EDs it is very important to immediately:
- include strict control of EDs in all relevant EU legislation on chemical substances and products, e.g. for cosmetics, toys and FCMs;
- improve the basis for identification to swiftly identify all substances with ED properties, and
- ensure transparency of assessments and easy public access to official information on substances’ ED properties.
Pia Juul Nielsen, CHEM Trust EDC Science Consultant said:
“We call on the European Commission to urgently move ahead with the protection of EU citizens and the environment from the hazardous effects due to exposure to EDs.
Many years of protection have been wasted by internal fights and delaying tactics by certain parts of industry. Now it is time to have full European cooperation, ensure strict controls of EDs and immediately reduce consumer exposure via transition measures. In the end, it is the reproduction and brain development of future generations that is at stake.”
- The new ED policy proposal complements CHEM Trust’s earlier submissions to the ‘ED fitness check’ and the ‘Chemicals Strategy for Sustainability’ consultations and will also be sent as follow-up to the 2nd July meeting in the REACH CARACAL subgroup work on EDs.
- CHEM Trust is also a member of the EDC Free Europe coalition which sent a letter to the Environment and Health Commissioners in December 2019, highlighting the need to address EDs in the chemicals part of the European Green Deal.
- In 2018 the EDC-Free coalition adopted eight demands for an EU future without EDCs .
