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The CHEM Trust view on the EU consultation on criteria for Endocrine Disrupting Chemicals (EDCs)

We are now in the final week of the European Commission’s consultation on Endocrine Disrupting Chemicals (EDCs), and today CHEM Trust submitted our response to the consultation. [Update: consultation has now finished].

Here are some of the key points we make in our response:

  • We support the proposal to use three different categories to define endocrine disrupting chemicals – known endocrine disrupter, suspected endocrine disrupter, potential endocrine disrupter. This approach allows the best use of available scientific evidence, and is line with the system already in use for carcinogens, mutagens and reproductive toxins.
  • We oppose the proposal to have a system that sets an arbitrary and unscientific cut off based on claimed ‘potency’ levels. For more details see this answer about potency in our Endocrine Disrupting Chemicals FAQ.
  • We oppose any changes to existing laws, as we consider that they already give sufficient flexibility and exemptions.

CHEM Trust also criticised the narrow approach of the consultation and the fact that there are no questions addressing the benefits of EDC phase-outs for health and environment. A recent report for the Nordic Council estimated potential savings of hundreds of millions of € in health costs by reducing exposure to EDCs that cause male health problems.

CHEM Trust is calling on the Commission to properly investigate the potential benefits of a phase out of EDCs, particularly for human health, but also in relation to the stimulation of innovation to deliver a safer and more sustainable chemical industry. This benefits study should be an essential part of the Commission’s impact assessment.

Gwynne Lyons of CHEM Trust summed up our views when quoted in the Eastern Daily News in the UK:

“If you look at all the hormone-related cancers, they have all gone up in the last few decades,” she said.

“It cannot just be the genes, so the concern is that our exposure to any disruptive substances can be associated with cancer, low sperm count and other hormone-related diseases and disorders.

“The costs of those are enormous and if we have to look for alternative pesticides then I have every faith that the chemical companies can come up with them, if they are given a mandate to do so. This scare-mongering does nothing to help the debate.

“I don’t think any one substance is likely to be causing these effects, but if you think we are exposed to many plastics, pesticide residues and some from substances in the home, this consultation is about the EU trying to reduce that overall exposure.”

Our response has also been covered by Chemical Watch in their review of responses to the consultation.