The EDC-Free Europe 

NGOs urge Member States to reject Commission’s 3rd revised proposal on EDC criteria see link FREE EU
To Health, Environment and Agricultural Ministers
Dear Minister,
The EDC-Free Europe NGO coalition urges your country to reject the European Commission’s 3rd revised proposal for identifying endocrine disrupting chemicals during the December 21st meeting of the Standing Committee of Food Animals Food and Feed. Although the revised version for pesticides has not been made public, we assume the identification criteria are the same as for biocides, whose texts have been released. We also understand that the proposal on the derogation remains the same – see point 1 below.
We are very concerned that this 3rd proposal fails to protect citizen’s health or the environment for the following reasons:
1) Derogation change from `negligible exposure` to `negligible risk`
The Commission claims legal authority to make the change from an article in the pesticides law that permits adjustments according to scientific advances. The scientific advance, which the Commission uses to justify the change to the risk-based approach is a key sentence in the 2013 scientific opinion from the European Food Safety Authority (EFSA). But recent newspaper investigations reveal that this key sentence was a pre-fabricated conclusion prior to the EFSA group even starting their work (For more details see the annex to this letter.) This news is deeply troubling and throws into serious doubt the scientific justification which underpins the Commission’s change to the derogation.
2) An excessively high burden of proof for identifying EDCs
Under the identification criteria proposed, it will be extremely difficult to identify an endocrine disruptor for regulatory action before people or the environment have been harmed. This is also the conclusion of the world’s leading scientific society specializing in hormones, The Endocrine Society, when they evaluated the prior proposal.
3) A new exemption for certain endocrine-disrupting characteristics
A new exemption has been introduced to excuse certain substances from identification (those with effects on moulting and/or growth), which could have wide ranging negative implications, in particular for wildlife. Firstly it contradicts the aim of the pesticides law to phase out use of endocrine disrupting pesticides and should therefore not be introduced as part of the identification criteria. Secondly, the identification criteria must be horizontally applicable, because they will have implications for the identification of EDCs under other laws. Exempting some Endocrine Disrupting characteristics from identification for purposes specific to the pesticides and biocides laws contradicts the commitment under the 7th Environmental Action Programme for horizontal criteria.
In summary, we understand that this 3rd version continues to propose a risk-based derogation that is founded on a contrived scientific justification to introduce an illegal change in the previously democratically agreed legislative text; contains mostly cosmetic changes to the overly-stringent identification criteria; and introduces a new exemption which excuses a certain set of endocrine disrupting characteristics from identification.
These proposals are unacceptable, and they do not respond to the growing public concern and mobilization for real action to reduce EDCs in our daily life. Over 220,000 EU citizens have signed an urgent petition to all European governments asking you to reject the EU Commission’s proposal.
With kind regards on behalf of the EDC-Free Europe coalition,
Genon K. Jensen
Executive Director, Health & Environment Alliance (HEAL)
In the view of the public interest in this matter we will make this letter available more widely.

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Philip Lewis

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