Indecision, hesitation, and delays

No, you are not about to read an undergraduate essay on Hamlet - this is a blog about Endocrine Disrupting Chemicals (EDCs).

In a few days the experts from the Standing Committee on Plants, Animals, Food and Feed (PAFF Committee) and the Biocides Committee will meet. These two committees, chaired by the European Commission, consist of representatives from governments of all EU Member States. They are part of the Byzantine regulatory architecture that essentially ensures that countries control how the European Commission implements EU laws.

I would venture to say that by now the representatives sitting on these two committees must know each other pretty well - they must even be quite chummy in fact after all these meetings on EDCs. On the 28th February they will meet yet again to discuss the fourth revised version of the long awaited EDC criteria, that the European Commission was under a legal obligation to prepare by December 2013, nearly half a decade ago…

(Click here to consult the latest versions of the Biocides EDC Criteria and Pesticides EDC criteria).

The issue with EDCs is that they affect the way our hormones work. Mounting evidence coming not only from the Endocrine Society, but also the World Health Organisation (WHO) and the broader scientific community indicates that exposures to such EDCs in “animals and humans, especially during development, may lay the foundations for disease later in life. More than 1,300 studies have found connections between EDC exposure and serious health conditions” (See Endocrine Society’s 2015 Scientific Statement). Recently the European Commission identified DEHP, BBP, DBP, and DIBP as EDCs for humans under the EU’s REACH Regulation.

We welcomed this decision as part of the REACH process, however the European Commission is still under legal obligation to produce robust criteria on EDCs. Sadly, the revised EDC criteria proposal was issued on 8th February remains a source of concern, in particular the high burden of proof required to identify EDCs. The reaction of the majority of scientists and of civil society to this fourth iteration were therefore predictable.

The Endocrine Society was clear: European Commission's revised proposal limits the ability to protect public from endocrine-disrupting chemicals. EDC Free Europe (a coalition of NGOs and civil society representatives including HCWH Europe) was just as explicit in its letter to Mr Frans Timmermans, European Commission First Vice-President: the criteria as they stand are neither “efficient” nor “coherent”.

HCWH Europe shares these views and has also repeatedly pointed out that the proposed criteria do not tally with the precautionary principle approach. In an earlier blog (A group of scientists reveals that water boils at 60°Celsius) we questioned why the European Commission was straying from the precautionary principle in requiring such an exactingly high level of proof. It is odd for the European Commission to be out of step with the apparent consensus that seems to emerge amongst most independent scientists, the European Parliament, the EDC-Free Europe coalition and, presumably, any well-informed EU citizen.

Going beyond our specific health and environmental concerns, Christian Zahn (President of the International Association of Mutual Benefit Societies) has recently warned about the predictable strain on the public purse that will be caused by the ever rising cost of chronic diseases partially resulting from exposure to EDCs (See Commission must take action against endocrine disruptors, 09/02/2017).

Despite all of these valid arguments, it would seem that the European Commission is engaged in a dialogue of the deaf with the scientific community and those organisations representing civil society. Not so for voices coming from other corners however. After the publication on 12th December of EurActiv’s article: New Endocrine Disruptor Rules Address your Trade Concerns, EU tells US, Canada, we know that the European Commission is more receptive to other arguments. The article comments on the released memo (14th July 2016) saying: “The European Commission told US and Canada that draft EU pesticides laws would “address the concerns” they had over possible trade restrictions on goods exposed to endocrine disruptors”. 

At this stage, we are all aware that strong representations made by affected sectors or by broader international trade considerations have influenced the process - these have all been well documented. These interests, however, should only be given the attention they deserve in the face of the EU’s responsibility to provide robust criteria. After four ‘dry runs’, the time has come for the EU to act: produce criteria guided by science without seeking to accommodate private commercial interests. To close, I will raise a simple question: robust and science-based EDC criteria - “to be or not to be? That is the question”.


- Philippe Vandendaele, Chemicals Policy Advisor, HCWH Europe