Endocrine disruptors are substances of particular concern; in order to minimise or better avoid any risks, the use of these substances must be embedded in coherent and harmonised EU legislation. The EESC therefore endorses the European Commission communication on endocrine disruptors and calls for a coherent, consistent and holistic strategy that is based on scientific knowledge and includes an action plan with clear targets and deadlines.
Endocrine disruptors (EDs) are synthetic or natural chemical substances that alter the way in which the endocrine system works. Exposure to EDs is due to a number of different sources, such as residues of pesticides, metals and additives or contaminants in food and can consequently negatively affect the health of humans and animals, including metabolism, growth, sleep and mood.
The EESC therefore welcomes the Commission communication on EDs, which aims to protect human and animal health more effectively and respond to increasing concerns about EDs.
The EESC considers it particularly necessary to carry out a complete fitness check on current legislation, including the social and economic impact, in order to establish the real state of play.
Harmonised and coherent legislation
"Current legislation is fragmented and sometimes incoherent due to a lack of coordination. We need a holistic approach in order to create a legislative framework enabling us to deal with the use of EDs in a coherent, consistent and scientific way. The use of EDs must be based on the precautionary principle and thus in line with effective provisions that have already been adopted on biocides and pesticides," said Brian Curtis, rapporteur for the EESC opinion "Towards a comprehensive EU framework on endocrine disruptors" which was adopted during the Committee's March plenary session. Furthermore, a long-term strategy should be reinforced with a realistic action plan in order to set targets and deadlines.
Since several substances, for instance bisphenol A, often used as additives in various sectors, are dealt with in different ways, the EESC warns that consistency could become the main challenge for the EU and recommends sticking to the scientific principle of one substance, one toxicology.
"This means that the criteria for identifying a substance as an ED must be consistent and coherent across all regulatory fields in the EU. In order to ensure consistency, it might be useful to include the new strategy under the REACH cross-sectoral umbrella," explained the rapporteur.
EU support for transition period
The Committee also proposes that the strategy include an anticipatory approach as regards a possible negative impact on parts of Europe's economy. For instance, a ban or restrictions imposed on some substances or products, plausibly identified as EDs, could have a relevant impact on certain enterprises and workplaces.
"In order to facilitate the transition period and help both enterprises and workers – improving production techniques and mechanisms or updating skills respectively - a specific financial mechanism should be provided for," argued Mr Curtis.
Involvement of civil society is key to both awareness raising and research & innovation
Civil society could play a crucial role in developing or supporting national awareness campaigns, by passing on information about EU measures to protect Europeans' health and education and training incentives.
In a fast changing world, independent research must play a decisive role, not least to ensure transparency for individuals and stakeholders. Research and innovation (R&I) is also crucial in order to improve and complete knowledge about EDs. The Committee suggests a budget for R&I which is no lower than the current one under Horizon 2020.
In order to identify EDs early on, as well as to identify safe alternative substances and environmental remediation at an earlier stage, an additional budget line should be considered.
Lastly, the global aspect should not be underestimated. For this reason, the EESC endorses the Commission proposal for a more proactive EU role at global level, supporting the OECD in improving its tests.
Moreover, the EESC believes that the EU should promote sustainability and the upholding of ED provisions in bilateral and multilateral trade agreements.