Food Authority EFSA embraces industry proposal to stop safety testing of chemicals


European food watchdog EFSA proposes to substitute the actual testing of chemicals with a fixed exposure figure [1]. An adult can – according to EFSA – for most chemicals [2] safely eat 90 microgrammes (µg) of a single chemical every day for his or her entire life, called the TTC (Threshold of Toxicological Concern). The TTC is a proposal developed by the pesticide industry and is far from safe.

The TTC is based on old, outdated company data which EFSA has not checked because the original studies are non-retrievable. The TTC is calculated by excluding the most toxic (5th percentile) chemicals of the database. This means many chemicals in the industry database itself show toxic effects below this “safe” TTC derived level. The pesticide Dieldrin is 30 times more toxic than the TTC derived level.

By way of this manipulation, TTC is set at an extremely high level of exposure, allowing all kind of untested chemicals easy market access. In addition, infants, which are known to be more vulnerable, are not protected by the TTC and mixtures of chemicals are not calculated. The TTC is scientifically unjustifiable, artificially puts TTC at an extremely high level, puts adults, babies and children at great risk and only serves to get unlimited market access for chemicals.

The findings of independent (non-industry) scientific literature were not taken into account in setting the TTC. PAN Europe could easily falsify the extremely high TTC threshold with such independent scientific data. For endocrine disrupting chemicals, doses that are lower than the TTC derived value by a factor of 10, 100, 1000 and even up to 7500 have been shown to be toxic in independent studies. This means allowing people to be exposed to these chemicals at TTC level will directly cause adverse effects.

EFSA proposes use of TTC now for chemical impurities and metabolites but industry is already working hard to extend its use in all directions.  If the TTC were applied to the most dangerous class of chemicals, pesticides (which are sprayed intentionally on food), almost all pesticides would suddenly be classified as “safe” for humans and no testing would be needed anymore. Hans Muilerman of Pesticide Action Network Europe said: “It is unbelievable that EFSA, which claims to be a top-class scientific institute, is proposing to adopt this dangerous non-science-based proposal of the chemical industry. EFSA’s blind love for industry also allowed industry lobbyists and other known promoters of TTC in the panel adopting TTC.”

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Background notes:, the consultation is on the use of TTC for chemical impurities and metabolites

This is proposed for the so-called ‘Cramer class III’ substances, the majority of the chemicals. Industry defined also some smaller groups of chemicals with a higher or lower TTC (nerve poisons 18 µg/day and genotoxic carcinogens 9 µg/day) and some chemicals are excluded like dioxins and metals.

PAN Europe report on EFSA and TTC

PAN Europe letter to Mr. Dalli concerning TTC

For further information please contact:

Hans Muilerman, PAN Europe, hans [at],Tel: +31 (0)6-55807255

© PAN Europe, Rue de la Pacification 67, 1000, Brussels, Belgium, Tel. +32 2 318 62 55

PAN Europe gratefully acknowledges the financial support from the European Union, European Commission, DG Environment, Life+ programme. Sole responsibility for this publication lies with the authors and the funders are not responsible for any use that may be made of the information contained herein.