Public consultation on EDCs not so «public»


The just-launched public consultation on Endocrine Disrupting Chemicals (EDCs) [1] is a request merely for scientific data and socio-economic impact assessments rather than public opinion. The questions are too technical for the general public, effectively allowing only the industry and research institutes to participate but in a limited amount of time to obtain new findings (3.5 months). PAN-Europe highlights that this approach is one step further in dismantling the democratically agreed rules in the EU and this type of impact assessment is not a remedy to the enormous health risks posed to the public by EDCs and chemicals.

The legislation on EDCs within the Plant Protection Products Regulation- PPPR 1107/2009 (EC) and Biocides Products Regulation- BPR 528/2012, is a story that started backwards. First, the European Parliament and Council voted in favor of the PPPR and BPR, which clearly state that “a substance…  shall only be approved if… it is not considered to have endocrine disrupting properties that may cause adverse effect in humans…” - known as a ’hazard-based’ cut-off approach, leaving the commission to subsequently define the criteria for EDCs identification. Thus, the law against the use of EDCs in PPP and Biocides was voted before establishing what an endocrine disruptor is.

In December 2013 the commission missed the deadline to publish the criteria that define EDCs. Previously, DG ENVI had published a draft version of the criteria following experts’ opinion, a version that provoked a reaction in the different DGs and stakeholders, as it revealed which chemicals would probably be removed from the market. To reach a consensus, the upper level of the Commission decided to first conduct an impact assessment on the different criteria options. In June 2014 the Commission (lead by DG SANCO and DG ENVI) published a roadmap explaining the different options for EDCs-criteria and for regulatory decision-making. The roadmap, as criticized by PAN-Europe [2], added socio-economic elements and further ways to exempt some harmful chemicals from the EDC cut-off in the PPPR. Following the roadmap, the Commision launched yesterday a public consultation to “hear the voice of the European Citizens”.

However, the commission will mostly hear the voice of the industry and research experts. The questionnaire of the consultation asks for data on the methodology used to assess EDCs, their potential substitutes and the outcome of the socioeconomic impact assessments on the different criteria options- being all too technical for the average european citizen. The structure of the consultation is such that without providing data, you cannot show disagreement.

Despite the importance of the public consultation as a regulatory tool, the one on EDCs will fail “to provide the public opinion”. PAN-Europe is concerned that questionaire facilitates the industry - the producer of these chemicals - to present biased data and thereby maintain EDCs in the market, often by refusing to accept scientific data that prove the opposite. Once again indusrty will outweigh the public opinion and humans will continue being exposed to these chemicals to whose contributione to the rise of endocrine-related diseases, such as cancer of the reproductive organs, diabetes and obesity, science is increasingly pointing.

-- ENDS --

Further information


2. Press Release 18th June

For further information please contact:

Angeliki Lysimachou, Tel: +32 (0)250 33137, angeliki [at]

© 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.