European Commission’s Fitness Check roadmap on Endocrine Disruptors - - PAN Europe’s feedback

Civil society organisations, Member States, and the Endocrine Society criticised the criteria for being too narrow and for setting the burden of proof too high: only certain classes of EDCs are addressed, and for each chemical they require to identify the endocrine mode of action, the adverse effect and the plausible biological link between the two3. [...] Resources should be spent on the implementation of the current EU law measures that address EDs, application of available OECD ED testing for dangerous chemicals in the market (pesticides and biocides), development and endorsement of new scientific methods to identify EDs, establishment of an assessment method to address chemical mixtures (required by EU law since 2005) and development of non-chem. [...] In the case of pesticides and biocides - two chemical classes with biological activity, hence the risk they may interfere with the endocrine system is high - the Regulations call for substances that meet certain ED scientific criteria not to be authorised, with some exceptions on restricted use (e.g. [...] The higher the chance of human and environmental exposure to dangerous substances, the stricter the regulation should be. [...] Priority should always be given to human health and the environment - the pivotal factors for human wellbeing - and the focus should remain on the implementation of EU legislative measures aiming to ensure a high level of protection for humans and the environment.