The EDC Working Group has compiled all their scientific knowledge in the field of EDCs to produce a concise Recommendations Report (dated October 2020) aspiring to contribute to more science based policy at the EU level.
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ESE key recommendations towards a less toxic EU environment to the benefit of human and animal health
Background
Endocrinology is the study of the complex communication between different organs to regulate essential body functions through signalling by chemical messengers – hormones. These complex and sensitive functions must be maintained in balance throughout life to avoid various illnesses, impaired fertility and/or problems of growth and brain development.
Endocrine Disrupting Chemicals (EDCs) are chemicals that may obstruct, imitate, or interfere with the normal biological functions of hormones, and as such can cause many adverse effects to the wellbeing of humans. Disruption of hormones at sensitive life stages e.g. during foetal development can for example increase risk of illnesses later in life.
Exposure to EDCs has been associated with a variety of rare cancers (especially in children), impaired reproduction, osteoporosis, thyroid disease, metabolic illnesses (e.g. diabetes, hypertension and obesity), birth defects and numerous other diseases or impairments.
Economically, EDCs cost the EU28 (including the UK) approximately €157 billion a year in actual healthcare expenses and lost earning potential. This is a conservative estimation; costs may be as high as €270 billion or 2% of European GDPi. Large contributors are the healthcare costs for neurodevelopmental and metabolic disorders (e.g. obesity and diabetes).
Summary of key ESE recommendations towards a less toxic EU environment and better health for human and animal life
➢ Harmonise the EU regulatory framework in line with the WHO definition for EDCs and ensure horizontal interpretation and application
Currently, definitions, criteria for identification data requirements and testing requirements for EDCs widely diverge in EU legislation, which has led to numerous legislative loopholes. These loopholes give the industry the opportunity under EU law to ‘rehabilitate’ a compound identified as an EDC under other EU legislation. For example, some phthalates are banned in cosmetics but are allowed in food contact materials. Triclosan cannot be used in food contact materials and is banned as a biocide, yet it is still allowed in personal care products. Other unauthorized chemicals may be used in food contact plastics if their migration into food is below the detection limit of 10 ppb (10 µg/kg food), and if they have not been shown to be genotoxic, mutagenic, toxic to reproduction, or substances in nano-form. No previsions are currently made for endocrine disruptors.
Also, the criteria for identification of EDCs have so far not been harmonised, nor cross-sectorial regulations appliedii. The EU biocide vs. the EU pesticide regulations are for example not identical in their data requirements to identify a substance as being an EDC. They are only ‘very similar’ which already creates a fundamental issue provoking confusion, conflicts and lack of practicability and credibility. This is strengthened by the fact that also the information requirements within the two regulatory frameworks diverge, leading to different levels of confidence in the identification. Animal testing is inconsistent as well in EU law, no animal test data can for example be requested under the cosmetic EU legislation. It is dependent on animal data obtained from other regulatory frameworks (e.g. REACH) which increases the risk for missing an EDC compound under cosmetics regulations.
01/10/2020