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Brussels, 26 october 2000
Euro Coop's Comments to the Commission's Communication on a Community Strategy for Endocrine Disrupters
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 12 of the 15 Member States of the EU and in 4 Central and Eastern European countries. Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.
Euro Coop is greatly disappointed that the European Commission fails to address consumer issues properly in its Communication on a Community Strategy for Endocrine Disrupters (COM(99) 706). It only describes policy actions for more research, but fails to introduce precise proposals and timetables for actions in how to reduce exposures to known endocrine disrupting chemicals. In Euro Coop's opinion, an EU Endocrine Disrupters' Strategy should be based on consumer protection, the precautionary principle and producer responsibility.
In this context, Euro Coop would like to take the opportunity to call, once more, for a revised EU Chemical Policy in order to properly assess the impact of chemicals to human health and the environment as described in our position paper on Chemical Policy from January 1999.
Euro Coop calls for the following to be included in a Community Strategy:
- For the Commission to speed up the process of identifying the problem of endocrine disruption, its causes and consequences.
- The Commission must take immediate action in cases where vulnerable groups, like children, are exposed to known endocrine disrupting chemicals.
- To evaluate and test the remaining substances, not on the Commission's list, which may be potentially endocrine disrupting.
- Producers should be responsible for having new substances properly tested for containing any endocrine disrupting chemicals before being put on the market.
- Producers should be obliged to label their products with environmental declarations.
- To ensure that the consumers' voice is heard in all discussions on endocrine disrupters by encouraging voluntary co-operation between the EU, the industry and consumers.
- Information on endocrine disrupters should be made widely available by the Member States and by the Commission.
So far, scientific evidence, according to the EU Committee on Toxicity, Ecotoxicity and the Environment (SCTEE), has shown that there is increased incidence of breast cancer and other cancers in the reproductive organs, lower sperm counts and testes cancer, which might be linked to endocrine disrupting substances. On this basis, Euro Coop urges the Commission to speed up the process of identifying the problem of endocrine disruption, its causes and consequences. Meanwhile, the precautionary principle should apply due to the uncertainty about the scope of the problems related to endocrine disrupters. In particular, in cases where vulnerable groups, like children, are exposed to known endocrine disrupting chemicals, the Commission must take immediate action. These substances should be banned or phased out immediately.
Therefore, Euro Coop supports the Commission strategy to establish by the end of year 2000 a list of substances, which are or are suspected of being endocrine disrupting. But Euro Coop urges the Commission to use this list to identify the substances, which should be banned or phased out immediately.
When establishing the list the approach to identify potential endocrine disrupting substances should be comprehensive focusing on their use, dispersion and disposal throughout product life cycles. As well, a set of criteria for persistency, bio-accumulation and toxicity should be developed.
However, in the Commission's strategy it will only be a subset of the over 560 suspected substances, which have been identified by the Commission's consultants, that will be on the list for further research. In the light of the critique from the SCTEE at its plenary meeting on 5 September 2000, stating in their opinion that the list is incomplete and poor methodology have been used by the consultants, Euro Coop believes it is vital that the remaining substances, which may be potentially endocrine disrupting, are also evaluated and tested due to the hazardous effects they might have on humans and wildlife. Besides, legislation should be introduced to ensure that producers are responsible for having new substances properly tested for containing any endocrine disrupting chemicals before being put on the market.
To ensure that consumer protection is respected producers should be obliged to label their products with environmental declarations, which specifies the level of chemical substances in each product and the hazard category for each substance. This would allow the consumer to make an informed choice about whether or not to buy a particular product.
Furthermore, Euro Coop believes that legislative provisions should provide a general framework for encouraging voluntary co-operation between the EU, the industry and consumers to ensure that the consumers' voice is heard in all discussions on endocrine disrupters. Hence, Euro Coop welcomes that the Commission will continue to engage in regular consultations with the Member States, industry, and non-governmental organisations to exchange views on existing scientific data and results as well as regulatory issues.
Last but not least, Member States and the Commission should make information on endocrine disrupters widely available. The information should seek to accurately communicate all the uncertainties to the public and the actions that are being taken to address the uncertainties and the problem in general.
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