2023 | July / August 2023

EU Chemicals Strategy for Sustainability: implications for the regulation of endocrine disrupting chemicals

by cyb2025

DAVID ANDREW*, SCOTT SAMUELS, APOSTOLOS KOUTSAFTIS, RICHARD ELSMORE
*Corresponding author
ERM, The Exchange, Harrogate HG1 1TS, United Kingdom

ABSTRACT

The 2020 EU Chemicals Strategy for Sustainability (CSS) has a strong focus on endocrine-disrupting (ED) chemicals, due to perceived concerns over their effects on human health and the environment. The CSS envisages strengthening both the CLP and REACH Regulations with respect to ED chemicals; the CLP Regulation has recently been amended to include additional classification categories for ED, and an ongoing review of REACH will introduce new ED-specific information requirements. These changes will be introduced alongside other measures, which together aim to prevent the development of ED chemicals and remove or restrict ED chemicals currently on the market.

BACKGROUND
The 2020 EU Chemicals Strategy for Sustainability towards a toxic-free environment (CSS) is intended to form a key part of the European Green Deal. While the CSS recognises the fundamental role that chemicals play in daily life, it also aims to address concerns over the perceived negative impacts of chemicals on human health or on the environment. The CSS therefore promotes a ‘safe and sustainable by design’ approach to chemicals, while proposing bans or restrictions on the use of those chemicals recognised as being hazardous and which are already on the market. Endocrine Disrupting (ED) chemicals are a particular focus of the CSS which states that exposure to ED chemicals is not only ‘a threat to human health’ but also ‘one of the key drivers putting the Earth at risk’, requiring specific attention due to their increased use and reported links to chronic and delayed health conditions. The CSS notes that exposure to ED chemicals during fetal development or puberty can cause subtle but irreversible effects, which often only become apparent many years later. The continued use of ED chemicals is seen as posing a serious risk to human health and wildlife, with consequent economic costs for society. Accompanying the CSS is the 2019 Commission Working document ‘Fitness Check on Endocrine Disruptors’ (1), which is intended to address inconsistencies between different pieces of EU Chemicals legislation.

ABOUT THE AUTHOR

David Andrew PhD, DABT is a Technical Consulting Director in the Product Stewardship and Regulatory Affairs group at ERM. David is a highly experienced toxicologist, having worked in research, government and consultancy for more than 25 years. He works with clients from the chemicals, pesticides and biocides industry, providing advice in areas including toxicology and ED testing strategies and data interpretation. He has a particular interest in reducing vertebrate testing through the use of in vitro and other non-testing methods, and increasing the regulatory acceptance of non-testing methods.

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