Ref. Ares(2016)4049973 - 02/08/2016
Ref. Ares(2016)7049618 - 19/12/2016
The Consumer Voice in Europe
HORMONE-DISRUPTING CHEMICALS: WHEN WILL THE
EU ACT AGAINST THESE EVERYDAY TOXICANTS?
BEUC Position on the Regulation of Endocrine Disruptors
Contact:
– xxxxxx@xxxx.xx
BUREAU EUROPÉEN DES UNIONS DE CONSOMMATEURS AISBL | DER EUROPÄISCHE VERBRAUCHERVERBAND Rue d’Arlon 80, B-1040 Brussels • Tel. +32 (0)2 743 15 90 • www.twitter.com/beuc • xxxxxxxxx@xxxx.xx • www.beuc.eu
EC register for interest representatives: identification number 9505781573-45
Co-funded by the European Union
Ref: BEUC-X-2016-077 – 29/07/2016
1
Endocrine Disruptors: Why it matters
Hormone-disrupting chemicals or EDCs for short have been linked to severe human health
problems, including infertility, genital malformations, early puberty, obesity, cancer and
neuro-behavioural disorders.
Consumers may encounter these harmful chemicals in many commonly-used products.
Examples include skin creams containing propylparaben, phthalates in toys and textiles,
furniture with brominated flame retardants, and bisphenol A used in everything from plastic
flooring and paper receipts to food containers.
In theory, EDCs are regulated by several EU laws. In practice, however, implementation
of these laws falls short as the EU lacks concrete criteria that define what an ‘endocrine
disruptor’ is. Moreover, current risk evaluation methods largely overlook a chemical’s
possible endocrine disrupting properties. As a result, EDCs escape control despite the
urgent need to reduce consumer exposure.
Recommendations
For more than two decades, the EU has debated how to reduce public exposure to
endocrine-disrupting chemicals (EDCs). Conclusive evidence links EDCs to a range of
severe diseases and disorders. Therefore a renewed political commitment to protect people
and the environment against these toxic chemicals is urgent.
BEUC calls on EU leaders to:
Adopt scientific EDC criteria applicable to all relevant EU laws. EDC criteria
must identify both those chemicals we know are endocrine disruptors and those we
suspect. This would allow the EU to act on early warning signs and prevent potential
harm to its citizens and the environment.
Reject the Commission’s flawed proposal on criteria for endocrine
disruptors which will fail to adequately protect consumers.
Apply a precautionary approach in all relevant legislation. The possible public
health implications of EDC exposures and the uncertainties in risk assessment
underscore the need to replace EDCs with safer alternatives whenever possible.
Place the burden of proof on the economic operator, not the public.
Companies should be made responsible for demonstrating the safety of their
products. The evidence they provide should be assessed by scientific committees.
Make the presence of EDCs in consumer products more visible. Better
information about the use of known and suspected EDCs in products would allow
consumers to make informed choices on how to protect their health.
Update risk assessment and risk management methods to take into account
low-dose effects and the cumulative impact of different chemicals.
Increase funding for research to address knowledge gaps. It is crucial to
better understand the negative health effects of endocrine-disrupting chemicals on
human health and on the environment.
1
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Contents
1. An ubiquitous threat to consumer health ..................................................... 3
2. Broken Promises: EDCs escape effective control .......................................... 4
3. EDC criteria must identify all substances that may harm consumers ........... 5
4. The Commission disregards the need for precaution on EDCs ...................... 6
5. How the EU can better protect consumers against EDC ................................ 9
1. Streamline existing REACH processes with regard to EDCs .............................10
2. Amend the Cosmetics Regulation with regard to EDCs ...................................11
3. Strengthen sector and product legislation ....................................................12
4. Protect consumers through a powerful EU Market Surveillance System ............12
5. Improve transparency about EDCs in consumer products ...............................13
6. Revise the Community EDC Strategy ...........................................................14
6. Industry must assume responsibility and phase out EDCs ......................... 15
7. TTIP and Better Regulation distract the EU from regulating EDCs .............. 15
2
1. An ubiquitous threat to consumer health
As consumers, we are all unwitting participants in a dangerous experiment with potentially
sweeping consequences for our health. Endocrine disruptors1 refer to a group of chemicals
that interfere with the body’s sensitive hormonal system. Given their capacity to mimic,
interfere and block natural hormones, exposure to even tiny amounts of these chemicals
can cause severe and irreversible effects on
humans and wildlife, such as infertility or
hormone-related cancers.2
Exposure to endocrine-
Exposure to endocrine-disrupting chemicals
disrupting chemicals
(EDCs) occurs at home and at work, through
(EDCs) occurs at home
the air we breathe, the food we eat, and the
and at work, through the
water we drink. Because chemicals with
air we breathe, the food
endocrine-disrupting properties are found in
we eat, and the water we
many of the products we use every day, this is
drink
a risk that concerns us all. Evidence from six
product tests undertaken by BEUC’s members
illustrates the scope of our exposure:
Five out of eight cans of peeled tomatoes tested3 by the Danish Consumer Council
contained bisphenol A, a known endocrine disruptor.
UFC Que-Choisir, our French member, found4 known or suspected endocrine
disruptors, such as ethylhexyl methoxycinnamate, in
7 out of 17 sunscreens.
The phthalate DIBP was found in
two soft toys tested5 by German Stiftung
Warentest.
1 in 2 beauty balms tested6 by Altroconsumo in Italy contained either known or
suspected endocrine disruptors, such as propylparaben or butylparaben.
PFOA, a chemical with known endocrine-disrupting properties, was found in
three
out of six children’s jackets tested7 by the Norwegian Consumer Council.
The Danish Consumer Council found8 that in
4 out of 5 ’loombands’, a popular
children’s toy, concentrations of the phthalate DEHP exceeded legal limit values.
In all of these tests, however,
risky chemicals were found in some but not in all
tested products. Much of our exposure could be avoided as in many cases use of these
chemicals do not seem necessary for the final product. (The annexed test results from our
members corroborate this conclusion.)
1 According to the accepted World Health Organization/International Programme on Chemical Safety
(WHO/IPCS) definition, an
endocrine disruptor is
an exogenous substance or mixture that alters
function(s) of the endocrine system and consequently causes adverse health effects in an intact organism,
or its progeny, or (sub)populations. http://www.who.int/ipcs/publications/en/ch1.pdf?ua=1
2 See e.g. Andrea C. Gore
et al., Introduction to Endocrine Disrupting Chemicals (EDCs). A Guide for Public
Interest Organizations and Policy-Makers, Endocrine Society and IPEN, December 2014.
https://www.motherjones.com/files/introduction_to_endocrine_disrupting_chemicals.pdf
3
http://kemi.taenk.dk/bliv-groennere/test-bisphenol-still-found-canned-peeled-tomatoes
4
https://www.quechoisir.org/comparatif-creme-solaire-n697/
5
https://www.test.de/Kuscheltiere-Zwei-Drittel-fallen-durch-den-Sicherheits-und-Schadstofftest-4947548-
4947558/
6
http://emagazine.altroconsumo.it/?paper=testsalute&selDate=20141001
7
http://www.forbrukerradet.no/vi-mener/2015/fpa-mat-og-handel-2015/helseskadelige-stoffer-funnet-i-
norske-barnejakker/
8
http://kemi.taenk.dk/bliv-groennere/test-kemi-i-vedhaeng-til-loombands
3
Although the long-term impact of this ubiquitous exposure is not fully understood,
scientists warn that EDCs may cause severe diseases and disorders.9 In the EU, the cost
of EDC exposure has
conservatively been estimated at an astronomic €157 billion per
year.10 Against this background, the World Health Organisation and the UN Environmental
Programme have called the impacts of endocrine disruptors a “global threat” that needs to
be resolved.11
2. Broken Promises: EDCs escape effective control
The 7th Environmental Action Programme (EAP) commits the European Union to
develop
by 2015 horizontal measures to ensure “the minimisation of exposure to
endocrine disruptors.”12 Yet, to date, the pace of EU action to protect consumers against
EDCs remains inexcusably slow – or altogether absent. While several EU laws regulate
EDCs
in theory, their practical implementation falls short as they lack concrete criteria that
define what an ‘endocrine disruptor’ is. As a result, EDCs escape effective control under
current EU laws despite the urgent need to minimise consumer exposure.
Under EU pesticides laws,13
BOX 1 Four options for EDC criteria
the European Parliament and
Council set December 2013
The 2014 Commission Roadmap considers four options for possible
EDC criteria:
as a deadline for the
European Commission to
Option 1: no formal criteria are specified, but the interim criteria set
in EU pesticides laws could continue to apply.
adopt scientific criteria to
Option 2: use the WHO/IPCS definition to identify EDCs.
determine
endocrine-
Option 3: use the WHO/IPCS definition combined with three
disrupting properties. In line
categories based on the different strength of evidence for
with the 7th EAP, these laws
fulfilling the WHO/IPCS definition.
Option 4: use the WHO/IPCS definition and include potency as an
oblige the Commission to
element of hazard characterisation.
develop hazard-based EDC
criteria based exclusively on
BEUC supports Option 3 as it would allow the EU to respond to
early warning signs and prevent potential harm to its citizens
scientific evidence related to
and the environment.
the endocrine system.
BEUC rejects Option 4 which modifies the accepted scientific WHO
definition by introducing the vague notion of ‘potency.’ As
In
summer
2013,
the
expressed in the landmark BfR consensus statement*
Commission was about to
“potency is not relevant for identification of a compound as
publish draft EDC criteria.14
an endocrine disruptor.”
But a coordinated lobby
* Roland Solecki
et al., Scientific principles for the identification of endocrine disrupting
chemicals – a consensus statement. Outcome of an international expert meeting
attack by the chemicals and
organized by the German Federal Institute for Risk Assessment (BfR), Berlin, 4 May
pesticides industries derailed
2016
. http://www.bfr.bund.de/cm/349/scientific-principles-for-the-identification-of-
endocrine-disrupting-chemicals-a-consensus-statement.pdf
the democratic decision-
9 See e.g. A. C. Gore
et al., EDC-2: The Endocrine Society’s Second Scientific Statement on Endocrine-
Disrupting Chemicals, November 2015.
https://www.endocrine.org/~/media/endosociety/files/publications/scientific-statements/edc-2-scientific-
statement.pdf?la=en
10 This estimate includes
direct costs such as hospital stays, physicians' services, nursing-home care and other
medical costs as well as
indirect costs resulting from lost worker productivity, early death and disability, and
loss of intellectual abilities caused by prenatal exposure. This estimate however does not cover
intangible
cost such as a loss of life-quality.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4399291/
11 United Nations Environment Programme and the World Health Organization, State of the Science of
Endocrine Disrupting Chemicals 2012. Summary for Decision-Makers, 2013.
http://apps.who.int/iris/bitstream/10665/78102/1/WHO_HSE_PHE_IHE_2013.1_eng.pdf?ua=1
12
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013D1386
13 Respectively, the Plant Protection Products Regulation (EC) No 1107/20092 and the Biocidal Products
Regulation (EU) No 528/20123.
14
http://www.environmentalhealthnews.org/ehs/news/2013/pdf-links/2013.06.11%20EDC_Recommendation
%20Commission%20Draft.pdf
4
making process.15 Rather than adopt EDC criteria as required by the law, the Commission
instead decided to first conduct an assessment of possible socio-economic impacts,
deliberately ignoring the deadlines set in the law.
The Commission subsequently published a roadmap16 (see BOX 1) that compares various
options for EDC criteria and also considers changes to existing laws. A compulsory review
of the Cosmetics Regulation with respect to EDCs was meanwhile shelved and is now one
and a half years overdue.
The Commission’s failure to adopt scientific criteria is unlawful as established by
the General Court of the European Union in December 2015. Notably, the Court ruled17 that
criteria to determine endocrine-disrupting properties must be based on science relating to
the endocrine system only – independent of economic considerations.18 The Court further
found that the decision to carry out an impact assessment does not exonerate the
Commission from complying with the December 2013 deadline set in the Biocides
Regulation.
BEUC welcomes the Court’s landmark decision as a victory for European consumers. Our
everyday exposure to endocrine-disrupting chemicals – in our homes, workplaces and
communities – must stop in order to protect the health of current and future generations.19
3. EDC criteria must identify all substances that may harm consumers
An EU definition of endocrine disruptors needs
to capture
all chemicals that
may disrupt the
hormonal system; that is, both those
chemicals we know are endocrine disruptors
and those we suspect. Similar to chemicals
Similar to chemicals that
that cause cancer, change DNA or are toxic to
cause cancer, change
reproduction (CMRs), EDCs should be
DNA or are toxic to
classified and regulated. BEUC therefore
reproduction, EDCs
supports the introduction of a strict hazard-
should be classified and
based
classification
system,
where
a
regulated
distinction is made between
known,
presumed,
and
suspected EDCs. Such a system would
facilitate a simple classification scheme based
on available evidence. It would further enable
authorities to prioritise chemicals for regulatory attention.20
Compared to the policy
option presented in the Commission Roadmap,21 this is equivalent to ‘Option 3’.
15
http://corporateeurope.org/sites/default/files/toxic_lobby_edc.pdf
16
http://ec.europa.eu/smart-regulation/impact/planned_ia/docs/2014_env_009_endocrine_disruptors_en.pdf
17
http://curia.europa.eu/jcms/upload/docs/application/pdf/2015-12/cp150145en.pdf
18
http://curia.europa.eu/juris/document/document.jsf;jsessionid=9ea7d0f130d58da361001f9141699c35f1e0
bf49014d.e34KaxiLc3eQc40LaxqMbN4OchqSe0?text=&docid=173067&pageIndex=0&doclang=SV&mode=ls
t&dir=&occ=first&part=1&cid=639996
19 See also BEUC, Open letter to Commissioner Andriukaitis, The European Commission’s approach to
chemicals which can disturb the hormonal system, Brussels, 2 February.
http://www.beuc.eu/publications/beuc-x-2016-011_ec_approach_to_chemicals_which_can_disturb_the_
hormonal_system.pdf
20 See Rémy Slama
et al., Scientific Issues relevant to Setting Regulatory Criteria to Identify Endocrine
Disrupting Substances in the European Union, Environmental Health Perspectives, 25 April 2016.
http://ehp.niehs.nih.gov/wp-content/uploads/advpub/2016/4/EHP217.acco.pdf
21 European Commission, Roadmap: Defining criteria for identifying Endocrine Disruptors in the context of the
implementation of the Plant Protection Product Regulation and Biocidal Products Regulation, June 2014.
http://ec.europa.eu/smart-regulation/impact/planned_ia/docs/2014_env_009_endocrine_disruptors_en.pdf
5
Our position aligns with the recommendations of international scientists,22 the European
Parliament23 and the EDC-Free Europe coalition.24 It is likewise in line with the judgment
of the European Court of Justice.25 In their review of the four criteria options proposed by
the Commission, epidemiologist Rémy Slama and colleagues for example conclude:26
“Only options 2 and 3 comply with science. […] We believe that, because of the parallel
with definitions of carcinogenic hazards (which have different categories based on evidence
levels) and because it calls for the identification of suspected EDs, Option 3 is more
relevant.”
4. The Commission disregards the need for precaution on EDCs
On 15 June 2016, after a delay of almost three years, the European Commission announced
a set of proposed criteria for the identification of endocrine disruptors.27 BEUC welcomes
that the Commission acknowledges28 the scientific consensus29 that
potency is not
relevant for scientific criteria to identify endocrine disruptors.
BEUC nonetheless strongly opposes the
proposed criteria as the Commission’s
approach contradicts the precautionary
principle, namely that protective action
should prevail in the face of scientific
If the proposed criteria
uncertainty. The proposed criteria will force
were applied, bisphenol A
regulators to await evidence that a chemical
– a widely acknowledged
beyond doubt causes harm, before they can
endocrine disruptor –
take protective action – but by then the harm
would not be recognised
to human health and the environment would
as such
already have occurred.30 BEUC in consequence
urges Member States and the European
Parliament to reject these flawed criteria
and to demand that the Commission
amends its proposal in line with Option 3.
22 See Jean-Pierre Bourguignon
et al., Science-based regulation of endocrine disrupting chemicals in Europe:
which approach?
The Lancet Diabetes and Endocrinology. 13 June 2016.
http://www.thelancet.com/journals/landia/article/PIIS2213-8587(16)30121-8/
23 European Parliament resolution of 14 March 2013 on the protection of public health from endocrine
disrupters (2012/2066(INI)), notably proposing “
the introduction of ‘endocrine disrupter’ as a
regulatory class, with different categories based on the strength of evidence.”
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P7-TA-2013-0091+0+DOC+
XML+V0//EN
24
http://www.edc-free-europe.org/
25
http://curia.europa.eu/jcms/upload/docs/application/pdf/2015-12/cp150145en.pdf
26 Rémy Slama
et al., Scientific Issues relevant to Setting Regulatory Criteria to Identify Endocrine Disrupting
Substances in the European Union, Environmental Health Perspectives, 25 April 2016.
http://ehp.niehs.nih.gov/wp-content/uploads/advpub/2016/4/EHP217.acco.pdf
27
http://europa.eu/rapid/press-release_IP-16-2152_en.htm
28 Communication from the Commission to the European Parliament and the Council on endocrine disruptors
and the draft Commission acts setting out scientific criteria for their determination in the context of the EU
legislation on plant protection products and biocidal products (COM/16/0350)
29 Roland Solecki
et al., Scientific principles for the identification of endocrine disrupting chemicals – a
consensus statement. Outcome of an international expert meeting organized by the German Federal
Institute for Risk Assessment (BfR), Berlin, 4 May 2016
. http://www.bfr.bund.de/cm/349/scientific-
principles-for-the-identification-of-endocrine-disrupting-chemicals-a-consensus-statement.pdf
30 See Endocrine Society, Endocrine Society Experts Concerned EU Chemical Criteria Will Not Protect Public,
July 2016.
https://www.endocrine.org/news-room/current-press-releases/endocrine-society-experts-
concerned-eu-chemical-criteria-will-not-protect-public
6
Against the advice of international scientists,31 32 the Commission proposes an
unprecedented burden of proof for a chemical to be defined as an endocrine disruptor. The
Endocrine Society, which speaks on behalf of the world’s preeminent EDC experts,
concludes33 that this restrictive definition sets “the bar so high that it will be challenging
for chemicals to meet the standard, even when there is scientific evidence of harm.” As a
result, few chemicals will be identified and regulated as endocrine disruptors.
In effect,
the Commission’s proposal would prevent the EU from effectively protecting its
citizens and the environment against the threat of EDCs.
Specifically, the Commission’s proposal is fundamentally flawed because:
The criteria demand an onerous level of proof for a substance to be defined as
an endocrine disruptor. The Commission proposes to identify chemicals as endocrine
disruptors only when evidence of
known adverse effects in humans and wildlife exists.
This is a notably stricter approach than current EU practice for chemicals that cause
cancer, change DNA or are toxic to reproduction (CMR). Proving a causal relationship
between a chemical and its effect in humans is notoriously difficult. In fact, most CMR
substances are only presumed to cause these effects.34 35 In contrast, the proposed
criteria replace expert judgement of presumed effects with the much stronger demand
that a chemical is
known to cause an endocrine-disrupting adverse effect relevant for
human health.36
Few substances will meet this unprecedented standard of proof, including some that
are already recognised to be endocrine disruptors. The French, Danish, and Swedish
governments for instance conclude37 that if the proposed criteria were applied,
bisphenol A – a widely acknowledged endocrine disruptor that the EU for example has
banned in plastic baby bottles – would not be recognised as such. The health impacts
of EDCs can take years or even generations to appear, and the Commission’s approach
would allow chemicals to cause significant harm before they finally are regulated.38
It would hinder an effective EU response to substances suspected of
endocrine disruption. Systematic identification of chemicals that may cause
endocrine disruption would allow the EU to act on early warning signs and prevent
potential harm to its citizens and the environment. Consistent with EU practice for
substances of equal concern, such as CMR substances, endocrine disruptors should be
classified and regulated using categories that express the degree of concern based on
31 Marlene Ågerstrand
et al., Open letter in response to the proposed criteria for identification and regulation
of endocrine disrupting chemicals, under the PPP and Biocides Regulations, 6 July 2016.
http://policyfromscience.com/wp-content/uploads/2016/07/Open-Letter-to-Andriukaitis-about-EDC-
Criteria.pdf
32 Andreas Kortenkamp
et al. EU regulation of endocrine disruptors. A missed opportunity,
The Lancet
Diabetes and Endocrinology. 1 July 2016.
http://thelancet.com/journals/landia/article/PIIS2213-
8587(16)30151-6/fulltext
33
https://www.endocrine.org/news-room/current-press-releases/european-commissions-overreaching-
decision-fails-to-protect-public-health
34 ClientEarth, How will the EU identify EDCs and ban or approve their use? The Commission cannot change
the scope and basis of the mechanism through the back door, July 2016.
http://www.documents.clientearth.org/wp-content/uploads/library/2016-07-08-summary-of-analysis-of-
european-commission-proposals-and-legal-requirements-concerning-the-determination-of-scientific-criteria-
to-identify-endocrine-disruptors-coll-en.pdf
35 Substances presumed to cause endocrine disruption were in fact included in the original ‘Option 2’ outlined
in the Commission roadmap, see
http://ec.europa.eu/smart-
regulation/impact/planned_ia/docs/2014_env_009_endocrine_disruptors_en.pdf
36 Andreas Kortenkamp
et al. EU regulation of endocrine disruptors. A missed opportunity,
The Lancet
Diabetes and Endocrinology. 1 July 2016.
http://thelancet.com/journals/landia/article/PIIS2213-
8587(16)30151-6/fulltext
37
http://www.regeringen.se/globalassets/regeringen/dokument/miljo--och-
energidepartementet/pdf/vytenisandriukaitis.pdf
38 See Endocrine Society, Endocrine Society Experts Concerned EU Chemical Criteria Will Not Protect Public,
July 2016.
https://www.endocrine.org/news-room/current-press-releases/endocrine-society-experts-
concerned-eu-chemical-criteria-will-not-protect-public
7
available evidence.39 The Cosmetics Regulation and the Toy Safety Directive for
example prohibit use of known, presumed
and suspected CMR substances. A parallel
approach should be taken for chemicals with endocrine-disrupting properties.
The Commission concludes40 that EDC criteria must define only what an endocrine
disruptor is, not what it may be. We fundamentally disagree. EU pesticides laws
expressly address chemicals with endocrine-disrupting properties that
may cause
adverse effects or for which scientific evidence of
probable serious effects to human
health or the environment exists. The proposed criteria thus run counter to the
democratic decision of the European Parliament and Member States. Moreover, by
excluding potential endocrine disruptors, the Commission disregards the need for
precaution on EDCs.
The Commission exceeds its mandate by proposing changes to the law: first,
the Commission proposes to change the wording in the Plant Protection Products
Regulation from the conditional ‘may cause adverse effects in humans’ to the
affirmative ‘having endocrine disrupting properties with respect to humans’. This
change however contradicts the precautionary approach that the co-legislators
deliberately chose to underpin the law.
Second, the Commission proposes to broaden the derogation in the Plant Protection
Products Regulation from ‘negligible exposure’ to ‘negligible risk’. If this risk-based
derogation is adopted, toxic substances that otherwise would be banned under the
law’s hazard-based approach could be allowed to stay on the market. In effect, the
Commission’s proposal would thus lower the level of protection sought by the co-
legislators. By proposing to change a crucial approval mechanism, the Commission in
short exceeds the limits of its delegated powers.41
It ignores the political commitment to develop horizontal EDC criteria
applicable to all current and future laws set out in
the 7th Environmental Action
Programme. The Commission’s proposal is developed exclusively based on a sectoral
view (pesticides). It is however unclear if the proposed criteria can be applied to other
sectors or product groups, such as for example cosmetics. Unlike data-rich pesticides,
the EU ban on animal testing of cosmetics ingredients means that in many cases
insufficient evidence is available to meet the standard of proof proposed by the
Commission. If applied to cosmetics and other consumer products, the Commission’s
proposal could jeopardize the need to protect consumers against chemicals with
endocrine-disrupting properties.
As a result of the unprecedented burden of proof and the proposed legal changes, few
chemicals will be defined and regulated as endocrine disruptors, even when there is
compelling scientific evidence of harm.
We again insist that the Commission amends
its proposal according to the recommendations outlined above.
39 See Rémy Slama
et al., Scientific Issues relevant to Setting Regulatory Criteria to Identify Endocrine
Disrupting Substances in the European Union, Environmental Health Perspectives, 25 April 2016.
http://ehp.niehs.nih.gov/wp-content/uploads/advpub/2016/4/EHP217.acco.pdf
40 Communication from the Commission to the European Parliament and the Council on endocrine disruptors
and the draft Commission acts setting out scientific criteria for their determination in the context of the EU
legislation on plant protection products and biocidal products (COM/16/0350).
41 See ClientEarth, How will the EU identify EDCs and ban or approve their use? The Commission cannot
change the scope and basis of the mechanism through the back door, July 2016.
http://www.documents.clientearth.org/wp-content/uploads/library/2016-07-08-summary-of-analysis-of-
european-commission-proposals-and-legal-requirements-concerning-the-determination-of-scientific-criteria-
to-identify-endocrine-disruptors-coll-en.pdf
8
5. How the EU can better protect consumers against EDC
A renewed political commitment to reduce consumer exposure to EDCs is urgent. The
possible public health implications of EDC exposures and the uncertainties in risk
assessment underscore the need to respond to early warning signals and to replace EDCs
with safer alternatives whenever possible.
BEUC therefore calls on EU leaders to draw
up an ambitious agenda on regulating EDCs in all consumer goods with clear
objectives and observable deadlines.
A precautionary approach should be applied in
all consumer relevant legislation to reduce
exposure to EDCs. This approach needs to
include overarching principles on how to
reduce EDC exposures, combined with
targeted strategies for all product categories,
Where health concerns
from cosmetics to food contact materials,
are raised, it should
textiles and toys. Where health concerns are
automatically trigger
raised in one sector or for one product, it
risk evaluation across
should automatically trigger risk evaluation
legislative ‘silos’ to
across legislative ‘silos’42 to fully assess the
ensure swift action in
impact of cumulative exposures and to ensure
the absence of scientific
swift action in the absence of scientific
certainty
certainty. The EU should systematically make
industry responsible for providing sufficient
evidence to demonstrate safety. All evidence
provided by industry needs to be verified and
assessed
by
independent
scientific
committees.
The EU should aim for a more holistic and coherent approach to risk management through
greater reliance on grouping of chemicals.43 This would also help avoid situations where a
chemical with endocrine-disrupting properties is substituted with chemically related
substances with similar hazardous properties. Growing evidence for example suggests that
bisphenol F and bisphenol S, two common substitutes for the endocrine disruptor bisphenol
A, are also endocrine disruptors.44 Such ‘regrettable substitutions’ clearly undermine efforts
to protect people and the environment.
Once adopted,
future EDC criteria must be implemented without delay.
Implementing criteria according to our recommendations will for instance contribute to
reducing consumer exposure to EDCs found as pesticide residues in food or as active
ingredients in e.g. antiseptic hygiene products, insect sprays or antibacterial cleaning
products.45 Based on the criteria, a systematic screening of existing product specific
legislation is needed to ensure that all relevant consumer legislation takes EDCs into
account. Here we highlight six areas where improvements in particular are urgent.
42 Richard M. Evans
et al., Should the scope of human mixture risk assessment span legislative/regulatory
silos for chemicals?
Science of the Total Environment 543, November 2015.
http://www.sciencedirect.com/science/article/pii/S0048969715309785
43
http://www.oecd.org/chemicalsafety/risk-assessment/groupingofchemicalschemicalcategoriesandread-
across.htm
44
http://ehp.niehs.nih.gov/1408989/
45 See CHEM Trust and Health and Environment Alliance, Challenges and solutions in the regulation of
chemicals with endocrine disrupting properties, no date.
http://www.env-health.org/IMG/pdf/36-
_heal_ct_edc_criteria_briefing_paper.pdf
9
1. Streamline existing REACH processes with regard to EDCs
Chemicals with endocrine-disrupting properties should be subject to
stricter control
under REACH. Based on the EDC criteria, authorities need to assess the endocrine-
disrupting potential of registered substances and, where necessary, pursue appropriate
risk management measures. Priority should be given to substances likely to come into
contact with the public, particularly with vulnerable populations such as infants, women of
childbearing age and pregnant women.
The EDC criteria should also play an
important role in determining how many
and which EDCs become subject to
restrictions
or
authorisation
under
By 2020, the EU has
REACH.46 EDCs identified as Substances of
committed to ensure that
Very High Concern (SVHC) should be
all relevant substances of
included on the REACH Authorisation List
very high concern,
and phased out without delay. Member
including those with
States and the Commission likewise need to
endocrine-disrupting
consider more restrictions on EDCs in
consumer products, especially in imported
properties, are placed on
goods.
the REACH candidate list
We thus welcome the French government’s
intention47 to classify bisphenol A (BPA) as a
SVHC on the basis of its CMR
and endocrine-disrupting properties. Sufficient evidence links
BPA to endocrine disruption and it should be phased out in all consumer products.48
Immediate action is likewise required against the 32 substances with scientifically
demonstrated endocrine-disrupting properties included on the SIN (‘Substitute It Now’)
List.49 The European Chemicals Agency, ECHA, and Denmark have recently proposed50
extensive restrictions on phthalates in consumer products, including those imported into
the EU. We strongly support this proposal.
Under the 7th Environmental Program, the EU has committed to “ensure that, by 2020, all
relevant substances of very high concern, including substances with endocrine-disrupting
properties, are placed on the REACH candidate list.”51 To achieve this goal, Member States
need to advance their efforts to identify substances with endocrine-disrupting properties
and depending on the outcome to nominate those substances for the candidate list.
Member States should also demand that inclusion of SVHCs on the Authorisation List is
accelerated.52
Against this background, we regret the recent decision to authorise use of the toxic
phthalate DEHP in recycled PVC despite the existence of safer alternatives. This decision
notably ignores the recommendation53 of the European Parliament which calls for a swift
46 See CHEM Trust and Health and Environment Alliance, Challenges and solutions in the regulation of
chemicals with endocrine disrupting properties, no date.
http://www.env-health.org/IMG/pdf/36-
_heal_ct_edc_criteria_briefing_paper.pdf
47
http://echa.europa.eu/registry-of-current-svhc-intentions/-/substance-rev/12537/term
48 BEUC, Bisphenol A Should Be Phased Out from Consumer Products, March 2011.
http://www.beuc.eu/publications/2011-00248-01-e.pdf
49 See ChemSec, The 32 to leave behind. The most well-founded list of EDCs relevant for REACH, no date.
http://chemsec.org/images/The_32_to_leave_behind_-_EDC_folder.pdf
50
http://echa.europa.eu/registry-of-submitted-restriction-proposal-intentions/-/substance-rev/13107/term
51
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013D1386
52 See European Environmental Bureau, A Roadmap to Revitalise REACH, November 2015.
http://www.eeb.org/index.cfm/library/a-roadmap-to-revitalise-reach/
53 European Parliament resolution of 25 November 2015 on draft Commission Implementing Decision XXX
granting an authorisation for uses of bis(2-ethylhexhyl) phthalate (DEHP) under Regulation (EC) No
1907/2006 of the European Parliament and of the Council (D041427 – 2015/2962(RSP))
10
end to the use of DEHP in all remaining applications. This decision risks setting a dangerous
precedent that could compromise the EU’s commitment to replace toxic substances with
safer alternatives.54
2. Amend the Cosmetics Regulation with regard to EDCs
Substances
with
endocrine-disrupting
properties are widely used as ingredients in
cosmetic
products,
for
example
as
preservatives. In joint test55 of 66 cosmetic
products, BEUC and International Consumer
The Commission has
Research and Testing (ICRT), in collaboration
with our British, Danish, French and Swiss
failed to assess whether
members, found high levels of substances
the Cosmetics Regulation
known
to
have
endocrine-disrupting
is fit to protect
properties. Similarly, the Norwegian Consumer
consumers against
Council found56 that one in two lip balms
cosmetics ingredients
contained one or more suspected EDCs.
with endocrine-
Although in all cases within legal concentration
disrupting properties
limits,
EU laws do not consider or regulate
the cumulative chemicals exposure from
daily use of multiple cosmetic products.
This suggests that the health of
consumers is potentially placed at
unacceptable risk.57
The Cosmetics Regulation instructs the Commission to review the regulation when
Community or internationally agreed criteria for identifying substances with endocrine-
disrupting properties are available, or
at the latest by 11 January 2015.58 Despite this
clear deadline, the Commission has so far failed to assess whether the Cosmetics
Regulation is fit to protect consumers against cosmetics ingredients with endocrine-
disrupting properties. We strongly criticise this delay which may create unnecessary health
risks for consumers.
The Austrian government has called on the Commission to present before the end of 2016
a concrete proposal for amending the EU Cosmetics regulation with regard to endocrine
disruptors.59 BEUC strongly supports this initiative.
It is paramount that a future amendment to the Cosmetics Regulation with regard
to endocrine disruptors protect consumers effectively, including from cumulative
exposures. Once EDC criteria have been adopted, the Commission should therefore
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+TA+P8-TA-2015-
0409+0+DOC+PDF+V0//EN
54 See e.g.
European Environmental Bureau, Stop! EEB sees red over DEHP authorisation application for PVC,
no date.
http://www.eeb.org/index.cfm/library/stop-eeb-sees-red-over-dehp-authorisation-application-for-
pvc/
55 BEUC & ICRT, Endocrine disrupting chemicals – analysis of 66 everyday cosmetic and personal care
products, 21 June 2016.
http://www.beuc.eu/publications/2013-00461-01-e.pdf
56
http://www.forbrukerradet.no/test/tester/leppepomade/
57 See BEUC & ICRT, Endocrine disrupting chemicals – analysis of 66 everyday cosmetic and personal care
products, 21 June 2016.
http://www.beuc.eu/publications/2013-00461-01-e.pdf
58 Art. 15(4) of the Cosmetics Regulation instructs the Commission to review the regulation with regard to
substances with endocrine-disrupting properties when “Community or internationally agreed criteria for
identifying substances with endocrine-disrupting properties are available, or at the latest on 11 January
2015.”
59
http://www.ots.at/presseaussendung/OTS_20160129_OTS0092/oberhauser-fordert-aenderung-der-eu-
kosmetikverordnung-und-schutz-vor-hormonell-wirksamen-stoffen
11
launch a comprehensive screening of all ingredients approved for use in cosmetic products
to assess their known
and potential endocrine-disrupting properties. Where a substance
can plausibly be linked to adverse effects, its use in cosmetics should be restricted – or
prohibited altogether.
3. Strengthen sector and product legislation
Robust chemical provisions are non-existent for many consumer products.60 REACH will not
compensate for these deficits as consumer goods – particularly imported ones – are barely
covered under REACH. Moreover, current EU chemicals-related legislation regulating
consumer products largely fail to set sufficiently ambitious thresholds to ensure adequate
protection of consumer health.
BEUC urges the Commission to review all consumer relevant legislation to ensure that the
risks associated with EDCs are adequately controlled. We in particular see a need to
strengthen requirements on chemicals with endocrine-disrupting properties in the Toy
Safety Directive61 and under the Regulation on Food Contact Materials,62 while special
precautions for EDCs in medical devices are needed.63 A product-specific approach to tackle
EDCs in textiles must also be considered.64 A clear deadline for this exercise is required to
guarantee that current loopholes are closed without delay.
4. Protect consumers through a powerful EU Market Surveillance System
Enforcement of EU consumer and chemicals-
related laws remains inadequate. In 2015,
25
per cent of total of notifications to the EU
Good laws are irrelevant if
RAPEX system were related to chemical
they are not enforced
risks,65 including toys containing phthalates, a
category of industrial chemicals known for
their
endocrine-disrupting
properties.
However, as a result of inefficient and ineffective market surveillance activities and a lack
of clear rules with regard to chemicals in consumer products,
this figure likely
represents only the tip of the iceberg. From a consumer perspective, it is unacceptable
that no EU harmonised market surveillance system is in place to ensure meaningful
controls in all Member States. Stricter market surveillance rules are urgently needed.
In February 2013, the European Commission proposed a Consumer Product Safety
Regulation and a Market Surveillance Regulation. This package contains important
innovations to enhance product safety, such as new rules on better traceability throughout
product supply chains.66 Despite backing from the European Parliament, Member States
continue to block this badly needed overhaul of the system. We regret this standstill which
60 See ANEC, Hazardous chemicals in products - The need for enhanced EU regulations, June 2014.
http://www.anec.eu/attachments/ANEC-PT-2014-CEG-002.pdf
61 ANEC and BEUC, EU Subgroup on chemicals in toys fails its mission. Critical review, November 2012.
http://www.beuc.eu/publications/2012-00799-01-e.pdf
62 See e.g. Health and Environment Alliance (HEAL), Food contact materials and chemical contamination,
February 2016.
http://www.env-health.org/IMG/pdf/15022016_-_heal_briefing_fcm_final.pdf
63 BEUC, Position on the Regulations on medical devices, March 2013.
http://www.beuc.eu/publications/beuc-
x-2013-031_ipa_medical_devices-beuc_updated_position-final.pdf
64 ANEC and BEUC, Protecting consumers from hazardous chemicals in textiles, March 2016.
http://www.beuc.eu/publications/beuc-x-2016-020_protecting_consumers_from_hazardous_chemicals_
in_textiles.pdf
65 European Commission, Press release. Protecting European consumers: toys and clothing top the list of
dangerous products detected in 2015, Brussels, 25 April 2016.
http://europa.eu/rapid/press-release_IP-16-
1507_en.htm
66 ANEC and BEUC, Position Paper on European Commission proposal for a Consumer Product Safety
Regulation, June 2013.
http://www.beuc.eu/publications/2013-00394-01-e.pdf
12
places consumers at unnecessary and unacceptable risk. Good laws are irrelevant if they
are not enforced.
Member States should promptly agree to a common European
market surveillance framework that will ensure a coherent and consistent
approach to the presence of dangerous chemicals, such as phthalates, in
consumer goods.
5. Improve transparency about EDCs in consumer products
At present, there is a serious lack of information on
which products contain chemicals with endocrine-
disrupting properties. As a result, it is almost
impossible for consumers to avoid these harmful
Given the little
chemicals.
More transparency about EDCs is
information available,
essential in particular for products which
consumers come in direct, close or regular
it is almost impossible
contact with, such as bed mattresses or textiles.
for consumers to
avoid products that
Article 33 of REACH establishes the consumers’
contain EDCs
right to be informed about substances of very high
concern present in products. It is however
generally recognised that this mechanism falls
short and needs to be strengthened.67 Research68 undertaken by BEUC and our members
for example found that consumers experience severe difficulties in accessing information
and that companies rarely have sufficient knowledge of their obligations under REACH. At
the same time, of the close to 800 chemicals with known or suspected endocrine-disrupting
properties,69 only a tiny fraction is included on the REACH Candidate list. Consumers are in
short denied reliable information about the vast majority of chemicals that may present a
risk to their health, including those suspected of being EDCs.
The European Parliament has urged “the Commission and the Member States to take
greater account of the fact that consumers need to have reliable information – presented
in an appropriate form and in a language that they can understand – about the dangers of
endocrine disrupters, their effects, and possible ways of protecting themselves.”70 We
strongly support this recommendation.
The EU should increase funding for organisations that work to inform the public about
EDCs, where they can be found and how they can be avoided. The Danish Consumer
Council has for example created a smartphone app, ‘kemiluppen’, which helps consumers
avoid cosmetics and personal care products with undesirable substances.71 By scanning the
product barcode consumers can access a chemical database and get answers immediately.
At present, this database contains information on more than 6.900 products, some 1.800
of which contains risky substances.72 To date, the app has been downloaded more than
67 See ECHA, Report on the Operation of REACH and CLP 2016, May 2016.
http://echa.europa.eu/documents/10162/13634/operation_reach_clp_2016_en.pdf
68 BEUC, Chemicals, Companies and Consumers - How much are we told? October 2011.
http://www.beuc.eu/publications/2011-09794-01-e.pdf
69 See e.g. Andrea C. Gore
et al., Introduction to Endocrine Disrupting Chemicals (EDCs). A Guide for Public
Interest Organizations and Policy-Makers, Endocrine Society and IPEN, December 2014.
https://www.motherjones.com/files/introduction_to_endocrine_disrupting_chemicals.pdf
70 European Parliament resolution of 14 March 2013 on the protection of public health from endocrine
disrupters (2012/2066(INI))
. http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-
//EP//TEXT+TA+P7-TA-2013-0091+0+DOC+ XML+V0//EN
71
http://kemi.taenk.dk/bliv-groennere/kemiluppen-runder-2-millioner-scanninger
72 If a product is not in the database, consumers can via the app submit snapshots of the product and its
ingredient list and ask that the product is assessed. When the product is assessed, the consumer receives
an email with the answer. The answer is also accessible to all others who scan the product.
13
100,000 times, and consumers have scanned more than 2 million products.73 We encourage
EU leaders to provide funding to allow this and other innovative tools to be replicated by
NGOs in other countries.
Greater transparency about known and suspected EDCs in consumer products
would in short allow consumers to make informed choices on how to protect their
health. Above all, however, we emphasise that improved transparency under no
circumstance should shift responsibility to the consumer for avoiding exposure. Only far
reaching regulatory measures as set out above are an acceptable solution to protect
consumer health and safety.
6. Revise the Community EDC Strategy
Given the mounting evidence74 unequivocally linking EDCs to chronic diseases and severe
disorders, the EU needs to revise the outdated 1999 Community EDC strategy75 on how to
protect the health of current and future generations. A primary policy objective must be to
lower human and environmental exposures to EDCs. A reinvigorated EDC strategy should
increase support for research to address data gaps and to develop the scientific
understanding regarding thresholds and low-dose adverse effects.76 BEUC would in
particular welcome initiatives that will achieve a better scientific understanding of the
effects of exposures during critical windows of development such as foetuses, young
children and pregnant women.
Risk assessment and risk management methods further need to be updated to take into
account low-dose effects of EDCs as well as the combined effect of different chemicals.77
Current EU legislation does not support a comprehensive and integrated assessment of the
cumulative effects of different chemicals. In its 2012 Communication on Combination
effects of Chemicals,78 the Commission committed to develop by June 2014 technical
guidelines to promote a consistent approach to the assessment of priority mixtures across
different EU laws. This has not happened.
BEUC urges the Commission to publish as soon as possible guidance documents promoting
an integrated and coordinated assessment across all relevant EU laws. Testing
requirements should also be updated to fully assess the impact of total EDC exposures and
of cumulative impacts, corresponding to the reality of our exposure.
73
http://kemi.taenk.dk/bliv-groennere/kemiluppen-runder-2-millioner-scanninger
74 See e.g. A. C. Gore
et al.,
EDC-2: The Endocrine Society’s Second Scientific Statement on Endocrine-
Disrupting Chemicals, November 2015.
https://www.endocrine.org/~/media/endosociety/files/publications/scientific-statements/edc-2-scientific-
statement.pdf?la=en
75 Communication from the Commission to the Council and the European Parliament - Community strategy for
endocrine disrupters - A range of substances suspected of interfering with the hormone systems of humans
and wildlife (COM/99/0706).
76 See Genon K. Jensen and Lisette van Vliet, Revising the EU Strategy on endocrine disruptors: nearing a
decisive moment, Journal of Epidemiology & Community Health, 9 November, 2012
. http://www.env-
health.org/IMG/pdf/jech_commentary_eu_edc_strategy_heal_website_.pdf
77 See Andrea C. Gore
et al., Introduction to Endocrine Disrupting Chemicals (EDCs). A Guide for Public
Interest Organizations and Policy-Makers, Endocrine Society and IPEN, December 2014.
https://www.motherjones.com/files/introduction_to_endocrine_disrupting_chemicals.pdf
78 European Commission, Communication from the Commission to the Council. The combination effects of
chemicals Chemical mixtures, May 2012.
http://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52012DC0252&from=EN
14
6. Industry must assume responsibility and phase out EDCs
Chemicals
with
endocrine-disrupting
properties must be replaced with safer
alternatives. Chemicals manufacturers and
their downstream customers therefore need to
phase out the use of such substances in all
Expensive does not
consumer products. The evidence from our
necessarily mean 'EDC
members’ comparative product tests tells a
free'. Our French and
compelling story: across diverse product
Belgian members found
groups, EDCs are present in some but not in
EDCs in some expensive
all products. (See annex) Moreover, neither
price nor brands appear to be a decisive
brand creams, but not in
factor. For example, in a test79 of 16 BB
the cheaper alternatives
creams,
Test-Achats/Test-Aankoop,
our
Belgian member, found EDCs in three
expensive brand creams, but none in the
cheaper alternatives. In a test of anti-aging
creams, UFC-Que Choisir likewise found EDCs in some expensive products, but not in the
cheaper alternatives.80
The evidence provided by our members thus demonstrate
that more often than not safer alternatives do exist.
Industry needs to live up to its repeated claims of safety and social responsibility.
Our
recommendation is clear: invest in safer alternatives and phase out chemicals
with endocrine-disrupting properties whenever possible. Progressive companies
have already committed to substitution.81 Danish retailer company, COOP, has for example
announced82 that it will remove bisphenol A from food cans in all the Group’s own brands.
H&M, IKEA, Kingfisher and Skanska are global companies dedicated83 to identify and phase
out substances with endocrine disrupting properties in their products. This shows that
choosing peoples’ health and the environment over profit is not only the responsible
approach; it is good for business!
7. TTIP and Better Regulation distract the EU from regulating EDCs
Against the backdrop of scandalous delays in regulating EDCs, the EU and the U.S. entered
the TTIP negotiations with a focus on reducing non-tariff barriers. BEUC sees a clear risk
that
current TTIP proposals would freeze progress on reducing consumer
exposure to EDCs.84 Regrettably, the threat that strong EDC criteria would jeopardise
TTIP appears already to have had an adverse effect on the EU decision-making process.85
The unambitious and inadequate criteria proposed by the Commission on 15 June only
confirm these concerns. We expect that with the conclusion of a formal agreement, this
regulatory freeze will intensify.
79
https://www.test-achats.be/sante/soins-du-corps/news/bb-et-cc-cremes-pas-de-miracles
80
https://www.quechoisir.org/comparatif-creme-antiride-n103/
81 ChemSec, The bigger picture. Assessing economic aspects of chemicals substitution, February 2016.
http://chemsec.org/wp-content/uploads/2016/03/The_bigger_picture_160217_print.pdf
82
https://om.coop.dk/presse/pressemeddelelser.aspx?nyhedid=13766
83
http://chemsec.org/wp-content/uploads/2016/06/Company-letter-to-the-Commission-2016-06.pdf
84 BEUC, The incompatible chemistry between the EU and the US. BEUC position on chemicals in TTIP, January
2016.
http://www.beuc.eu/publications/beuc-x-2016-007_beuc_ttip_and_chemicals_position_paper.pdf
85 Stéphane Horel and Corporate Europe Observatory, A Toxic Affair: How the Chemical Lobby Blocked Action
on Hormone Disrupting Chemicals, May 2015.
http://corporateeurope.org/sites/default/files/toxic_lobby_edc.pdf
15
In parallel, the Commission has launched a
fitness check of EU chemicals legislation
(except REACH) and a separate REFIT
evaluation of the REACH regulation. Much like
the TTIP negotiations, these REFIT exercises
If we are serious about
focus narrowly on identifying regulatory
protecting people’s
burdens to industry, quantifying costs, and
health and the health of
eliminating redundancies.86 This unbalanced
future generations,
emphasis on regulatory costs diverts attention
from a progressive agenda on regulating
Europe’s inaction on
chemicals of concern in consumer products,
endocrine disruptors
such as EDCs.
must come to an end
The Commission has repeatedly claimed that
neither the TTIP negotiations nor its Better
Regulation agenda threaten the EU’s high
standards of protection. Given that the primary objective of both agendas is the elimination
of regulatory costs to businesses87 – not the development of more ambitious EU policies to
protect consumers – these claims have never been particularly convincing.
TTIP and the Better Regulation drive must not serve to distract the EU from an ambitious
agenda on better protecting consumers against chemicals with endocrine-disrupting
properties. We remind EU leaders that safety delayed is all too often safety denied. If we
are serious about protecting people’s health and the health future generations, Europe’s
inaction on endocrine disruptors must come to an end.
END
86 ANEC and BEUC, Regulatory fitness check of chemicals legislation except REACH – a consumer view, May
2016.
http://www.beuc.eu/publications/beuc-x-2016-048_anec_beuc_chemicals_refit.pdf
87 See e.g. Pieter de Pous, Better Regulation. TTIP under the Radar? European Environmental Bureau, January
2016
. http://www.eeb.org/index.cfm/library/better-regulation-ttip-under-the-radar/
16
This publication is part of an activity which has received funding under an operating grant
from the European Union’s Consumer Programme (2014-2020).
The content of this publication represents the views of the author only and it is his/her sole
responsibility; it cannot be considered to reflect the views of the European Commission and/or
the Consumers, Health, Agriculture and Food Executive Agency or any other body of the
European Union. The European Commission and the Agency do not accept any responsibility for
use that may be made of the information it contains.
17
BEUC would like to thank the European Environment and Health Initiative (EEHI) for providing
funding for the development of this publication.
ANNEX - Non-exhaustive list of BEUC members’ comparative product tests, 2013-2016
BEUC Member
Country
Product/
No. tested
Products
Substance(s) found
Product group
products
with
unwanted
substances
Altroconsumo
Italy
Anti-aging
15
5
Propylparaben, butylparaben
creams
and/or octyl methoxycinnamte
Altroconsumo
Italy
BB creams
14
7
Propylparaben, butylparaben
and/or octyl methoxycinnamte
Danish
Denmark
Canned peeled
8
5
Bisphenol A
Consumer
tomatoes
Council
Danish
Denmark
‘Loombands’
5
4
DEHPi
Consumer
(toy)
Council
Danish
Denmark
Food contact
16
4
Fluorinated substances
Consumer
materials
Council
(paper)
Danish
Denmark
Chewing gum
150
92
BHAii or BHTiii
Consumer
Council
Danish
Denmark
Baby sleeping
8
2
DEHP and fluorinated substances
Consumer
bags
Council
Danish
Denmark
Headphones
16
2
Phthalates (DEHP, DIBPiv and
Consumer
DINPv)
Council
Danish
Denmark
Prams
7
3
DEHP, TCEPvi and/or TDCPvii
Consumer
Council
Danish
Denmark
Pushchairs
8
4
TCPPviii or chlorinated paraffins
Consumer
Council
Danish
Denmark
Microwave
9
9
Fluorinated compounds
Consumer
popcorn
Council
Danish
Denmark
Schoolbags
9
3
Phthalates (DEHP, DBPix and
Consumer
DPHPx) and/or chlorinated paraffins
Council
Danish
Denmark
Winter mittens
11
9
Fluorinated substances and/or
Consumer
nonylphenol ethoxylates
Council
Danish
Denmark
Pesto
8
1
DEHP
Consumer
Council
Danish
Denmark
Vitamins
12
3
BHT
Consumer
Council
1
BEUC Member
Country
Product/
No. tested
Products
Substance(s) found
Product group
products
with
unwanted
substances
Danish
Denmark
Game
12
4
Phthalates (DPHP, DEHP and
Consumer
controllers
DINP), chlorinated parafins and/or
Council
TCPP
Danish
Denmark
Child restraints
52
2
DINP or TCPP
Consumer
Council
Danish
Denmark
Lip balms
89
24
Benzophenone-3, BHA, BHT,
Consumer
propylparaben, ethylparaben,
Council
methylparaben and /or ethylhexyl
methoxycinnamate
Danish
Denmark
Sunscreens
66
13
Ethylhexyl methoxycinnamate,
Consumer
benzophenone-3, ethylparaben,
Council
methylparaben, BHT, and /or
cyclopentasiloxane
Danish
Denmark
Personal care
6.944
1.741
Parabens, BHT, triclosan, BHA,
Consumer
products (From
ethylhexyl methoxycinnamate
Council
the App
and/or benzophenones
‘Kemiluppen’)
Danish
Denmark
Toothpastes
32
4
Triclosan, methylparaben and/or
Consumer
propylparaben
Council
DECO
Portugal
Deodorants
15
1
Ethylhexyl methoxycinnamate
PROTESTE
Norwegian
Norway
Children’s
6
3
PFOAxi
Consumer
jackets
Council
Norwegian
Denmark
Lip balms
Benzophenone-3, ethylhexyl
Consumer
methoxycinnamate, ethylparaben,
Council
methylparaben, propylparaben
and/or BHT
Norwegian
Norway
Cleaning wipes
18
4
Propylparaben and/or
Consumer
methylparaben
Council
Norwegian
Norway
Sunscreens
35
11
Propylparaben, methylparaben
Consumer
and/or ethylhexyl
Council
methoxycinnamate
Norwegian
Norway
Deodorants
40
10
Cyclometicone, BHT and/or
Consumer
cyclopentasiloxane
Council
Stiftung
Germany
Soft toys
30
2
DIBP
Warentest
Stiftung
Germany
Anti-aging
9
3
Methyl, propyl and/or ethylparaben
Warentest
creams
Stiftung
Germany
Fan make-up
12
4
Phthalates (DEHP, DIBP, DBP
Warentest
(cosmetic)
and/or BBPxii)
2
BEUC Member
Country
Product/
No. tested
Products
Substance(s) found
Product group
products
with
unwanted
substances
Test-
Belgium
BB creams
16
7
Propylparaben
Achats/Test-
Aankoop
Test-
Belgium
Anti-aging
17
5
Propylparaben, butylparaben
Achats/Test-
creams
and/or octyl methoxycinnamte
Aankoop
UFC Que-
France
Sunscreens
17
7
Ethylhexyl methoxycinnamate
Choisir
and/or cyclopentasiloxane
UFC Que-
France
Anti-aging
15
3
Ethylhexyl methoxycinnamate
Choisir
creams
and/or cyclopentasiloxane
UFC Que-
France
Baby wipes
21
4
Propyl and/or butylparaben
Choisir
UFC Que-
France
Make up set for
8
4
Propylparaben
Choisir
kids
UFC Que-
France
Carnival kits
10
5
Propylparaben and/or lead
Choisir
UFC Que-
France
Deodorants
6
4
Cyclopentasiloxane
Choisir
(Men)
UFC Que-
France
Deodorants
16
5
Cyclopentasiloxane and
Choisir
(Women)
propylparaben
UFC Que-
France
Toothpastes
16
2
Triclosan or propylparaben
Choisir
UFC Que-
France
Personal care
237
126
Benzophenones, BHA, ethylhexyl
Choisir
products
methoxycinnamate,
cyclopentasiloxane,
cyclotetrasiloxane, sodium
propylparaben, propylparaben
and/or butylparaben
i Bis(2-ethylhexyl) phthalate
ii Butylated hydroxyanisole
iii Butylhydroxytoluene
iv Diisobutyl phthalate
v Diisononyl phthalate
vi Tris (2-chloroethyl) phosphate
vii Tris (1,3-dichloro-2-propyl) phosphate
viii Tris (1,3-dichloroisopropyl) phosphate
ix Dibutyl phthalate
x Di(2-Propyl Heptyl) phthalate
xi Perfluorooctanoic acid
xii Benzyl butyl phthalate
3