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Chemicals, Health and Environment Monitoring Trust

CHEM Trust

CHEM Trust is an environmental NGO working to protect humans and wildlife from harmful chemicals.

Lobbying Activity

Meeting with Romana Jerković (Member of the European Parliament)

18 Nov 2025 · PFAS

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

28 Oct 2025 · Civil society perspective on the chemicals competitiveness, modernisation and simplification’s debate

Meeting with Martin Hojsík (Member of the European Parliament) and European Environmental Bureau

3 Oct 2025 · REACH, implementation of legislation

Meeting with Jessika Roswall (Commissioner) and

29 Sept 2025 · Conference organised by HEAL and CHEM Trust on chemicals policy: REACH revision 2025: simpler, faster, bolder

Meeting with Jutta Paulus (Member of the European Parliament) and Health & Environment Alliance

29 Sept 2025 · Speaker: REACH revision 2025 simpler, faster bolder (conference)

Meeting with Jessika Roswall (Commissioner) and

2 Sept 2025 · Roundtable on the revision of REACH and the environmental and health impact of chemicals including PFAS followed by a site visit.

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

2 Sept 2025 · REACH revision; Chemicals Omnibus; PFAS

Meeting with Veronica Manfredi (Director Environment)

16 Jul 2025 · CHEM Trust requested a meeting to discuss work on the REACH revision and the upcoming conference on 29 September organised in collaboration with HEAL.

Meeting with Elisa Roller (Director Secretariat-General)

4 Jul 2025 · REACH revision

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

25 Jun 2025 · REACH revision and inclusion of a MAF; polymers (with scientists’ presentation)

Meeting with Majdouline Sbai (Member of the European Parliament)

20 May 2025 · Dossiers en Commission ENVI

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

29 Apr 2025 · Chemicals policy

Meeting with Hubert Gambs (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

11 Apr 2025 · Exchange of views on the REACH revision

Meeting with Hildegard Bentele (Member of the European Parliament)

9 Apr 2025 · Chemicals/pollution

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

3 Apr 2025 · REACH

Response to 2025 Strategic Foresight Report

19 Mar 2025

Summary of our response: As recognised in the Call to Evidence for the 2025 Strategic Foresight Report, resilience needs to be delivered in a sustainable, fair and democratic manner with a join up across policy priorities. The 2023 Foresight Report was right to identify that the sustainability transition is built on a triple promise: a healthy planet and thriving environment; economic growth that is decoupled from resource use and environmental degradation; and an assurance that no person or place will be left behind. That report made strong links between environmental sustainability and economic resilience but mostly related this to the transition to a net zero economy with some reference to the damage caused by pollution. The 2025 Foresight report needs to make a stronger link to the EUs ambition for a zero pollution economy and specifically the need to reduce the production, use and import of harmful chemicals. CHEM Trust welcomes the opportunity to explain the importance of including chemical regulation in the policy actions needed to strengthen resilience in the EU. The EU is facing multiple crises of climate change, chemical pollution and biodiversity loss that are interconnected and are impacting on citizens health, the ecosystems that humans depend upon and the economy. Increasing pollution of our environment and our bodies with toxic chemicals are key challenges that must be addressed in any strategy to ensure a resilient and desirable future. It is surprising therefore that the last Foresight Report (2023) did not include specific reference to chemical pollution despite containing a strong recognition of the need for environmental sustainability and wellbeing to be at the heart of resilience. Our answers to the specific questions set out in the Call for Evidence together with our supporting evidence and our policy recommendations are in the attached document.
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Meeting with Stefan Fuehring (Head of Unit Secretariat-General)

18 Mar 2025 · CHEM Trust’s recommendations for the REACH revision

Meeting with Elżbieta Katarzyna Łukacijewska (Member of the European Parliament)

17 Mar 2025 · Pfas in EU regulation

Meeting with Per Clausen (Member of the European Parliament)

17 Mar 2025 · PFAS, REACH

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall), Vita Jukne (Cabinet of Commissioner Jessika Roswall)

10 Mar 2025 · EU chemicals regulation / REACH

Meeting with Paul Speight (Head of Unit Environment) and European Environmental Bureau and

14 Feb 2025 · EU chemicals regulations / REACH revision

Meeting with Paul Speight (Head of Unit Environment) and European Environmental Bureau and

16 Jan 2025 · Restrictions under REACH

Response to Commission Roadmap to phase out animal testing

15 Oct 2024

CHEM Trust welcomes this opportunity to provide input into the Commission initiative to develop a roadmap to phase out animal testing. CHEM Trust has worked actively for many years to accelerate regulatory action to better protect humans and wildlife from harmful chemicals. Please find attached our input as a separate file. We are available for further contributions in the course of the foreseen targeted consultations.
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Meeting with Christine Singer (Member of the European Parliament)

26 Sept 2024 · Austausch neue Legislaturperiode

CHEM Trust welcomes bisphenol ban but urges broader scope

6 Mar 2024
Topic — EU regulation restricting bisphenol A and related chemicals in food contact materials.
Message — The organization supports the prohibition but requests expanding coverage to include category 2 hazard classifications for carcinogens, mutagens, reproductive toxicants and endocrine disruptors. They want the ban extended to all food contact materials, including recycled plastics and paper, with enforceable limit values.123
Why — This would prevent regrettable substitution with other hazardous bisphenols and ensure cleaner recycling.456
Impact — Chemical manufacturers lose flexibility to substitute BPA with similar substances without full testing.78
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Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and ClientEarth AISBL

7 Feb 2024 · Implementation of EU Chemicals Strategy

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and European Environmental Bureau and ClientEarth AISBL

7 Feb 2024 · Implementation of EU Chemicals Strategy

Meeting with Martin Hojsík (Member of the European Parliament)

25 Jan 2024 · Chemical policies, Toys

CHEM Trust demands faster action on chemical hazard classifications

30 Mar 2023
Topic — This consultation reviews rules for classifying, labelling, and packaging hazardous chemical substances.
Message — CHEM Trust supports adding new hazard classes but wants faster decisions on endocrine disruptors. They also request that neurotoxicity and immunotoxicity be included in future safety regulations.123
Why — Stricter deadlines would accelerate the organization’s goal of minimizing harmful chemical exposures.4
Impact — The public and environment remain vulnerable to harmful toxins during long transition periods.5
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

14 Mar 2023 · Implementation of the EU Chemicals Strategy for Sustainability and PFAS related measures

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Environmental Bureau

2 Dec 2022 · Implementation of the Chemicals Strategy for Sustainability and the REACH revision

CHEM Trust urges faster rollout of chemical hazard classes

18 Oct 2022
Topic — Revision of EU rules for classification and labeling of hazardous chemical substances.
Message — The group supports the introduction of new hazard classes but calls for shortening transition times. They argue application times should be changed to 12 months for substances. They also suggest broader criteria to prevent persistent water contaminants from falling through the net.123
Why — These changes would help the group protect human health and ensure transparency in supply chains.45
Impact — Chemical manufacturers would face higher costs and tighter deadlines for reclassifying and relabeling their products.6
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CHEM Trust urges transparency in EU chemical safety assessments

29 Jul 2022
Topic — This initiative aims to improve chemical data access and safety assessment transparency across the EU.
Message — CHEM Trust seeks to transfer transparency principles from food safety to all chemical laws. They support increasing transparency to avoid animal testing and strengthening authority powers to commission monitoring.123
Why — This policy would improve the speed and effectiveness of measures protecting health and nature.45
Impact — Industry players providing insufficient data would lose control as authorities commission their own testing.6
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Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and ClientEarth AISBL and

8 Jul 2022 · Implementation of the EU Chemicals Strategy for Sustainability and REACH revision

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

8 Jul 2022 · Implementation of the EU Chemicals Strategy for Sustainability and REACH revision

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

3 Mar 2022 · Restrictions Roadmap and the CSS implementation

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and Health & Environment Alliance and International Pollutants Elimination Network

8 Dec 2021 · To discuss the EU Chemicals Strategy for Sustainability and PFAS

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Health & Environment Alliance and International Pollutants Elimination Network

8 Dec 2021 · EU Chemicals Strategy for Sustainability and PFAS

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Health & Environment Alliance and International Pollutants Elimination Network

8 Dec 2021 · EU Chemicals Strategy for Sustainability and PFAS

Meeting with Thierry Breton (Commissioner) and

24 Jun 2021 · Discussions on the implementation of the chemicals strategy for sustainability.

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

8 Jun 2021 · Chemicals Strategy for Sustainability and restriction roadmap

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

31 May 2021

CHEM Trust would like to take this opportunity to comment on the Commission’s plans for revising the EU CLP legislation. CHEM Trust welcomed the commitments made in the Chemicals Strategy for Sustainability (CSS) for strengthening the identification and control of chemicals with properties that are endangering public health and the environment. However, we are very concerned that some of these policy commitments in the CSS seem to have become optional as described in the Inception Impact Assessment. It will be very important to focus the revision of the EU chemicals policy framework on those policy areas where the greatest potential for protecting health and environment can be expected. In CHEM Trust’s view the emphasis should be placed on introducing new hazard classes for endocrine disruptors (EDs) with different sub-categories. Together with our campaign partners from the EDCFree-Europe-Coalition we have advocated for many years for a better identification of EDs, followed by necessary protective measures to minimize exposure. CHEM Trust also strongly supports the introduction of new hazard classes relating to persistent, bioaccumulative and toxic properties (PBT, as well as vPvB properties) and persistent, mobile and toxic properties (PMT, as well as vPvM properties). We also support a greater emphasis on the identification of substances with developmental neurotoxic- and immunotoxic properties, as mentioned in the CSS. If the EU Green Deal is supposed to live up to its aims to result in more prevention and precaution, this will require a more efficient identification of harmful substance properties and subsequent control measures that provide for long-term benefits and go beyond window-dressing. See the attached briefing for our full response and our policy blog for more information about our work: https://chemtrust.org/policy/
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NGO urges stronger REACH rules to protect health from toxic chemicals

28 May 2021
Topic — EU revision of chemical registration law to achieve toxic-free environment goals
Message — The organization requests mandatory grouping of related chemicals, stronger data requirements for hazard identification, and faster restriction processes. They emphasize that chemicals with similar structures should be treated as having the most toxic properties in their group unless industry proves otherwise.123
Why — This would reverse the burden of proof onto industry and enable faster regulatory action against harmful chemicals.456
Impact — Chemical manufacturers lose the ability to substitute banned chemicals with similar hazardous alternatives and delay action through inadequate data.789
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Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

CHEM Trust demands ban on hazardous chemicals in food packaging

29 Jan 2021
Topic — Revision of EU rules on materials contacting food to reduce hazardous chemicals.
Message — The organization requests rapid bans on the most hazardous chemical groups in food contact materials, including endocrine disruptors and carcinogens. They want the Commission to prioritize group restrictions under REACH immediately, rather than waiting for new regulations. They also demand establishment of a positive list system for all substances used in food contact materials.123
Why — This would eliminate their exposure to toxic chemicals in food packaging materials.45
Impact — Industry loses flexibility to use cheaper hazardous chemicals and self-regulate safety compliance.67
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Meeting with Gaelle Garnier (Cabinet of Commissioner Thierry Breton), Valère Moutarlier (Cabinet of Commissioner Thierry Breton)

3 Sept 2020 · Exchange of views in the context of the preparation of the sustainable chemical strategy

Meeting with Virginijus Sinkevičius (Commissioner) and

23 Jul 2020 · To discuss the Chemicals Strategy for Sustainability, especially with relation with endocrine disruptors.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Eidgenössische Technische Hochschule Zürich and Food Packaging Forum Foundation

9 Jul 2020 · European Green Deal and EU Chemicals Strategy for Sustainability

CHEM Trust Urges Swift Phase-Out of Toxic Chemical Groups

19 Jun 2020
Topic — The consultation seeks input on a new EU strategy for a toxic-free environment.
Message — CHEM Trust demands a framework to ban endocrine disruptors and persistent PFAS chemicals. They advocate for regulating substances in groups and accounting for combined cocktail effects.12
Why — A comprehensive strategy would fulfill the organization's vision of eliminating chemical-induced diseases.3
Impact — Chemical manufacturers would face widespread bans and higher costs to develop safer alternatives.45
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

4 Jun 2020 · VC meeting to discuss Chemicals Strategy

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

4 Jun 2020 · VC meeting - Chemicals Strategy

Response to Farm to Fork Strategy

16 Mar 2020

The Farm to Fork Strategy must ensure Safe Food in Safe Packaging. Please see CHEM Trust's full consultation response in the attached document. CHEM TRUST’s view is that, in order for food to be considered safe, it must be uncontaminated. European citizens should have access to food without pesticide residues or any other harmful chemical contaminants. In this respect, it is very important not to overlook the widespread contamination of food which is caused by chemicals migrating from Food Contact Materials (FCM). Every step in the food supply chain involves contact between our food and different FCMs. Storage containers, factory equipment, food packaging, and kitchen utensils are food contact articles made from FCMs which contain numerous chemical substances that can migrate into our food. Some of these chemicals are harmful to human health, in particular endocrine disrupting chemicals that can impact the hormone system already at very low doses. In our recent comments to the ongoing EU ED Fitness Check we pointed out in our response to the stakeholder survey that more protection is needed from EDCs and that the reform of the Food Contact legislation will need to play an important role in minimising exposures. We welcome the aim of the Farm to Fork Strategy while at the same time we wish to highlight that contamination from FCM, particularly the so-called Non-Intentionally Added Substances, the NIAS, may exceed other contaminants in food by a factor of 100 or more. The current EU policy framework has failed to protect people from harmful chemicals in FCM. CHEM Trust has highlighted this fact many times in recent years, including in a recent letter to Commissioner for Health and Food Safety. We were grateful to receive a reply from the Commissioner stating that the Commissioner is keen to take action where necessary in order the maximise the protection of human health, and that she considers the area of FCMs extremely important in this respect. On March 3rd a group of 33 scientists from around the world published a peer reviewed Consensus Statement expressing deep concern about the current use of harmful chemicals in food packaging and other Food Contact Materials (FCM). This Statement was followed by a Declaration of Concern and Call to Action, signed by CHEM Trust and more than 170 civil society groups from Europe, the U.S. and Asia calling on regulators to upgrade regulatory frameworks on FCM. The timing of this clear statement from the scientific community is particularly relevant in the EU as the European Commission has recently conducted a evaluation of the existing EU legislation on FCM and must soon communicate to stakeholders about when and how it will take steps to improve the current situation. CHEM Trust strongly encourage the Commission to focus on avoiding the use of hazardous chemicals while also taking steps to ensure reduced and sustainable packaging. The recent scientific statement clearly supports this approach. The Farm to Fork roadmap states that the European Green Deal cannot be achieved without addressing food sustainability. We believe that a reform of the regulatory framework for FCM is an essential element in achieving the goals of both the Farm to Fork strategy and the European Green Deal as a whole. We call on the Commission to ensure that the Farm to Fork strategy will commit the Commission to addressing the problems related to hazardous chemicals in FCM. This should include a timeline for the development of new, more protective and effective, legislation.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

CHEM Trust welcomes a Biodiversity Strategy aiming to deal with the drivers of the biodiversity crisis and would like to emphasize the urgent need to deal with one of the drivers listed in the roadmap: pollution, and more specifically, chemical pollution. Chemical pollution does not only involve pollution from direct sources such as industrial accidents or large-scale pollution from the widespread use of synthetic pesticides, but also diffuse pollution from synthetic chemicals leaching from consumer products such as flame retardants, plasticizers, water and grease repellents and pharmaceuticals. Over the past years CHEM Trust published many reports that highlighted the impacts of chemicals on biodiversity1-3. Recent scientific findings provide very concerning evidence of chemical pollution as a driver of ecosystem losses, as much for terrestrial ecosystems as for marine ecosystems. To mention just a few: • on land: bird populations in Europe are highly impacted by the extensive use of synthetic pesticides4; • in freshwater: in the EU, on average 20 % of aquatic species are disappearing due to exposure to chemical mixtures5; • in marine waters: legacy pollution from banned PCBs is threatening the survival of orca populations6. A conservative estimate suggests that in terms of economic value at least 27% of total ecosystem service losses are due to chemical pollution7. Moreover, chronic exposure to chemical pollution, such as from endocrine disrupters, is impacting wildlife’s welfare and resilience by weakening their reproduction, immune, hormonal and neurological systems as well as their mating, migration and feeding behaviours8-10. This makes wildlife populations and entire ecosystems more vulnerable and less resilient in a context where they are also affected by many other external stressors such as climate change or habitat loss. The burden of synthetic chemicals in the air, water and soil has reached critical levels. To cite one example, a study mapping chronic risk on the aquatic environment demonstrated that organic chemicals were likely to exert chronic long-term effects on sensitive freshwater species in 42% of the 223 European sites they studied11. Tragically, the situation is set to get worse: The 2019 landmark report of the European Environment Agency on the state of the European environment concluded: “The projected increase in chemical production and continued emissions of persistent and hazardous chemicals suggests that the total chemical burden on health and the environment is unlikely to decrease”5. Some of the synthetic chemicals burdening the environment are highly persistent, such as the group of PFAS chemicals12. Therefore, further emission means a constant increase of this synthetic chemical burden and an increase of the exposure. Once these chemicals are present in the environment it is extremely challenging, costly and in some instances impossible to remove them. Restricting these chemicals at the source and replacing them with safer alternatives and processes is critical to slow down the build-up of this toxic load in the environment. Stricter risk management measures to better control and reduce the overall use of chemicals of very high concern is also crucial to ensure Europe can establish a clean circular economy. In CHEM Trust’s view the success of the Biodiversity Strategy is therefore bound to the ambition and delivery of several other strategies developed in the context of the European Green Deal. Especially the Zero-pollution ambition for a non-toxic environment including the Chemical Strategy for sustainability as well as the ‘Farm to Fork’ Strategy. An integrated approach between all these strategies is critical to restore the natural environment on a path to recovery. The text with all references can be found in the attached CHEM Trust briefing.
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CHEM Trust urges faster horizontal rules for endocrine disruptors

10 Jul 2019
Topic — Evaluation of EU regulations governing endocrine disruptors and their impact on health.
Message — The group calls for a single horizontal approach to identify and control endocrine disruptors across all legislation. They demand a thorough analysis of consumer products like toys and cosmetics to ensure high protection levels. The Commission should take immediate action based on existing science rather than delaying for further studies.123
Why — Tighter regulations would help fulfill the organization's vision of a toxic-free environment.4
Impact — Chemical manufacturers face stricter restrictions and higher costs from harmonized hazard-based criteria.5
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CHEM Trust demands stronger EU action on endocrine disruptors

18 Jul 2018
Topic — The consultation aims to develop a comprehensive EU framework for regulating endocrine-disrupting chemicals.
Message — CHEM Trust urges a new strategy with measures to close gaps in identifying and controlling these chemicals. They recommend treating these substances as non-threshold hazards and addressing the risks from chemical mixtures.123
Why — These measures would help the group achieve its goal of high health and environmental protection.4
Impact — Chemical manufacturers would face broader bans and costlier testing for products like food packaging.56
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CHEM Trust demands transparent reform of food packaging regulations

21 Dec 2017
Topic — The Commission is evaluating the safety and effectiveness of food contact legislation.
Message — CHEM Trust calls for an open, transparent, and participative evaluation process. They urge the Commission to modernize regulations that are currently considered grossly inadequate. The group demands equal treatment for civil society stakeholders compared to industry.123
Why — This would allow the NGO to actively participate in previously restricted policy discussions.45
Impact — Industry groups may lose their exclusive influence over the food safety regulatory process.67
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Meeting with Xavier Prats Monné (Director-General Health and Food Safety) and ClientEarth AISBL and Health & Environment Alliance

11 Oct 2017 · Discussion on Food Contact Materials

CHEM Trust demands total ban on BPA in food packaging

20 Sept 2017
Topic — The consultation concerns regulating Bisphenol A in food contact coatings, varnishes, and plastics.
Message — The organization advocates for a total ban on BPA in all food contact materials. They also recommend addressing other similar bisphenols and prioritizing the substitution of harmful substances with safer alternatives.123
Why — A total ban would advance their mission of protecting public health from endocrine-disrupting chemicals.4
Impact — The paper and board industry would face new regulations and costs for recycled packaging.56
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Meeting with Vytenis Andriukaitis (Commissioner) and

10 Jul 2017 · Food contact materials

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

5 May 2017 · endocrine disruptors, REACH

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Environmental Bureau and ClientEarth AISBL

30 Mar 2017 · Reach Evaluation

Meeting with Vytenis Andriukaitis (Commissioner) and

2 May 2016 · Endocrine disruptors

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

8 Mar 2016 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

8 Mar 2016 · chemical policy

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and Health & Environment Alliance

25 Feb 2016 · Criteria of endocrine disruptors

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

17 Jun 2015 · REACH