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Child Rights International Network

CRIN

CRIN's overall vision is a world in which children’s rights are recognised, respected and enforced and where every rights violation has a remedy.

Lobbying Activity

Response to Strategy on Intergenerational Fairness

3 Nov 2025

CRIN welcomes the initiative for a Strategy on Intergenerational Fairness (IGF). Upholding childrens rights, including by preserving the health and environment of current and future generations of children, is central to this Strategy. Decisions of today determine the living conditions, health, and integrity of children across generations. Ensuring IGF requires that current and future laws fully comprehend and uphold childrens rights, including their rights to life, health, participation, non-discrimination and bodily integrity. As such, several key EU goals should be embedded in the IGF Strategy: 1.Delivering on the Green Deal to respect the planetary boundaries Children are uniquely vulnerable to climate change, biodiversity loss and chemical pollution. Hazardous chemicals can persist in the environment, accumulate in human tissue and pose severe health risks, including to neurological development and reproductive health. Contamination is transmitted from parents to children before birth, perpetuating harm across generations. Harmful chemicals also degrade the environment, ecosystems and resilience of food systems. These realities make chemical safety a defining issue of intergenerational fairness. Through the Green Deal and its Chemicals Strategy for Sustainability, the EU Commission promised efficient measures to ensure chemicals would not harm current and future generations. However, most of the proposals have yet to be delivered, as major regulatory and enforcement gaps remain, directly undermining IGF and jeopardising fundamental rights. For instance, mixture and cumulative effects are rarely accounted for, despite childrens exposure to multiple chemicals at once. Many substances also remain on the market while having insufficient toxicity data, and even when the hazards of chemicals are known, it takes years to stop their uses. These shortcomings create an unjust legacy and existential threats for generations of children. 2. Guaranteeing childrens rights and long-term thinking in decision-making Adopting a child rights-based approach across all policy areas is key, ensuring that the interests of existing and future generations are explicitly assessed. Hence, impact assessments must further consider how EU decisions affect childrens rights and environmental inheritance in the short, medium and long term. Protecting children from environmental harm is also about justice and accountability. Environmental degradation deepens inequalities, as vulnerable communities suffer the greatest harms. Ensuring EU decisions respect fundamental rights will prevent children from bearing the costs of short-term political or economic choices. 3. Protecting democracy, rule of law and civic space Transparent, participatory decision-making is essential. Citizens, including children, must have access to information and opportunities to participate meaningfully in any processes having intergenerational consequences. Children should have a voice in decision-making spaces, respecting their agency and ability to contribute as experts in their own lives. By embedding childrens rights in the IGF Strategy, the EU can set a global standard for responsible, forward-looking governance. Future generations will only be treated fairly if todays systems and institutions are transparent, participatory, and accountable. IGF relies on strong democratic institutions, rule of law, and civil society protection. Shrinking space for civil society and attacks on the rule of law silence voices essential for fairness and accountability. CSOs must be able to operate freely and safely, as they support and represent citizens interests. IGF cannot be fulfilled unless the Strategy stands firm on childrens rights, environmental justice, and the protection of democracy. These are not optional ideals. These are non-negotiable, as they are the foundations of a fair sustainable society and the safeguards of fundamental rights for every generation to come.
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Response to EU Civil Society Strategy

21 Aug 2025

Civil society actors are essential pillars of democracy, human rights, and social cohesion across the European Union. They represent diverse communities, particularly marginalised and underrepresented groups, including children and youth, amplifying their voices in democratic processes and holding public institutions accountable. Moreover, many civil society organisations serve as crucial providers of services that directly benefit people, communities, and vulnerable groups, acting in crises and filling gaps that public systems may not fully address. The Child Rights International Network (CRIN) welcomes the proposal of an EU Civil Society Strategy, a much-needed step to acknowledge civil society not merely as an implementer of policies but as an active partner, and to better support and equip civil society actors with the tools and resources they need. In recent years, civil society has faced unprecedented challenges: shrinking space, legal, political and administrative restrictions, smear campaigns and targeted attacks, abusive lawsuits, surveillance, and increasing financial insecurity. These pressures are undermining CSOs capacity to operate effectively and independently, thereby weakening the EUs democratic values and fundamental rights. A robust, coherent, and well-resourced Civil Society Strategy is crucial to safeguard and empower civil society actors to continue their indispensable work. Key initiatives expected of the European Commission under the Civil Society Strategy include: - Carry out a systematic civic space impact assessment across all legislative and regulatory proposals, to ensure that all EU policies support rather than restrict civic space. - Develop a comprehensive, multi-layered EU protection system for Human Rights and Environmental Defenders and Civil Society Organisations. The coordinated EU protection system would provide timely legal, financial, psychosocial, and digital security support to defenders and CSOs under attack. This system should be independent, sustainable, and rooted in human rights standards, with rapid response capacity and follow-up for systemic reform. - Ensure strong and structural support for civil society in the new MFF through confirming and reinforcing a stand-alone, directly managed programme to support civil society and strengthen civic space; increasing the overall funding allocation to Operating Grants; improving their accessibility; explicitly including advocacy as a legitimate activity; and simplifying their functioning procedures. In particular, the LIFE Programme and its Operating Grant must be maintained and strengthened as a key instrument supporting environmental civil society organisations. - Develop a binding Agreement on Civil Dialogue between the European Commission, the European Parliament and the Council of the European Union to establish regular structured practices of engagement of civil society across all stages of the policy cycle. - Structure the upcoming Civil Society Platform as a mechanism to support systematic, transversal and vertical dialogue between the EU Commission and civil society and strengthen civic participation in shaping the political agenda. - Encourage Member States to develop formal, transparent, and inclusive civil society engagement frameworks to strengthen civil dialogue and participation mechanisms at the national level - Develop recommendations for an enabling environment for civil society at national level. - Remove obstacles to cross-border cooperation of non-profit organisations and foundations in the single market, guaranteeing them freedom of establishment and free movement of goods, services and capital. The European Cross-Border Association Directive would be an important first step.
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Response to Export and import of hazardous chemicals

7 Aug 2025

As an international childrens rights organisation, the Child Rights International Network (CRIN) would like to emphasize the urgent need for the EU to ban the production and export of hazardous chemicals altogether. While we welcome the draft delegated act amending Regulation (EU) No 649/2012, we would like to stress that export notifications, as provided under this Regulation, are utterly insufficient when it comes to upholding childrens rights and protecting their health and environment from hazardous chemicals. The EU Strategy on the Rights of the Child stresses that the EU plays a leading role in supporting children globally, by strengthening access to quality, safe and inclusive education, basic services, health (...). However, reality shows that the EU involvement in guaranteeing that childrens rights protection against harmful contamination worldwide is far off these promises. As it stands today, EU companies are still allowed to export hazardous chemicals that are prohibited in the EU to other countries. The use of these substances has been prohibited because they pose serious risks to human health and the environment, including (but not limited to) harming fertility, increasing risks of developing cancers, damaging child development, and polluting ecosystems. Yet, they are still sent abroad, often to countries with fewer protections. This double standard is legally and ethically unacceptable, and leads to severe human rights violations and environmental injustices. The Commission should fully align EU rules on the export and import of hazardous chemicals with its own environmental health standards and human rights obligations (including - but not limited to - the UN Convention on the Rights of the Child and the Charter of Fundamental Rights of the EU). Sending an export notification or requesting consent from importing countries is not enough to protect local communities and ecosystems from the devastating impacts of these pesticides. As such, the current legislative proposal fails to take any meaningful step toward ending this harmful double standard, despite the Commissions clear 2020 commitment to ensure that hazardous chemicals banned in the EU are not produced for export. We recommend that any pesticide banned in the EU for health or environmental reasons is automatically added to Annex V of Regulation (EU) 649/2012, Chemicals and articles subject to export ban under Article 15.2, which prohibits their export elsewhere. We are particularly concerned that the current revision proposes to allow continuing the exports of substances like carbendazim, classified as a mutagen (may cause genetic effects) and toxic to reproduction (may damage fertility and foetus development), or metribuzin, an endocrine disruptor for human health. Requiring only prior informed consent (PIC) for these dangerous substances is not enough. Together with more than 600 organisations worldwide, we call on the European Commission to urgently present a legislative proposal to prohibit the export of all pesticides and other hazardous chemicals that are banned in the EU, in order to protect childrens rights, human health and the environment. Moreover, the existing double standard applies to other goods beyond pesticides and other chemicals. In a 2024 briefing, over 100 organisations, including CRIN, warned that the current EU legal framework still allows its companies to profit off the production and export to non-EU countries of other goods which are deemed too dangerous or unfit for the EU market and people - for instance, unsafe toys and single-use plastic products. (https://home.crin.org/readlistenwatch/stories/cruel-trade-loopholes-eu-companies-export-toxic-products-banned-eu-market ). Exporting prohibited products and substances is completely immoral, unethical and goes against human rights treaties, including EU and Member States obligations to uphold childrens rights. Its time to close those loopholes.
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Response to Evaluation of the Cosmetic Products Regulation

20 Mar 2025

The Child Rights International Network (CRIN) is grateful for this opportunity to take stock of the efficiency - and deficiencies - of the Cosmetic Products Regulation (CPR). This summary reflects our inputs available in the attached document, with references to scientific studies and human rights requirements hereby mentioned. In recent years, the CPR has undergone several assessments already, including the Fitness Checks of chemicals legislation and on endocrine disruptors, which identified several shortcomings in the regulation. In the Chemicals Strategy for Sustainability and through the recent CPR review process, the Commission also repeatedly acknowledged the need to modernise the text, stressing that its revision aims at supporting the green transition of the chemical industry, by minimising and substituting as far as possible chemicals having a chronic effect for the environment and phasing out the most harmful ones for non-essential societal uses. While the EU willingness to deliver on its promises might seem to regrettably falter, the urgent need to protect citizens' rights and health against harmful chemicals has not. The CPRs shortcomings persist, and so is the need to revise it to put an end to childrens rights violations linked to their exposure to hazardous chemicals. This exposure can have damaging effects on childrens health, even at very low doses as demonstrated by independent scientific studies. Harmful impacts include childhood cancers, asthma, diabetes, obesity and disruption in bone development. Because of their smaller bodies, rapid growth and behavioural habits, children are worst affected by those substances. Worryingly, hazardous substances (such PFAS, parabens, salicylic acid, among others) can still be found in cosmetic and personal care products regulated under the CPR. And if some are prohibited for uses intended to children under certain age limits, they can still be used in many products sold in the EU, and can affect children above prescribed age limits, as well as fetuses exposed prenatally via parents exposure. Children are affected by their direct exposure but also prenatally impacted by chemicals found in cosmetic and personal care products as exposure can occur during the foetal development, a critical period of life with increased vulnerability to exposure to hazardous chemicals. Such exposure leads to violations of childrens rights that are internationally recognised. Yet, the Commission mentioned that the initiative on CPR is unlikely to have any impacts on fundamental rights. This misconception is rooted in a lack of understanding of the links between exposure to harmful chemicals and human rights. Research, including from UN experts, demonstrated that such exposure can lead to severe infringements upon childrens rights to health, bodily integrity, gender equality, non discrimination, as well as to a clean, healthy and sustainable environment. Under the UN Convention on the Rights of the Child and the Charter of Fundamental Rights of the EU, the child's best interests must be a primary consideration in all actions relating to children. The EU Strategy on the Rights of the Child states that all children have a right to a good standard of living. Protecting children from exposure to hazardous chemicals should be a cornerstone to deliver on the Strategys promises. Children are fully entitled to these rights the EU and Member States committed to uphold. Looking at the extensive body of scientific studies, there is no doubt that children are still exposed directly and indirectly to harmful chemicals found in cosmetic and personal care products. The CPR must be updated to reflect the state of science, including by better comprehending and upholding childrens rights, strengthening the assessment and management of chemicals, as well as improving enforcement. To deliver on its human rights commitments, the EU must achieve the CPR review as swiftly and efficiently as possible.
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Meeting with Erik Marquardt (Member of the European Parliament) and Greenpeace European Unit and SOLIDAR

18 Mar 2025 · Export Ban/ PCD

Meeting with András Tivadar Kulja (Member of the European Parliament, Shadow rapporteur for opinion)

13 Feb 2025 · Toy safety

Meeting with Catarina Martins (Member of the European Parliament)

6 Feb 2025 · hazardous chemicals

Meeting with Clint Tanti (Cabinet of Commissioner Glenn Micallef), Deša Srsen (Cabinet of Commissioner Glenn Micallef) and

16 Jan 2025 · Intergenerational Fairness Strategy

Meeting with Rudi Kennes (Member of the European Parliament)

20 Nov 2024 · Toxic substances and children's rights

Response to Protection of Minors Guidelines

30 Sept 2024

CRIN is grateful for the opportunity to submit feedback regarding the upcoming guidelines under the Digital Services Act on the protection of minors. Please find the submission attached.
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Meeting with Veronika Cifrová Ostrihoňová (Member of the European Parliament)

16 Jul 2024 · Children's Rights

Meeting with Marion Walsmann (Member of the European Parliament, Rapporteur)

31 Oct 2023 · Toy Safety Regulation

Response to Revision of the Toy Safety Directive

27 Oct 2023

We welcome the EU Commissions proposal for a Toy Safety Regulation, revising the existing directive on the safety of toys in force since 2009. We support this ambitious proposal, which is a great step toward a better protection of children and their rights against exposure to harmful chemicals. As we write, many toys containing harmful chemicals are being sold in the European market, to end up in the hands and mouths of children. Exposure to those substances presents particularly damaging effects on foetuses, infants and children, and there is no such thing as a tolerable intake of hazardous chemicals in toys. Contamination due to their exposure causes severe childrens rights infringements, including violations of their rights to health, play and physical integrity. Children are worst affected by harmful substances, even at very low doses. All toys should be safe and hazard-free. Guaranteeing the highest level of safety in toys is the only way for the EU to effectively comply with its legally binding commitments under the UN and EU human rights frameworks. To deliver on the Chemicals Strategy for Sustainability, a revision of this outdated directive is more than needed to reinforce childrens rights protection in line with the latest scientific evidence. As appropriately proposed by the Commission, the revision can better protect children not only against carcinogenic, mutagenic and reprotoxic substances, but other hazard classes as well. The TSR is the chance to finally tackle the combination of multiple chemicals and to restrict hazardous substances that were under the radar so far, though particularly damaging to childrens health, such as known and suspected endocrine disrupting chemicals. Among other improvements, the Commission proposes to strengthen control and market surveillance, including by requiring all toys to have a Digital Product Passport. Imposing the DPP can help authorities to access crucial information on toys and better control products sold online. This measure is more than welcomed, as harmful substances in toys currently placed on the EU market irreversibly affect childrens health and the enjoyment of their human rights. Some of the proposal's provisions need refinement, as they fall short in fully comprehending and upholding childrens rights. Among other issues, the long transition period as well as the risk to leave the door open to derogations for uses of the most harmful chemicals raise concerns and should be reconsidered. In the coming months of negotiations, the EU institutions must support this ambitious proposal and tweak the text, so toy safety can be effectively guaranteed under a refined regulation which: - Better understands and upholds childrens rights, by fully comprehending the links between exposure to hazardous substances and childrens rights violations, as well as recognising children as independent rights holders. - Bans both known and suspected categories of hazardous substances, including (but not limited to) CMRs and EDCs, under the generic approach to risk management. - Updates limit values for chemicals in all toys, to protect all children below and above 3 years-old. - Puts an end to unjustified derogations, moving away from the safe use misconception, and limits the transition period during which children will continue to be contaminated by hazardous substances. - Improves access to information, compliance and control, by supporting effective market surveillance and customs including with the introduction of a Digital Product Passport and the reinforcement of the custom capacities. Our detailed position and inputs are available in the attached document.
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