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Environment and Health Justice Support

HEJSupport

Health and Environment Justice Support aims to achieve a healthy environment and environmental justice for affected people.

Lobbying Activity

Response to Revision of the Toy Safety Directive

29 Oct 2021

The protection of children and the realization of the rights of the child and the right to live in a clean and healthy environmental should be one of the most important goals for the EU, as it has been laid down in the EU Strategy on the Rights of the Child . All products used by children should be subject to the precautionary principle. Toys are not justified of having any essential use, that would allow for the use of harmful chemicals or other threats to children`s safety or health. Therefore, we urgently request the EU Commission to include the following points in the revision of the TSD. On chemicals: • All uses of Endocrine Disrupting Chemicals (EDCs) in toys should be strictly prohibited, without any exemptions. For EDCs no safe threshold limits can be set, as by default they should be considered as non-threshold chemicals. Additionally, for toys there is no justification of any essential use that would allow the presence of EDCs. • All CMRs should be banned in toys completely, without any derogations. • All PFAS should be banned in toys completely, without any derogations. • Limits for nitrosamines and heavy metals such as lead, cadmium are too high, these substances should be banned in all toys. • Some allergenic fragrances are banned in toys. However, to apply to precautionary principle all fragrances and sensitizers should be banned in toys. There is no justification for their essential use in toys. • PVC contains many toxic additives therefore it should be banned for the use in toys. • To fully apply the precautionary principle, also manufactured nanomaterials should be prohibited in toys. • Chemical limit values should only be set for chemicals if there is no general ban (a total ban should include EDCs, CMRs, fragrances, sensitizers, heavy metals, PBT, vPvB, SVHCs, PFAS and PVC). The limit values should then apply for all children and not only for those under 36 months. Simplification of limit values must not lead to lower protection levels, instead they should lead to better protection of all children. • Where colorants and preservatives are needed, a positive list should be established, which should not contain any substances which are sensitizing or bioaccumulating. • Combined exposures leading to mixture effects must be considered. Safe levels of chemicals should not be set by one chemical alone. On transparency and traceability: • Full disclosure of ingredients along the supply chain should be introduced, to ensure the right to know for citizens. This will improve the traceability and accountability along the life cycle. • A product passport should mandatorily contain all chemical ingredients and necessary sustainability information (e.g. correct disposal, origin) • Data security and protection of personal data and privacy of children must be guaranteed through the revision of the TSD. On market surveillance and enforcement: • Market surveillance is too weak and has to be improved on all levels. The RAPEX notifications show that there are still too many toys on the market that do not comply with EU regulations. • Mandatory third-party testing should be included, taking into account negative and positive experiences of the USA Submission including footnotes attached and here: https://hej-support.org/toys-should-be-fun-and-not-toxic-revision-of-the-eu-toy-safety-directive/
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Response to Revision of EU rules on food contact materials

29 Jan 2021

HEJSupport welcomes the opportunity to submit comments on the EC plans for a revision of the EU Food Contact Materials (FCM) legislation. HEJSupport works on chemicals in products for a long time, and e.g. represents NGOs in the steering committee of the UNEP chemicals in products steering group in the frame of SAICM. In the legislation we see a number of loopholes that a revised legislation should address. These include, among others: • Many harmful chemicals present in FCM, even those already identified as substances of very high concern (SVHC) under REACH, are not addressed or restricted enough to protect human health and environment sufficiently. Therefore, the EU should ban all hazardous chemicals in all FCM. This would be in line with the commitments of the Green Deal and the Chemicals Strategy for Sustainability. • FCM is recognized as a significant source of per-and polyfluoroalkyl substances (PFAS). All PFAS are highly persistent in the environment and will remain a source of exposure for thousands of years. However, the vast majority of PFAS on the market are unregulated. The EU should prohibit the use of the class of PFAS in FCMs in order to decrease their release into the environment and their contamination of food, and drinking water. • There is no assessment of Endocrine Disrupting Chemicals (EDCs) or Non-intentionally added substances (NIAS). EDCs should not be present in FCMs. NIAS should be assessed for safety and regulated accordingly. • Recycled materials should undergo the same assessments as virgin materials and the same standards should been applied • Mixture effects and real-life exposure should be included in risk assessments. We believe that significant changes are needed and should not be limited to the current framework. Therefore, we support option 2 “Develop a new regulatory framework to replace the current regulation” presented in the roadmap, as we think it is the best choice. A group of NGOs presented 5 key principles for a new legal framework to ensure basic safety concerns. We fully support this proposal and think they should be included in a future framework. We want to highlight that the introduction of an element of defining safety and monitoring compliance is important, however it should never be carried out by industries themselves. Public authorities are the right entities to be in charge of these tasks. Another important element that the legislation should address is the right to know of consumers. They should have easy access to understandable information about products they buy or use, especially about hazardous chemicals. Therefore, it should be mandatory to disclose all ingredients in those products.
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Response to EU strategy for sustainable textiles

28 Jan 2021

HEJSupport welcomes the EU strategy for sustainable textiles Roadmap’ and the EU Commission’s initiative to address the impacts of textiles. To succeed, the Textile Strategy should be based on the principles of a safe circular economy that eliminates toxic chemicals in the materials cycle, ensures less extraction of raw materials and increases the use of materials already in circulation in the most efficient way. Circular material flows can only be safe if they are free from hazardous chemicals or if hazardous chemicals that cannot be phased out are strictly regulated. We agree that being among the most polluting industries, textile industry has to become sustainable to minimize resource use and pollution, improve the safety of workers, eliminate sexual abuse, and ensure the right of consumers to make an informed choice. The Textile Strategy should recognise that the future of sustainable textiles largely depends on its ability to reduce the use of resources, such as land, water and oil, ensure reuse and recycle of products to minimize waste. In addition, the it should focus on other aspects, including protection of the environment and human health, occupational safety, gender equity and women’s empowerment, as well as meeting the demand of consumers for eco-friendly textile products. In addition, the Textile Strategy should include measures to raise the capacity and awareness of industry, politics, and civil society in low- and middle-income production countries, to tackle problems at source. Increasing consumer awareness More attention should be paid on the importance of increasing consumers’ awareness of consumerism and the associated environmental and health risk. For consumers to make informed decisions regarding their clothing, they must be aware of the issue at hand. Awareness involves not only having the information, but also ensuring it is easily understood and accessible by all. Make consumers a driving force for sustainability Information on toxic chemicals and other environmental impact of clothing and textiles should become a mandatory reporting requirement for companies and should be made available to consumers. Product sustainability claims should be oriented on the proof of action to reduce negative environmental and social impact throughout the supply chain and should not be limited to commitments and plans only. Information on product sustainability claims should be publicly accessible and regularly updated. They should be reliable, traceable, backed by science and CSOs, verified by a third party, be accessible and transparent. The presented ideas are built on our recent report “Sustainable Fashion? How companies provide sustainability information to consumers”, and related work that we conducted in the last years. Circularity Manufacturers and brands should be responsible for ultimate disposal and therefore should be required to make products environmentally sound. Safe circularity requires all materials to be free from hazardous chemicals and ready for reuse and safe recycling. All businesses along the supply chain should know and share information about the materials, ingredients and harmful chemicals being used in the products they manufacture, use and sell. The Strategy should include the phase out of harmful chemicals from textile products and processes, and use safe alternatives, including non-chemical ones. To avoid further contamination of the textile supply chain, globally agreed requirements for transparency, traceability, and accessibility of information on harmful chemicals in textile products should be encouraged by the Textile Strategy to contribute to the elimination of such substances in products and related material flows. Textile supply chains are multi-national, and the spread of harmful chemicals in them is hard to address until harmonized global actions are adopted. The Textile Strategy could play the leading role in developing global information requirements to address this issue.
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Meeting with Virginijus Sinkevičius (Commissioner) and

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

Response to Chemicals strategy for sustainability

19 Jun 2020

HEJSupport priorities for the EU Chemical Strategy for Sustainability We appreciate the opportunity to comment on the EU Commission Roadmap on the EU Chemical Strategy for Sustainability. We expect this strategy to deliver strong activities on the EU`s work on global policy level and regarding the implications of its work for developing and CEIT countries. The world is facing a global chemical crisis: the size of the chemical industry is projected to double by 2030, hazardous chemicals are released in large quantities, already globally banned chemicals appear in new products, hazardous wastes and chemicals are traded globally including via illegal channels, millions of lives and the ecosystem are severely damaged. According to the EU Commission (SWD (2019) 199) one third of chemicals produced in the EU are hazardous to the environment and two thirds are hazardous to human health. Being the region with major chemicals producers and users, the EU should have an obligation to become a global leader for a toxic-free environment. HEJSupport (Transparency Register ID 282761121111-78) is a non-profit organization working internationally to achieve a non-toxic environment. In the EU we focus on the international aspects of its chemical policies. We expect the EU to push • for a SAICM successor that includes a mechanism of work on new and existing issues of concern (IoCs) that should provide roadmaps, targets, milestones and indicators, and should have sustainable and sufficient funding. The mechanism to move IoCs to which no progress has been achieved to a level with increased obligations should include concrete risk elimination measures, and full public engagement • for a global overarching chemicals policy framework, that includes combined mandatory national action plans for all chemicals and waste conventions, SAICM and its successor, strong enforcement, and fair stakeholder participation at all levels, mandatory reporting and evaluation • for a reform of the Special Programme, to make it eligible for NGOs to apply and prioritize projects with clear identification of public engagement • for a global fund for exposure reduction to internalize cost of polluting industry and raise funds for risk reduction activities We expect the EU to • extend the scope of REACH to imported and exported articles, and the REACH authorization process to cover imported articles • apply REACH provisions to substances, mixtures and articles exported to third countries and assist third countries in strengthening their national regulations • withdraw existing exemptions in the Stockholm Convention and commit to abstain from possible exemptions in the future. • ensure strong enforcement of the provisions of the POPs Treaty, including those to which specific exemptions were previously required but later withdrawn (exp. PBDE recycling exemption) • establish a system for obligatory disclosure of hazardous chemicals in products and articles throughout the life cycle to ensure safe circular economy, efficient recycling, and public right to know • apply the same limits and standards for POPs in recycled and virgin materials to keep the circular economy clean. • prohibit the export of hazardous, electronic, and plastic waste in third countries. Electronic products in the end of life should not be considered as non-waste or materials for recycling and should be banned for exporting to developing or CEIT countries to avoid low capacity recycling and associated environmental and health risks. • fully implement and enforce the Ban amendment and plastic amendments under the Basel Convention • prohibit export and production of pesticides that are banned in the EU, encourage countries to apply safe and non-chemical alternatives • come up with an EU Endocrine Disrupting Chemicals Strategy including all elements of the EDC-Free Europe`s “Eight demands for an EU EDC Strategy” Contact: Dr Olga Speranskaya Alexandra Caterbow www.hej-support.org info@hej-support.org
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Response to Fitness Check on endocrine disruptors

10 Jul 2019

Thank you for giving the opportunity to comment on the Roadmap. The Fitness Check on EDCs presents another delay in the process to provide protection from EDCs for environment and health, especially for vulnerable groups. The current Commission has failed to deliver protective measures as described in the 7th EU Environment Action Programme (7th EAP) from 2013, which already aims to ensure minimization of exposure to EDCs. Several Commission reports have already pointed out the gaps in various pieces of EU legislation regarding these harmful hormone disruptors . As emphasized by the European Parliament Resolution on EDCs, adopted on 18 April 2019 , and by the 26 June 2019 Environment Council conclusions "Towards a sustainable chemicals policy for the Union" , it is now urgent for the European Commission to uphold its commitments as per the 7th EAP and effectively reduce people’s exposure to EDCs in a comprehensive way throughout Europe. The 2018 European Commission Communication "Towards a comprehensive European Union framework on endocrine disruptors" should in no way be considered as an update of the 1999 Community Strategy for EDCs. This eleven-page document fails to provide any proposal for specific measures, a timeline, targets, an action plan, or a budget. To achieve a real added value, the Fitness Check should focus on assessing how to strengthen protection against EDCs through improved and new EU regulations. In this way, the EU can deliver on its objectives to protect human health and the environment from endocrine disruptors, and in particular vulnerable groups. This approach should include international dimension of the Fitness Check exercise. Effective control of EDCs to ensure a high level of health and environment protection is not only essential for the purpose of imported products in the EU, but also in respect to the positions the EU is taking in multilateral initiatives for safer chemicals . Finally, the Fitness Check must also ensure that future provisions on EDCs will be fit for purpose to guarantee a clean circular economy and a non-toxic environment. Specific comments The approach of hazard identification is key for regulations on endocrine disrupting chemicals and will lead to better control of these substances. The Fitness Check on endocrine disruptors should thoroughly take into consideration the analysis and conclusions from the report commissioned by the European Parliament: “Endocrine Disruptors from Scientific Evidence to Human Health Protection” March 2019 . On the horizontal approach and criteria for the identification of endocrine disruptors: The 7th EAP requires in particular the EU to “develop harmonised hazard-based criteria for the identification of endocrine disruptors." These criteria must be based on the definition from the World Health Organization (WHO). In addition, full consideration of the differences in data availability is essential in order to ensure that substances are not being considered as safe just because not enough data are available to classify them as EDCs. It is also essential to ensure a higher level of transparency to indicate which substance has been assessed or in the process of being so. The inadequacy of the criteria adopted for the identification of EDCs under the Plant Protection Products regulation and the Biocidal Products regulation must be addressed. EDC-Free Europe has repeatedly warned that these criteria are not sufficient to protect human health and the environment. On regulatory consequences for endocrine disruptors: The different regulatory approaches for ED substances depending on the different pieces of legislation should not necessarily be taken as a problem or an indication of incoherence, as the text of the Roadmap seems to suggest. The deliberate choice of the EU.... full paper see attachment.
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Response to Towards a more comprehensive EU framework on endocrine disruptors

18 Jul 2018

HEJSupport`s response to EU Commission`s "Roadmap: Towards a more comprehensive EU framework on endocrine disruptors" areas(201res(2018)3295383: https://ec.europa.eu/info/law/better-regulation/initiative/255075/attachment/090166e5bba46e82_en HEJSupport welcomes that the EU Commission is becoming active on the topic of endocrine disrupters (EDs). This is a long overdue step, after the commitment in the 7th Environment Action Plan from 2013 to minimize the exposure to endocrine disruptors , and the European Council conclusions from 2016, which reiterates the need to protect humans and the environment from EDs and invites the EU Commission to update the 1999 EU strategy on endocrine disruptors as appropriate . However, although the need for exposure reduction was explicitly highlighted in both documents, the roadmap does not emphasize on that important demand. Activities to reduce exposure to EDs are not listed under potential types of actions. Therefore, we strongly urge the EU Commission to include a list of activities to force exposure reduction in their Communication to protect human health and environment in the EU. Although an EU Communication is a step in the right direction, it is important that the EU Commission will develop an EU EDC strategy as soon as possible. This strategy and also the presented Communication should include the following essential elements: • Public health, precaution and exposure reduction should be the cornerstone of a new EU EDC strategy • Regulation should be improved and the control of the use of EDCs should be controlled across all sectors • The regulatory substance-by-substance approach should be replaced by regulation of problematic groups of EDs • Testing, screening and identification should speed up • To achieve a clean circular economy EDs in products should be avoided from the start • Safer substitution and promotion of innovative solutions, like agroecology, should be enhanced • Health and environmental effects of EDs and EDC exposure should be monitored to be able to respond swiftly to minimize them. Additionally to the mentioned elements, awareness raising among EU citizens should be highlighted and suitable programmes should be established in the Communication and in a future EU EDC strategy. Especially most vulnerable groups, like pregnant women, are not aware of the health effects of EDs in the products they use and in their environment. Information materials for medical, health and educational professionals are urgently needed, so that they can advise the public on reducing their exposures. Disclosure of EDs and other chemicals in products is needed to ensure the right to know of citizens. The EDC Free Europe Alliance, of which HEJSupport is a member, called on EU Commission President Jean-Claude Juncker to bring out a fully-fledged strategy before the summer of 2018. The joint position of the Alliance presents more details of our demands for an EU-EDC strategy, which should be included in the roadmap. ( http://www.edc-free-europe.org/wp-content/uploads/2018/05/EDC-Free-statement-on-EU-EDC-Strategy-final-EN1.pdf) Contact: Alexandra Caterbow Co-Director alexandra.caterbow@hej-support.org HEJSupport – Health and Environment Justice Support e.V. www.hej-support.org von-Ruckteschell Weg 16 85221 Dachau, Germany
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