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European Network of Scientists for Social and Environmental Responsibility

ENSSER

The European Network of Scientists for Social and Environmental Responsibility (ENSSER) brings together independent scientific expertise to develop public-good knowledge for the critical assessment of existing and emerging technologies.

Lobbying Activity

Response to Export and import of hazardous chemicals

1 Aug 2025

As a concerned organisation, I am writing to urge the European Commission to fully align EU rules on the export and import of hazardous chemicals with its own health and environmental standards. What we are seeing is an immoral double standard: certain pesticides are banned in the EU because they are deemed too dangerous to use, but the Union still allows European companies to manufacture and export them to other countries. The use of these substances has been prohibited precisely because they pose serious risks to human health and the environment, including causing cancer, harming fertility, damaging child development, and polluting natural resources. Yet, instead of being removed from the market, they are sent abroad, often to countries with fewer protections, despite being banned for use in Europe. If we protect our own population and environment from these substances, it is unethical to purposefully expose other countries' populations and environment to them. Sending an export notification or requesting consent from importing countries is simply not enough to protect local communities and ecosystems from the devastating impacts these pesticides can have: we share responsibility for this if we produce and export these substances. And yet, 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. This is not a technical loophole. It is a conscious violation of human rights and environmental injustice. What is too dangerous for people in Europe is too dangerous for people anywhere. We therefore call on the European Commission to ensure 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. Moreover, it is particularly concerning 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 simply not enough. This is not a matter of consent, it is a matter of ethics. Exporting substances known to cause cancer, harm fertility, damage the development of children or poison water resources is simply immoral. The EU must lead by example and take a strong stand in support of health protection, environmental justice, and human rights globally, and stop the export of banned and hazardous pesticides. [attached- statement signed by 600 organisations]
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Meeting with Frans Timmermans (Executive Vice-President) and Greenpeace European Unit and

27 Jun 2023 · New genomic techniques

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and Corporate Europe Observatory

30 Mar 2017 · EU's Research Policy (Innovation Principle vs. Precautionary Principle)

Response to Draft Commission Directive updating the environmental risk assessment of GMOs

8 Dec 2016

We would like to submit following comments and also refer to our critique of the 2010 EFSA Guidance on ERA for GMPs (http://www.ensser.org/developing-responsible-approaches-to-risk-assessment/ensser-comments-on-final-efsa-gmp-era-guidance/) C1 3.b & c The amendment will lead to an exclusion of vast numbers of scientific peer-reviewed studies published by public scientific institutions from future ERA of GMOs in the EU. Many of these studies were funded by the EU and its Member States and are used in ERA until now. The extension of principles of Directive 2004/10 on testing chemical substances to the ERA of GMOs is inappropriate because apart from 1) excluding data it also will very likely lead to 2) establishing a bias in the set of the remaining data. 1) The intended exclusion of scientific studies from public scientific institutions from future ERA contradicts central provisions of Directive2001/18, e.g.: Preamble 20, Art 16, Annex II General Principle The requirement to only use data generated in GLP accredited laboratories will result in the undue preference of data from studies by commercial entities resp. the applicants. Only few public laboratories are GLP accredited, let alone laboratories that produce data relevant for ERA. While GLP as technical standards should guarantee the proper documentation and traceability of data and results to prevent fraud, they do not relate or even guarantee scientific value of the studies and results. The accepted methodology for securing scientific value is the peer-review process in respected scientific journals. Many of those studies produced by GLP accredited laboratories will not be published in peer-reviewed scientific journals thus will not be submitted to this common test on scientific value. 2) The intended creation of a biased database in ERA favouring studies claiming high levels of safety contradicts central provisions of Directive2001/18, e.g. Art 4, Annex II Objective As documented in many scientific publications an international controversy is on-going on whether studies by commercial entities resp. the applicants (likely to be conducted in GLP accredited laboratories) providing data for risk assessment claim a higher degree of safety than studies planned and undertaken by public science institutions independent from commercial interests (mostly without GLP accreditation) (references available on request) It is not the GLP accreditation itself that could cause such differences in results, but the approaches and methodologies chosen by the different research groups. Without going into details here, this debate underlines clearly the need to make it obligatory that GLP and non-GLP studies are included in risk assessments. C1 3.f The Directive is very clear on the nature of the comparator. According to the General Principles Annex II a GMO should be compared with the “non-modified organism from which it is derived”; in other word: the parental organisms. ENSSER has been commenting on this issue extensively (references available on request) and recommends that the amendment is reflecting the language of the General Principles. C1 3.a While ENSSER supports this improvement, the text should not refer to “Europe” but the “European Union”. Europe as a geographic area includes several countries - and therefor receiving environments - which are outside of the territory of the EU Member States. C1 3.d ENSSER supports this amendment. The limitations caused by providing raw data in pdf format on independent analysis of the data became obvious for us when scrutinising GMO application dossiers. ENSSER also learnt that EFSA does not necessarily receives these data in more appropriate formats which strongly restricts the possibility for EFSA experts to check the statements on statistical issues made by applicants. C1 3.e ENSSER supports this amendment. Any other option would not suffice the provisions of the Directive to ensure ERA based on high quality data.
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