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Health and Environment Justice Support

HEJSupport

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

Lobbying Activity

Meeting with Hildegard Bentele (Member of the European Parliament) and Bund für Umwelt und Naturschutz Deutschland e. V. and Women Engage for a Common Future

25 Sept 2024 · Plastic Policy

Response to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials

5 Mar 2024

HEJSupport welcomes the opportunity to submit feedback on the EC plans for restrictions on bisphenol A (BPA) and other bisphenols in food contact materials. 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 UNEP. We welcome the initiative of the Commission to ban BPA. However, it is not enough to just ban BPA and some other bisphenols instead of the whole group of bisphenols. A grouping approach should be applied to cover all bisphenols to protect human health and the environment at the highest level. The scope of the bisphenol ban should include, at a minimum, those meeting the criteria for classification as CMRs and EDCs for human health of Category 2. Not addressing bisphenols as a group leaves consumers and especially vulnerable groups such as children and pregnant women exposed to harmful chemicals associated with e.g. hormone-related cancers, infertility, and metabolic diseases. The precautionary principle, as enshrined in Art 191 of the TFEU, should definitely be applied in this legislation. It is essential to change the authorization for BPS in plastics in Regulation 10/2011 on plastic food contact materials to ensure no regrettable substitution of BPA for BPS is allowed. BPS should be removed from the list of authorized substances in Regulation 10/2011 like BPA so that companies will need to re-apply for specific applications. It is key to ensure that bisphenols are not present in articles containing recycled materials. These articles include paper, board materials and plastics. Data from ECHA confirms that some manufacturers substitute BPA with BPS in paper and board materials, thus contaminating articles with already confirmed toxic substances. Moreover, BPA from PET products is already found in recycled materials. Data from the European market confirms a higher migration level of BPA from recycled materials than from virgin PET bottles. It is vital to ensure that food contact materials with recycled content are not contaminated with bisphenols at levels that can harm human health, prioritizing the most vulnerable groups, including children. Finally, we want to emphasize the importance of revising the FCM framework legislation without further delays. Contact Dr Olga Speranskaya, Alexandra Caterbow www.hej-support.org, info@hej-support.org
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Meeting with Jutta Paulus (Member of the European Parliament) and European Environmental Bureau and

23 Jan 2024 · REACH

Response to Environmental claims based on environmental footprint methods

21 Jul 2023

This is a submission on behalf of the following members of the NGO Coalition Exit Plastik: a tip: tap e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Heinrich-Böll-Stiftung, HEJSupport e.V., Küste gegen Plastik e.V., Women Engage for a Common Future e.V. (WECF), Zero Waste Germany e.V. und Zero Waste Kiel e.V.
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

30 May 2023

This is a submission on behalf of the NGO Coalition Exit Plastik. Members of the Coalition are: a tip: tap e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Greenpeace e.V., Heinrich-Böll-Stiftung, HEJSupport e.V., Küste gegen Plastik e.V., Surfrider Foundation Germany e.V., Women Engage for a Common Future e.V. (WECF), Zero Waste Germany e.V. und Zero Waste Kiel e.V.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

24 Apr 2023

This is a submission on behalf of the German NGO Alliance Exit Plastik. Members of Exit Plastik, who developed this paper are: a tip: tap e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Greenpeace e.V., HEJSupport e.V., Küste gegen Plastik e.V., Surfrider Foundation Germany e.V., Women Engage for a Common Future e.V. (WECF), Zero Waste Germany e.V. und Zero Waste Kiel e.V. The submission is attached as a pdf file.
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Response to Introducing new hazard classes–CLP revision

17 Oct 2022

HEJSupport welcomes the draft proposal of the EU Commission for new hazard classes in the annexes of the CLP regulation and the draft criteria for ED identification. The proposal reflects the goals of the CSS and leads to better prevention and minimization of EDC exposure. Many studies show that EDCs pose a serious risk to the environment and human health, especially to vulnerable groups, including children. Diabetes, cancer, and developmental disorders are among illnesses, often irreversible, linked to EDC exposure. We welcome the introduction of two categories, category 1 for known or presumed endocrine disruptors and category 2 for suspected endocrine disruptors. With this, the ED categories are coherent with the existing CMR categories. The proposal for classification is also in line with the WHO definition of EDCs and presents the current state of the science. A short transition period is necessary to protect citizens and workers without further delay. A transition period of 42 months + 18 months until entry into force is way too long and should be drastically shortened. Information about the presence of EDCs in products people buy and work with should be transparent, reliable, and accessible to all. An easy-to-understand symbol/pictogram is necessary to provide a clear notice of the presence of endocrine disruptors in products and at the workplace.
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