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Health & Environment Alliance

HEAL

The Health and Environment Alliance (HEAL) addresses how the environment affects public health in Europe.

Lobbying Activity

Health Alliance backs stronger EU chemicals agency with expanded resources

1 Dec 2025
Topic — Proposal to strengthen governance and financing of the European Chemicals Agency.
Message — The organisation supports strengthening ECHA's governance and increasing its capacities. They request adding protection for vulnerable groups, aligning the proposal with the One Substance One Assessment approach, and fortifying the agency's independence.123
Why — This would enable ECHA to better protect health and environment through stronger scientific capacity.45
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Response to Strategy on Intergenerational Fairness

10 Nov 2025

The Health and Environment Alliance (HEAL) welcomes the initiative for a Strategy on Intergenerational Fairness. Intergenerational Fairness is at the heart of the European project and a topic of high relevance for the health of people in the EU and beyond. HEAL calls on the EU Commission to embed the following four key issues into the Intergenerational Fairness Strategy: 1. Intensifying efforts to address the triple planetary crisis of climate change, biodiversity loss and pollution 2. Further integrating long-term thinking into decision-making 3. Protecting and strengthening civil societys engagement 4. Ensuring the next EU budget invests in better health, not pollution We have attached a our detailed comments on these four key issues. Complementing the HEAL input to this initiative, we also support the comments of the Child Rights International Network (CRIN).
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Health group opposes loosening pesticide approval standards in EU omnibus

13 Oct 2025
Topic — EU proposal to simplify food and feed safety regulations and speed up product approvals.
Message — The organization opposes changes that would lower health and environmental protections in pesticide and biocide approval systems. They argue simplification cannot come at the cost of protection and that an omnibus is unsuitable for such changes. They support maintaining comprehensive reviews and endocrine disruptor assessments.123
Why — This preserves their mission to protect health from environmental chemical exposures.45
Impact — Farmers and industry lose faster access to new pesticides and biocides.67
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Meeting with Jutta Paulus (Member of the European Parliament) and Chemicals, Health and Environment Monitoring Trust

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

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen) and Friends of the Earth Europe and

29 Sept 2025 · presentation of and discussion about their roadmap to reduce pesticide use in Europe

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

HEAL urges pollution prevention in EU cardiovascular health plan

15 Sept 2025
Topic — The European Commission is developing a plan to improve cardiovascular health outcomes across the EU.
Message — HEAL calls for the plan to prioritize reducing air and chemical pollution at the source. They demand an end to fossil fuel subsidies and increased funding for pollution prevention.12
Why — Success would increase HEAL's influence over EU health policy and help achieve their objectives.3
Impact — Fossil fuel companies would lose billions in subsidies and face stricter emissions limits.4
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Health & Environment Alliance urges stronger EU civil society protections

5 Sept 2025
Topic — The EU is developing a framework to support civil society and address shrinking civic space.
Message — HEAL calls for a well-resourced strategy and binding commitments for structured civil dialogue with EU institutions. They also request increased funding in the next budget to end competition for reduced resources.123
Why — Secured funding and formal dialogue would provide financial stability and guaranteed access to EU decision-making.45
Impact — Corporate lobbyists may lose their disproportionate access to decision-makers if civil society engagement is prioritized.6
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HEAL urges a health-centered and binding climate resilience law

4 Sept 2025
Topic — Consultation on an integrated framework to manage accelerating European climate change risks.
Message — HEAL requests a binding legal mandate featuring measurable health indicators and targets. They propose mandatory health integration for national adaptation strategies and heat-health plans.12
Why — This mandate would secure health's position in climate policy and unlock dedicated funding.34
Impact — Member States lose autonomy as their fragmented climate strategies face mandatory EU harmonization.5
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Meeting with Ewa Malz (Head of Unit Environment)

2 Sept 2025 · Simplification

Health and Environment Alliance urges health protections in industrial plans

8 Jul 2025
Topic — EU initiative to accelerate industrial decarbonisation and stimulate investments in energy-intensive sectors.
Message — The group demands the Act include human health protections and significant pollution reduction targets. They advocate for a rapid transition to renewable energy rather than fossil gas infrastructure. They also call for an end to financial subsidies for polluting industries.12
Why — Strengthening pollution controls would lower massive societal costs from healthcare and climate-related events.3
Impact — Fossil fuel companies would lose financial support and face stricter limits on gas power generation.45
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Meeting with Anne Funch Jensen (Cabinet of Commissioner Piotr Serafin) and Transport and Environment (European Federation for Transport and Environment) and

11 Jun 2025 · Exchange of views on the future Multiannual Financial Framework and other EU priorities

Meeting with Francois Wakenhut (Head of Unit Environment) and European Environmental Bureau and ClientEarth AISBL

6 Jun 2025 · Exchange on the implementation of Directive (EU) 2024/2881 of the European Parliament and of the Council of 23 October 2024 on ambient air quality and cleaner air for Europe (recast)

Response to Policy agenda for cities

22 May 2025

Environment and climate stressors - air, noise, chemicals pollution; heat; lack of urban green space - are major determinants of city residents health. Health impacts include premature mortality, increased risk of cancers, cardiovascular and respiratory disease, heat stress, as well as mental health impacts. However, this health dimension is currently lacking in most of the existing EU urban initiatives on sustainability and climate. Health and well-being considerations, evidence, indicators and monitoring, as well as the definition of protection and prevention goals should be an essential part of the EU cities new policy agenda. As a first step, an EU urban health platform should be set up. The new cities agenda should include providing financing to better protect residents from environmental, climate stressors under the next EU budget (MFF). Fostering inter-sectoral / inter-departmental collaboration at city, regional, national and EU level should also be encouraged through a strengthened governance approach. In current governance systems, too many siloes exist, leading to missed opportunities for health benefits of sustainability and climate measures. The health of vulnerable groups in cities, including pregnant women, children, those already sick, the elderly, those experiencing socio-economic inequalities is particularly at risk from climate and environmental stressors. These groups should be specifically considered in future initiatives and policy measures, including targeted policies. In the development of sustainability, climate and health policies and initiatives for the urban level civil society organisations and city residents need to be involved. In addition, research projects such as the EU funded research project UBDPolicy provide for important data on the health impacts of environmental, climate stressors and the benefits of urban sustainability initiatives. A clear mechanism should be set up for the integration of new research findings, data from health impact assessments, and evidence on economic health benefits of urban sustainability measures into the EU new city agenda, as well as into city-level decision-making. An inclusive and consultative approach to stakeholder and science involvement will help to increase support for the implementation of EU environmental and climate policies at the urban level. More information: https://www.env-health.org/addressing-air-pollution-in-cities-can-greatly-lessen-disease-burden-and-health-costs/ https://www.env-health.org/briefing-how-clean-air-action-can-help-address-socio-economic-health-inequalities/ https://www.env-health.org/new-policy-brief-on-the-health-benefits-of-low-emission-zones-in-brussels-and-antwerp/ ubdpolicy.eu
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Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and Standing Committee of European Doctors

21 May 2025 · Air pollution in Europe

Meeting with Veronica Manfredi (Director Environment)

13 May 2025 · Revision of REACH Regulation

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

8 May 2025 · Impact of chemicals on fertility; REACH revision

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

14 Feb 2025 · EU chemicals regulations / REACH revision

Meeting with Martin Hojsík (Member of the European Parliament)

6 Nov 2024 · Endocrine disrupting chemicals - event with EDC-Free Europe Campaign

Meeting with Christophe Clergeau (Member of the European Parliament)

17 Oct 2024 · Chemicals

Meeting with Robert Biedroń (Member of the European Parliament)

3 Oct 2024 · Air pollution

Response to Evaluation of the National Emission reduction Commitments Directive

13 Mar 2024

The Health and Environment Alliance (HEAL) welcomes the opportunity to input into the Commissions call for evidence on the evaluation of the National Emission reduction Commitments (NEC) Directive, in place since 2016, and successor of the National Emission Ceilings Directive. HEAL and other health organisations had extensively provided expertise and advocated during the negotiations for the current NEC, highlighting that the directive needs a high level of ambition in order to deliver clean air and health benefits. Complementary to the Ambient Air Quality Directive (AAQD) that regulates maximum concentrations of key air pollutants for our health and the environment in ambient air across the EU, the NEC Directive is a critical instrument to reduce emissions of key air pollutants at Member State level. It aims at limiting transboundary air pollution between different countries, thus contributing to improving ambient air quality locally with benefits for peoples health and nature. Achieving emission reductions under the NEC has the potential to bring significant socio-economic benefits. HEAL strongly considers that the unacceptably high health and environmental burden from air pollution is largely preventable through firm political will expressed via legislation. Unfortunately, in this respect the current NEC is a missed opportunity to save lives, prevent disease, and save costs. HEAL considers that the NEC should be revised, to address several shortcomings and tackle new pollution developments (inclusion of methane, intermediate binding targets, stronger action on black carbon, etc). Such a revision is the logical next step in the EUs efforts for zero pollution and tackling climate change.
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HEAL urges faster phase-out of bisphenols in food contact materials

8 Mar 2024
Topic — The consultation addresses a draft regulation restricting bisphenols in food contact materials.
Message — HEAL supports restricting bisphenols as a group to prevent unsafe replacements. They want a wider scope and shorter transition periods.123
Why — Stricter rules would lower the economic burden on health systems from chemical-related diseases.4
Impact — Companies using BPS as a BPA substitute would face stricter re-authorisation requirements.5
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Response to 8th Environment Action Programme – Mid-term Review

25 Jan 2024

According to the World Health Organisation (WHO), the environment is a major determinant of health, estimated to account for almost 20% of all deaths in the WHO European Region. The 8th EU Environment Action Programme (8 EAP) that entered into force in May 2022 sets the framework for EU environmental policy until 2030. It is a key policy instrument to protect health and prevent disease from climate and environmental threats. In particular, the 8 EAP sets a number of priority objectives, targets and indicators until 2030 in areas that are of high relevance for health, such as climate change mitigation and adaptation, as well as zero pollution (including on air pollution) and a toxic-free environment. Among so called enabling conditions, the 8 EAP commits to reduce environmental inequalities. The Health and Environment Alliance (HEAL), an alliance of over 80 member organisations, has been engaged in the policy development and implementation of the 8 EAP, and previous EAPs. We welcome the opportunity to respond to this consultation. HEAL considers that overall, since 2022, Member States have been too slow and unambitious in the implementation of the 8 EAP commitments, which results in health impacts and cost occurring which are preventable. Given the growing body of evidence and data on how the environment impacts health in the European Union, HEAL considers it key that for the remaining time of the 8 EAP, Member states step up in taking measures to implement the 8 EAP objectives, recognizing the urgency to act on the multiple crises including from global heating, environmental pollution and biodiversity loss. For the remaining years of the 8 EAP, HEAL urges Member States to significantly increase delivering on the 8 EAP objectives, especially when it comes to adopting measures which recognize the urgency to act, ending fossil fuel subsidies, and swifter action on zero pollution for a non-toxic environment (air and chemicals pollution): 1. Ending fossil fuel subsidies: EUs credibility as a global leader at stake 2.Tackling health harm from air pollution inequalities 3. Swifter action on reducing health harm from hazardous chemicals This would also be in line with and help to implement the EU Member States commitments in the Declaration of the Seventh Ministerial Conference on Environment and Health in Budapest in 2023. In addition, HEAL calls on the European Commission and Member States to recognize the interlinkages between the social and the environmental determinants of health, and take measures to address social inequalities and health for a Just Transition, not only in the 8 EAP implementation period, but also in the development and implementation of a 9th EU Environment Action Programme.
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Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

7 Nov 2023 · Transition towards sustainable food systems

Meeting with Kurt Vandenberghe (Director-General Climate Action)

19 Sept 2023 · Keynote speech at the Climate and Health Adaptation conference

Meeting with João Albuquerque (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and

25 Apr 2023 · CLP - Classification, labelling and packaging

HEAL Urges Tougher Hazard Standards and Faster Chemical Regulation

29 Mar 2023
Topic — The EU is updating regulations on how chemicals are classified, labelled, and packaged for safety.
Message — HEAL supports new hazard categories for endocrine disruptors and recommends setting clear deadlines for regulatory decisions. They also call for prioritizing chemical groups and keeping hazard warnings on physical labels.123
Why — Public health and the environment benefit from stricter, faster, and more transparent chemical hazard identification.4
Impact — Chemical companies lose exclusive control over classification proposals and must justify divergent hazard data.56
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Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

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

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 Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

7 Dec 2022 · Follow-up on HEAL's stepping down from the High-Level Roundtable on the Chemicals Strategy

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

8 Nov 2022 · reaction on AAQD

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

8 Nov 2022 · Air quality

Health group HEAL urges swift adoption of new hazard classes

13 Oct 2022
Topic — The EU is revising chemical classification rules to include new hazard classes.
Message — HEAL demands the rapid introduction of hazard classes for endocrine disruptors and persistent chemicals. They advocate for shorter transition periods and alignment with existing scientific guidance. The group also requests clear pictograms and hazard statements including impacts on future generations.123
Why — Stronger regulations help the organization achieve its mission of protecting public health.4
Impact — Chemical manufacturers would face stricter labelling requirements and tighter deadlines for market compliance.5
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Meeting with Daphne Von Buxhoeveden (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

10 Oct 2022 · VTC meeting on health and environmental civil society air quality

HEAL backs ECHA reform and fees for non-compliant companies

6 Oct 2022
Topic — The proposal aims to modernize the governance and financing of the European Chemicals Agency.
Message — HEAL supports the proposal to ensure the agency handles its expanding workload. They urge the Commission to introduce fees for non-compliant registration dossiers. Fees for hazardous substances should also incentivize switching to safer alternatives.12
Why — This would strengthen the agency’s capacity to protect public health and the environment.3
Impact — Non-compliant chemical companies would face higher costs through new administrative fees.4
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Health Alliance urges 80% pesticide cut by 2030, not 50%

19 Sept 2022
Topic — EU regulation setting binding targets for reducing pesticide use and risk.
Message — The organization demands an 80% reduction in synthetic pesticide use by 2030 with complete phase-out by 2035, not the proposed 50% target. They want buffer zones around sensitive areas increased from 3 meters to 50-100 meters, and stricter definitions of Integrated Pest Management to make chemicals a last resort.1234
Why — This would reduce public health risks from pesticide exposure linked to cancer, infertility and cognitive disorders.567
Impact — Pesticide manufacturers lose sales from stricter limits and expanded pesticide-free buffer zones.8
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Meeting with Virginijus Sinkevičius (Commissioner) and

7 Sept 2022 · To exchange views, upon HEAL’s request, on the upcoming Commission proposal for a revision of the Ambient Air Quality directives

Response to Evaluation of the LIFE Programme 2014-2020

13 Apr 2022

The Health and Environment Alliance (HEAL) is the leading European not-for-profit organisation addressing how the natural and built environments affect health in the European Union (EU). As a beneficiary of the LIFE operational grant, HEAL welcomes the opportunity to give input into the evaluation of the LIFE programme 2014-2020. In HEAL’s view: - The LIFE programme is of high relevance to the implementation of EU’s environment and climate policies. In order to ensure coherence and effectiveness of the programme fully implementing the EU Green Deal, its zero pollution agenda, the Chemicals strategy for sustainability, the Farm to Fork Strategy and the newly adopted 8th Environment Action Programme should be the guiding principle for LIFE now and in the future period. - The science is very clear on the state of the environment and how it impacts health. In order to ensure efficiency in addressing these impacts, the LIFE programme needs to continue to explicitly address the climate – environment – health nexus. Attention should also be given to highlighting the signficant co-benefits to health and well-being which will be gained through ambitious EU environment and climate policies. - Providing financial support and building up capacity for civil society to participate in the development and implementation of EU policies on the basis of EU values, and act as a watchdog at all levels of governance, is essential for ensuring that the proven EU added value in tackling global challenges such as climate change, environmental degradation and their corresponding health impacts is made operational. There is a continued need for NGO operational grants in the next LIFE grant cycle.
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Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski)

11 Apr 2022 · Delay to EU Pesticide Reduction Exposes Citizens to Increased Health Risks

Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

9 Mar 2022 · VTC meeting: Revision of the SUD Proposal

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and Chemicals, Health and Environment Monitoring Trust 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 Chemicals, Health and Environment Monitoring Trust 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 Chemicals, Health and Environment Monitoring Trust and International Pollutants Elimination Network

8 Dec 2021 · EU Chemicals Strategy for Sustainability and PFAS

Meeting with Kadri Simson (Commissioner) and

3 Dec 2021 · Discussion on upcoming Hydrogen and Decarbonised Gas Markets Package (adoption foreseen for 14.12.2021)

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

14 Oct 2021 · To discuss the endocrine disrupting chemicals & cosmetics

Meeting with Thierry Breton (Commissioner) and

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

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

1 Jun 2021

The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the inception impact assessment for the revision of the EU legislation on hazard classification, labelling and packaging of chemicals (CLP). We are pleased with the Commission’s commitment under the Chemicals Strategy for Sustainability (CSS) to reinforce the CLP Regulation (together with REACH) in order to rapidly respond to scientific findings and address ongoing and emerging health and environmental concerns. However, we regret to see that the IIA roadmap falls short in delivering the Commission’s commitment. CLP is a cornerstone of the EU chemicals legislation and its purpose is to ensure a high level of protection of health and the environment as well as the free movement of substances, mixtures and articles. The assessment at the basis of classification determines whether a substance or mixture meets certain classification criteria to be considered as hazardous for human or environmental health. It triggers policy action under other legislations, and determines manufacture, use, distribution and trade of the substance. Consequently, it is of utmost importance that substances or mixtures that are hazardous to human health and the environment are properly identified via CLP and that this classification can feed into other chemical legislations. CLP is currently missing hazard classes. As a result, certain hazardous substances that can give rise to human diseases and environmental degradation are still placed on the market, without being properly identified and without adequate restrictions being implemented under other legislations. In parallel, there is a need to increase the quality and transparency in the hazard assessment process, to make more resources available to the authorities in charge of it and to enhance safeguards for its integrity. To our disappointment, the IIA roadmap does not mention all the important European Commission commitments foreseen for the CLP review in the EU CSS. It focuses considerably on the quantification of the potential economic impacts of the CLP review for companies at the expense of protection needs. There is indeed only little emphasis on the creation of new hazard classes and the strengthening of the hazard evaluation procedure in Europe – which should be the main aim of this revision process in view of delivering the European Commission commitments under the CSS. According to HEAL and on the basis of the CSS commitments, the IIA should focus on what elements the CLP review must include to increase human and environmental protection from chemical substances and mixtures, always in line with the latest scientific knowledge. Increased human and environmental health protection will inevitably result in significant long-term economic benefits for society. Saving on health costs associated with chemical exposure and on resources dedicated to mitigating impacts of chemicals and pollution clean-up pollution (e.g. drinking water companies) will not only protect the health of future generations, but it will also increase the overall wellbeing and functioning of our society and economy. (further details are provided in the attached document)
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the inception impact assessment for the revision of the REACH legislation. We support the Commission’s assessment of the state of the legislation. In HEAL’s view, an upgrade of REACH is necessary to fully untap its health protection potential against hazardous substances, better serve disease prevention and meet the EU chemicals strategy for sustainability (CSS) objective of a toxic-free environment, in which chemicals production and use avoid harm to current and future generations. To do so, it is important that the review: - fully incorporates earlier findings about the EU chemicals legislative acquis, e.g. study for the strategy on a non-toxic environment, 2018 REACH review, fitness check on endocrine disruptors; - proposes actions to address every REACH-related commitment present in the CSS. HEAL therefore urges the Commission to guarantee that the following actions are included in the upcoming revision: - Set up a clear action plan of action to deliver the CSS ‘zero compliance’ commitment, which is currently absent from the roadmap. This is crucial to make the ‘no data – no market’ principle a reality, to speed up the evaluation process and to ensure that it allows for swift regulatory action when a substance presents concerns for health and/or the environment. This requires a commitment to upgrade completeness checks, define conditions under which registration numbers can be revoked, and explore options for mandatory and regular updates to registration dossiers. When the registrants fail to deliver the necessary data to the proper evaluation of a chemical, authorities should always have the flexibility to apply the precautionary principle. - Revise information requirements: for all hazard properties (including endocrine disruption, carcinogenicity, mutagenicity, reproductive toxicity, immunotoxicity, neurotoxicity, immunotoxicity as well as environmental toxicity including mobility) for all tonnage levels. The current lack of information for low-tonnage chemicals is of concern. Comprehensive information about use and exposure is also necessary for further risk management measures. - Introduce registration requirements for polymers, starting with those that people are most exposed to via consumer products; - Introduce SVHC categories for endocrine disrupting chemicals, persistent, mobile, toxic (PMT) and very persistent and very mobile substances (vPvM) – as promised in the CSS. The introduction of SVHC categories for the immunotoxicity and neurotoxicity endpoints should also be considered. When substances are classified under CLP for endpoints that match with existing SVHC categories, SVHC identification should be triggered automatically. - Introduce a generic mixture assessment factor to address the combination effects of chemicals for health and the environment and truly increase protection (civil society groups support the establishment of a generic MAF of 100); - Reform and accelerate both restriction and authorization processes in view of enhanced protection. In so doing, the commitment to truly implement the precautionary principle and place the burden of proof on industry applicants (especially for derogations requests) is crucial to guarantee that hazardous chemicals are restricted and that only uses, for which there is a societal added-value without safer alternatives can be granted, albeit in a time-limited way. The REACH revision must also lead to the initiation of restrictions for all priority substances of concern outlined in the CSS, including based on a grouping approach – which is not clear from the roadmap. - Increase transparency: through improved provisions in articles 7 and 33 to guarantee transparency about hazardous chemical presence in articles, including from online retailers. Finally, the proceedings of the REACH committee, including Member States’ votes, should be made public.
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Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

Response to Revision of EU rules on food contact materials

25 Jan 2021

The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the European Commission’s plans for revisions of the EU Food Contact Materials (FCM) legislation. HEAL has long called on the EU authorities to close the loopholes in the legislation, which put the health of Europeans at risk through potential leaching of chemicals of concerns from the food contact articles and materials into the food. Our full response can be found in the attached.
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Response to Revision of EU Ambient Air Quality legislation

13 Jan 2021

Air pollution is the number one environmental threat to health in the European region and globally, leading to 400,000 premature deaths and hundreds of billions of euros in health costs in Europe each year. There is a large body of evidence on how air pollution harms health. Poor air quality is a leading risk factor for chronic disease including heart and lung diseases or cancer. In the past years, studies have especially pointed to children being particularly at risk of harm by polluted air, given that their heart, brain and nervous systems are still developing. Their health can already be affected before birth, with lifelong consequences. Air pollution is largely preventable and EU air quality standards – especially legally binding limit values – have proven to be instrumental in reducing pollution. The EU Ambient Air Quality Directives are the cornerstone of the EU’s clean air policies, setting standards for air quality to protect people’s health. The Health and Environment Alliance (HEAL), the leading European not-for-profit organisation addressing how the natural and built environment affects health in the European Union, welcomes the publication of the Commission’s inception impact assessment for the revision of the ambient air quality directives (AAQD). This publication is the long awaited first step of the legislative update urgently needed for health protection from ambient air pollution, recognized through the EU Green Deal’s commitment to a zero pollution ambition for a toxic-free environment. In view of the revision, HEAL would like to underline the following: : 1. Full alignment of EU standards with latest available science is overdue The current EU AAQD standards are the result of an outdated political compromise that does not reflect the latest science embodied in the WHO guidelines. Currently, WHO is revising its air quality guidelines and expects to publish the outcome of this thorough scientific process in 2021. Thus, the EU legally binding limits for air pollutants should use and be as strict as these WHO regularly updated guidelines. 2. Swift legislative process reflecting the urgency to act is needed The completion of the legislative process by the European Commission and the EU co-legislators should result in the health benefits of the EU Green Deal being breathable by the end of the current legislature 2019-2024, in order to reflect the latest available science and answer the high public demand for effective policy action in air pollution prevention.
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Meeting with Virginijus Sinkevičius (Commissioner) and

12 Jan 2021 · To discuss the implementation of the Biodiversity strategy, the actions under the zero-pollution ambition as well as green funding under the new MFF and the recovery funds.

Response to 8th Environment Action Programme

22 Dec 2020

The Health and Environment Alliance (HEAL) welcomes the draft Decision on the 8th Environment Action Programme (8EAP) from the European Commission, which will now go into legislative debate. In particular we welcome the objective on pursuing a zero-pollution ambition for a toxic free-environment (Article 2.d). The World Health Organization (WHO) says 25% of all death and disease in the European region is due to environmental factors. The urgency to act to prevent harm from chemical or air pollution has been demonstrated. Our vulnerability is amplified by climate change, a cause of systemic threat to public health, as well as the COVID-19 pandemic and economic crisis. HEAL considers essential for the 8EAP’s success that it provides a foundation to: 1. Hold Member States accountable for the continuity of the EU Green Deal’s objectives in legislation beyond 2024 The 7EAP finishes in 2020 and committed the EU co-legislators to a coherent and comprehensive long-term vision until 2050 on climate, health and environmental actions. It enabled the assessment of the European Commission’s performance in steering the delivery of EU commitments in the fields of sustainability: the evaluation concluded that “its 2050 vision and priority objectives are still valid” but “that progress related to nature protection, health and policy integration was not sufficient.” While implementation and enforcement of EU environmental and climate legislation heavily depend on political will at national level, the European Green Deal Communication (EGD) only commits the current 2019-2024 EU Commission. To achieve the transformational, systemic change needed to address the magnitude of the challenges we are facing today, the 8EAP must provide the foundations for a successor of the EGD which leads us closer to SDG 2030 goals.The 8EAP will also provide a further incentive for Member States to act on environmental pollution and climate, where political commitment in the past has often been insufficient (e.g. exceedance of EU clean air standards). Building on the 7EAP vision and the EDG objectives, the 8EAP - “General Union Environment Action Programme to 2030” - will commit both the EU Member States and Parliament, thereby providing for policy coherence and continuity in the field of environmental health beyond the mandate of the current EU Commission. The 8EAP will succeed if it helps amplify synergies of policy action in line with the EGD at every governance level in the EU and also helps accelerate the implementation and enforcement path. 2. Check that budgetary priorities are aligned with the zero pollution ambition for a toxic free environment This starts with ensuring adequate financial means to implement policies stemming from EU’s zero pollution ambition – such as from the Chemicals Strategy for Sustainability published in 2020 or from the Zero Pollution Action Plan expected in 2021 - or the Farm to Fork Strategy. The 8EAP could monitor and report back to citizens if adequate funding at EU, national and local level is available to deliver on the tasks stemming from the EGD. With the growing importance of impacts of the urban environments on health, the 8EAP should support city-level action. 3. Ensure timely monitoring, transparency and follow up of data on impacts of the environment on health The draft 8EAP proposes how the programme is to be monitored and how communication on the results of that monitoring should be done. Full transparency of scientific data, inclusion of citizen science, timely (as close as possible to real time) universal accessibility of the data and high-level political follow-up are essential for effective public participation, implementation and enforcement of EU’s environmental and climate legislation. In particular, direct and indirect health costs of environmental pollution and the cost of policy inaction should be part of the 8EAP indicators, as well as spotlighting increasing environmental health inequalities.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

27 Oct 2020

Beat pollution – prevent disease bit.ly/2G2BDki With a view to better protect health and prevent disease and ill-health, HEAL considers it essential that the ZPAP includes tangible measures, timelines and goals, to swiftly achieve a reduction of the environmental and climate-related burden of disease. According to the latest figures from WHO and EEA, 1 in 8 deaths in the EU are attributable to the environment. In its 2020 SOER the EEA reported that “exposure to fine particulate matter is responsible for around 400 000 premature deaths in Europe every year”, “human health and well‑being are still affected by noise, hazardous chemicals and climate change” and “accelerating climate change is likely to bring increased risks, particularly for vulnerable groups.” Ending health harm from pollution requires firm preventive and remedial action and needs political will and commitment at all levels of policy making. Protecting every human being from pollution - especially those that are most vulnerable - requires developing and implementing disease preventing policies that a) build on the latest science, b) prioritise prevention and precaution (e.g. preventing pollution at source) and c) are enshrined in binding legislation with clear goals and timelines. In HEAL’s view the ZPAP has to build on 3 principles: 1. Zero harm from pollution Everyone is affected by pollution, and as a society, we are only as strong and resilient to it as the most vulnerable among us. The aim of a zero pollution action plan should thus be to urgently and drastically reduce the magnitude of environmental stressors on the entire population and those with one or multiple forms of biological or social vulnerability, such as children, older people, those already sick and people living in poverty. The ZPAP should also aim to prevent impacts of pollution in early life and at critical windows of development, which can increase the risk of developing disease much later in life, and tackle the complexity of pollution exposure, e.g. exposure to multiple stressors over a day and over a lifetime and impacts of pollution mixtures. The ZPAP should better recognise the interlinkages between environmental, health and social inequalities and propose integrated measures. 2. Zero money for pollution Preventing pollution means ending direct or indirect public financing of polluting processes. This requires fully aligning the EU budget and COVID-19 recovery funds with the zero pollution objective of cutting pollution at the source. A crucial tool to attain this objective is for the EU to adopt a comprehensive climate and environmental conditionality list for the MFF and Next Generation EU. This list should be in line with the proposal HEAL formulated jointly with the members of the Green 10 coalition: https://bit.ly/35a1LCh.The ZPAP should also further the full application of the polluter-pays-principle and truly encourage polluting industries to switch to ‘do no harm’ processes. 3. Zero delay in stopping pollution Answering the urgent need to protect health from pollution requires a short timeline to ban and phase-out toxic substances and transform polluting economies and ways of life. In order to protect health today and in the future, HEAL urges the European Commission in particular: - to enable the path to achieving climate neutrality by 2040, including through upping the EU’s 2030 GHG target to at least -65%, and ending subsidies to any fossil fuels by 2025 - to achieve good air quality outside and inside with no significant health harm by 2030: by swiftly proposing the full alignment of EU air standards with WHO guidelines and the latest science – with implementation by the next EU elections of 2024; by further cutting pollution at the source; and, by continuing to act on exceedances of air standards, and giving greater policy priority to healthy indoor environments - to end chemical pollution in the air, water and soil by moving to 100% non-toxic material cycles by 2030
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HEAL urges immediate pesticide cuts instead of more assessments

5 Aug 2020
Topic — The European Commission is revising rules for the sustainable use of pesticides.
Message — HEAL urges the Commission to move from promises to concrete action instead of undertaking another impact assessment. They support an 80% reduction in synthetic pesticides by 2030.123
Why — Drastic use reductions would deliver major health benefits across the lifespans of European citizens.4
Impact — Agrochemical companies would lose profits from the sale of highly hazardous pesticides.5
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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

10 Jun 2020

The Health and Environment Alliance (HEAL) is grateful for the opportunity to comment on the European Commission roadmap on a chemical strategy for sustainability. We welcome the stated ambition to tailor the upcoming strategy in order to serve the Zero Pollution ambition towards a toxic-free environment. Our detailed comments can be found in the attached document.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Transport and Environment (European Federation for Transport and Environment) and

3 Jun 2020 · Chemicals Strategy

Response to 2030 Climate Target Plan

15 Apr 2020

HEAL feedback on the European Commission roadmap 2030 Climate Target Plan Climate change is the greatest threat to public health of the 21st century, and decisive and strong mitigation action will yield large health benefits, also in Europe. The Health and Environment Alliance (HEAL) welcomes the EU Commission’s commitment to continue the process for upping the bloc’s 2030 goal with the COP26 postponement, and the goal to achieve climate neutrality in 2050. However, this overall climate commitment also needs to translate into the EU taking a leadership role on even stronger mitigation action for 2030, given the scientific understanding on the remaining carbon budget and the reaching of tipping points. The EU’s climate commitment must mean achieving greater GHG reduction in the next years - and not wait for the too distant 2050 future: this will also be the best way to promote people’s health. This means that the Commission should move towards upping the EU’s 2030 goal to - at least - 65% emissions reduction, and carry out the respective assessment. The uptake of the emissions reduction targets needs to be more ambitiously set in next decades rather than 2 decades after 2030. We lack time for change, it needs to start now more radically and follow more an even linear line to a net zero EU. Moreover, under a revised heading “social and health impacts”, it is crucial that the impact assessment and initiative explicitly assess the health impacts and benefits to health care systems as a whole. Those benefits are larger than considering only air pollution effects and include i.e. reduced healthcare costs from an overall strengthened health of the population (e.g. through greater physical activity in a decarbonized mobility system). In particular, impacts for vulnerable subgroups of the population should be assessed. The EU Commission should also require member states to assess such health co-benefits, which will help us advance towards a more comprehensive costs and benefits picture. For such an assessment, the Commission should consider the integration of the WHO Carbon Reduction Benefits on Health calculation tool (CaRBonH) available here: http://www.euro.who.int/en/health-topics/environment-and-health/Climate-change/publications/2018/achieving-health-benefits-from-carbon-reductions-manual-for-carbonh-calculation-tool-2018 With the Covid-19 pandemic the need to better protect people’s health and strengthen health resilience in the short and long term has become prominently understood around the globe. The current planetary health emergency reminds us that our essential systems need to be resilient and healthy in order to carry the burden of natural disasters and crisis ahead of us. It would be naive to expect such crisis would not appear again. Thus, EU’s 2030 climate goals need to take into account those essential pillars of EU society such as health and well-being of the whole population - including the most vulnerable ones among us - resilient heath care, resilient local support systems as important modus within a diverse and interconnected EU society.
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Meeting with Thierry Breton (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

15 Apr 2020 · Priorities for the Coronavirus recovery

Response to Adapting data requirements in the Annexes to the BPR to the ED criteria

11 Mar 2020

The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the proposed update of the EDC information requirements in the biocides products regulation (BPR). Our detailed comments can be found in the attached.
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Response to Europe’s Beating Cancer Plan

3 Mar 2020

A toxic-free environment as long-term cancer preventing environment : some chemicals in the work & home environment are known to be carcinogenic; others disrupt the human hormone system & are associated with hormonal cancers, such as breast or prostate cancer. EU environmental action & implementation by member states is a major component of primary cancer prevention – it can contribute to reducing the 40% of preventable cancers & meeting the WHO targets on non-communicable diseases to reduce cancer deaths by 25%. HEAL welcomes that the Roadmap puts a strong emphasis on how many EU environmental policies can help prevent the preventable cancer cases through an ambitious Farm to Fork Policy as well as the Zero Pollution Strategy. It also foresees using legislative measures with targets to reduce exposure to carcinogens. Urgent regulatory action to decrease presence of substances linked to many types of cancer: scientific evidence calling for EU legislative action has been accumulating over the past decades. In 2010 the European Parliament & Council urged “reducing exposure to environment contaminants” as part of the EU Commission’s cancer prevention strategy. The time for bold action to reduce exposure is now. For instance, removing glyphosate from the market following its 2015 IARC classification as probable carcinogen to humans, banning PFAS for non-essential uses, a forever chemical, as exposure is associated to a number of serious health impacts including kidney & testicular cancer. Green Deal cancer prevention, eliminating sources of cancer causing pollution: to prevent the preventable means to cut pollution at source. Humans can be exposed to carcinogens through what they eat, drink, breathe & touch: hazard-based legislation is thus the most effective tool to protect the population from exposure to cancer causing substances throughout their lives, including exposure in utero, which can increase risks later in life of serious diseases, including cancer. 1 Fight cancer with the most vulnerable in mind Protect the most vulnerable: focus action on the vulnerable groups to ensure protection of the broader population, by applying prevention & precaution where & when vulnerability is being expressed. Nobody should be exposed to CMRs at work, in school, in hospitals, in utero. Make occupational cancer data visible: ensure that employers comply with the established exposure limit values, recognise occupational carcinogens & support education of health professionals to collect gender disaggregated data on workplace exposure for existing cancer registries. 2 Prevent from farm to fork Ensure the Farm to Fork Strategy strives to end intake of pesticide residues linked to cancer. HEAL supports the ECI to save bees & farmers’ health which calls for a phase-out synthetic pesticides by 80% by 2030. Revise outdated EU food contact materials legislation to ensure carcinogens and EDCs associated with increased cancer risk, & other negative health impacts, are eliminated. 3 Prevent through zero-pollution in every part of the environment EDCs: close the current endocrine disruptors gap in the sectorial legislation & apply cross-sectorial coherence. EDCs should not be allowed in toys, cosmetics & food contact materials, nor in any other consumer product. Toxic chemicals: ensure Europe’s Beating Cancer plan is closely linked to a comprehensive EU Chemicals Strategy for Sustainability & other chemical policy frameworks to rationalise & simplify EU’s chemicals & pesticides regulations for substances causing cancer; swiftly prepare the non-toxic environment strategy, & act to detoxify the circular economy. Air pollution: lower the tolerance to concentration of pollutants in both outdoor and indoor air, as there is no safe level of air pollution. The EU should speed up alignment of EU legal air pollution limits on the WHO guidelines to enter into force by the end of this mandate 4 Raise awareness on ways to limit exposure more www.env-health.org
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HEAL calls for rolling updates to banned pesticide additives

13 Feb 2020
Topic — The European Commission is updating the list of unacceptable co-formulants in pesticides.
Message — HEAL requests that the banned substances list be updated continuously rather than through a one-off exercise. They argue industry must provide thorough safety data or face automatic bans for additives. Finally, the group wants the tolerance level reduced to the detection limit.123
Why — This ensures the precautionary principle is applied, favoring public health over industrial interests.4
Impact — Pesticide manufacturers lose the ability to use cheaper, unassessed additives without thorough safety data.5
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Response to Fitness Check on endocrine disruptors

9 Jul 2019

EDC-Free Europe, a coalition of public interest groups representing more than 70 environmental, health, women's and consumer groups across Europe who share a concern about hormone disrupting chemicals (EDCs) and their impact on our health and wildlife, welcomes the opportunity to comment on this Roadmap. Our contribution can be found in the PDF attached.
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

7 Sept 2018 · EDC Strategy

Response to Towards a more comprehensive EU framework on endocrine disruptors

17 Jul 2018

The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the European Commission’s proposed roadmap “Towards a more comprehensive framework on endocrine disruptors” . In HEAL’s view, a comprehensive European approach to address the health and societal challenges of endocrine disrupting chemicals (EDCs) that reduces exposure is long overdue and an absolute necessity. You can find our full response in the attached document.
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

An ambitious EU Product Policy Framework contributing to the Circular Economy should take place in the context of an articulated European Strategy for a non-toxic environment, which is one of the deliverables the European Commission is committed to under the 7th Environment Action Programme. In HEAL's new, regulations for new products need to be strengthened, in particular through better implementation of REACH. Speeding up the identification and regulation of substances of very high concern (SVHCs) should be a priority. All the hazardous substances should be restricted or banned from products, leading to the redesign of products without toxics. Products already on the EU market should be screened for toxics, so that they can safely be treated and the recycling of hazardous toxics is prevented. Finally, there is an urgent need to honor Europe’s commitment to release a Union Strategy towards a non-toxic environment by 2018. In HEAL’s views, priorities should include: o A clear commitment to address chemicals of concern due to their impacts on vulnerable populations such as infants, small children or pregnant women; o Clear guidance on how to assess and avoid cumulative exposure to chemicals; o Clear guidance to shift from a current chemical-by-chemical evaluation approach towards an approach that looks into groups of chemicals; o Clear guidance to promote safe substitution; o Clear guidance to make sure that chemicals regulated under REACH are regulated consistently under other regulations. Eliminating materials that harm our health in daily environments would offer great benefits for public health by preventing many chronic diseases and be a big step forward towards a nontoxic circular economy in Europe.
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

26 Apr 2018 · discussion on EU chemicals policy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

26 Apr 2018 · Circular Economy agenda and the chemicals/environmental/health policy

Meeting with Vytenis Andriukaitis (Commissioner) and

20 Apr 2018 · General Food Law

Response to Evaluation of Food Contact Materials (FCM)

19 Dec 2017

Please find here enclosed a short paper outlining the comments of the Health and Environment Alliance in response to the European Commission's consultation on the proposed roadmap for the evaluation of the food contact materials regulation.
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Meeting with Xavier Prats Monné (Director-General Health and Food Safety) and ClientEarth AISBL and Chemicals, Health and Environment Monitoring Trust

11 Oct 2017 · Discussion on Food Contact Materials

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

1 Feb 2017 · A Union of Democratic Change; Energy Union; Jobs, Growth and Investment; A stronger Global Actor

Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

28 Nov 2016

Health and Environment Alliance (HEAL) is the leading European not-for-profit organisation addressing how the environment affects health in the EU. With the support of more than 75 member organisations in 28 European countries, HEAL brings independent expertise and evidence from the health community to decision-making. Our broad alliance represents health professionals, not-for-profit health insurers, doctors, nurses, cancer and asthma groups, citizens, women’s groups, youth groups, environmental NGOs, scientists and public health institutes. Air pollution has many severe effects on human health and the environment. Nine out of 10 people globally live in places with poor air quality. A recent report from the World Health Organisation blames a worldwide air pollution crisis for being a major factor in millions of deaths per year. Children and the elderly are especially vulnerable. In Europe, according to WHO estimates, nearly 500,000 premature deaths are linked to exposure to air pollution. HEAL welcomes the Commission’s proposal on the 3rd RDE package as a timely step in the right direction to solve this issue, by tackling particulate emissions from Gasoline Direct Injection cars and strengthening the RDE test procedure. However, we are particularly concerned by two issues: Firstly, the extension of RDE to measure PN emissions must be implemented without delay under the proposed timetable, i.e. 2017 for new types and 2018 for all new vehicles. Any slippage of either of these dates is unacceptable and would lead to delaying urgent investment needed to ensure the growing fleet of direct gasoline injection petrol cars meets the Euro 6 limit on the road. Secondly, both the actual RDE test results and the maximum declared values for manufacturers must be made available in the public database in line with the Commission proposal. Any weakening of these important access to data provisions will seriously undermine RDE 3 and public information. There are orders of magnitude difference in emissions for vehicles fitted with gasoline particle filters and not, and drivers should be provided with this information. HEAL considers the current draft text to be the minimum acceptable to be effective. If there is any further weakening during discussions in TCMV on the 20th December, HEAL and many other stakeholders, including possibly the European Parliament, will have legitimate concerns as to the suitability of the new regulation and whether we should seek to have it rejected. There are several areas of potential improvements that should be made to the text, ideally now, or certainly before the 2nd step of RDE is introduced in 2020. These are: Addressing ultra-fine particles, something the Commission recognises in recital 14. Further work is needed to extend measurement to these most dangerous to health emissions in order to include them by 2020 at the latest. The approach used to account for higher cold-start emissions (point 27 in annex 2) should be replaced with a more accurate weighting process of their fair share in an average urban trip. Furthermore the possibility to use an up to 30s idling period between the engine start and the first movement of the vehicle (point 25 in annex 2) is a loophole to severely underestimate cold-start emissions of gasoline engines, and should be closed. As regards regeneration events, HEAL asks the TCMV to remove the possibility to use Engine Control Unit (ECU) data for detection of such events to ensure RDE results cannot be manipulated by carmakers (point 19 of annex 2). The exhaust temperature should be used instead. We welcome recital 17 that allows updates of Ki factors to be closer to real-world situations, but the Commission should establish a public database with more realistic values from independent tests. The conformity factors should be reviewed annually. The above changes will ensure that on-road emissions tests are robust and accurately represent real vehicles’ performance.
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Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

8 Jun 2016 · Commission proposal on scientific criteria to identify endocrine disrupting chemicals (EDCs)

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and Chemicals, Health and Environment Monitoring Trust

25 Feb 2016 · Criteria of endocrine disruptors

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Environment Council Preparation

Meeting with Miguel Arias Cañete (Commissioner) and

30 Apr 2015 · International climate talks ans EU climate diplomacy. State of play of legislative files

Meeting with Frans Timmermans (First Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

13 Feb 2015 · Meeting with Representatives of Green 10 on CWP 2015

Meeting with Miguel Arias Cañete (Commissioner) and

15 Jan 2015 · Follow-up to Lima and climate action diplomacy up to Paris / Energy Union (state of play)

Meeting with Giulia Del Brenna (Cabinet of Commissioner Carlos Moedas) and Greenpeace European Unit and Corporate Europe Observatory

15 Jan 2015 · Meeting on principles of scientific advice

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

18 Dec 2014 · Energy Union