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International Pollutants Elimination Network

IPEN

IPEN's mission is a toxics-free future for all.

Lobbying Activity

Response to Ensuring that hazardous chemicals banned in the European Union are not produced for export

27 Jul 2023

IPEN is a network of over 600 public interest organizations in over 125 countries, mostly in low- and middle-income countries with a vision of a toxics free future for all. IPENs vision aligns with the goal set by the European Green Deal for a toxic-free environment. There is wide evidence about toxic substances contaminating people´s health globally. IPEN works to strengthen global and national chemicals and waste policies, to conduct research providing data relevant for national, regional and international policies, and to build a global movement for a toxics-free future. As recognized by the United Nations General Assembly Resolution A/76/L.75 on the human right to a clean, healthy and sustainable resolution the unsound management of chemicals and waste, has negative implications, both direct and indirect, for the effective enjoyment of all human rights and these consequences are felt most acutely by women and girls and those segments of the population that are already in vulnerable situations. Most users in developing countries to which the EU exports banned, and severely restricted chemicals do not have basic national chemicals management systems and are ill equipped to manage the use of chemicals that have already been deemed to cause an unacceptable risk in the EU. Countries in low- and middle-income countries are net importers of chemicals. These countries import chemicals without due consideration of their health and environmental effects. Stopping their export would thus benefit the environment, biodiversity and protect the lives of populations at risk. Stopping these exports would also lead to lower availability of these hazardous chemicals and create bigger incentives to shift to safer alternatives. In the agricultural sector, there is evidence that replacing hazardous pesticides with cost-effective alternatives offers health, environmental, and biodiversity benefits without affecting crop yields. While the chemical industry uses unsubstantiated claims that reducing access to highly hazardous pesticides would threat food security, farmers that are ill equipped to manage the hazardous properties of these chemicals are continuously exposed to them. About 385 million cases of acute pesticide poisonings occur each year, mainly in low- and middle-income countries, where a large proportion of the population continues to be involved in agriculture or lives in areas where pesticides are used. In 2018 alone, more than 81,000 tonnes of pesticides containing 41 different hazardous chemicals banned on EU fields, have been exported from European factories for use in agriculture in other countries. Allowing double standards in levels of protection between EU and non-EU citizens is both unethical but also contrary to human right principles. IPEN generates data about the presence and impacts of hazardous chemicals in products, including recycled plastic materials in Africa, Asia and Latin America and has documents the widespread uncontrolled presence of hazardous chemicals in products and materials exported to these countries. Especially once chemicals and products containing hazardous chemicals become waste, they are often mismanaged and create uncontrolled toxic exposures. These countries are lacking resources and infrastructure to properly manage risks from using toxic chemicals and pesticides. Together with an export ban, the EU should implement its commitment in the Chemical Strategy to promote due diligence for the production and use of chemicals within the upcoming initiative on sustainable corporate governance and clarify that companies headquartered in the EU should be restrained from producing or selling dangerous chemicals that are banned in the EU anywhere in the world. IPEN also calls the EU to support global processes to ensure global controls of the manufacturing, use and trade of hazardous chemicals, such as the SAICM Beyond 2020 process and the legally binding plastics treaty being currently negotiated.
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Response to Introducing new hazard classes–CLP revision

13 Oct 2022

Arnika - Toxics and Waste Programme welcomes the draft proposal for new hazard classes in the annexes of the CLP regulation. Arnika published numerous studies about the pollution of water, soils and especially products and wastes including those intended for recycling or further use with persistent, bio-accumulating and toxic substances as well as very persistent and very bio-accumulative chemicals and endocrine disrupters. We have shown the global contamination of these chemicals in products coming back to our markets from countries where the legislation is not as stringent as in the EU. This proposal is in line with the toxic-free vision of the Chemicals Strategy for Sustainability (CSS) and its intention to shift the focus from the use of toxic chemicals towards the use of substances that are safe and sustainable by design. This is a long awaited step forward to allow for prevention and minimisation of exposure to EDCs, PBT, vPvB substances which are for the moment present everywhere in people's daily life and the environment from serious risk to human health as well as contamination of EU citizens and the adverse effects of these mixtures of chemicals on human health such as, among others, cancers, developmental disorders of children, reduced fertility, diabetes and obesity. The widespread and irreversible environmental pollution will lead to long-lasting exposure of wildlife and humans including future generations through the consumption of contaminated drinking water. Persistent and mobile chemicals should also be regulated through the generic approach to risk management under REACH to ensure clean drinking water for future generations. The inclusion of the new hazard classes in CLP should prompt changes in the REACH regulation and trigger the restriction of endocrine disruptors and persistent chemicals for consumer uses as this is already happening for carcinogens, mutagens, and reprotoxicants already classified under the CLP. The EC proposal for a classification of endocrine disruptors according to two categories [(1) Known or presumed endocrine disruptors // (2)Suspected endocrine disruptors] is in line with the existing categories for carcinogenic, mutagenic and reproductive substances (CMR) in EU and WHO definitions. Arnika notes that the proposal doesn’t provide for a symbol/pictogram to easily notice the risk of endocrine disruption in a substance or mixture. This should still be added, as this is the case for carcinogens, mutagens and reprotoxic substances. The proposed hazard statement should be amended to reflect that EDCs may also cause harm to the future generations. Arnika studies showing the global contamination with PBTs and EDCs: https://arnika.org/en/publications/download/1359_6642beee5ca9f251192b6c3fb969f8d6 https://arnika.org/en/publications/download/1347_9d56c311b924a247b09e4796f4526f45 https://arnika.org/en/publications/download/1390_9ab53df34ba28efcd50002e1cc586f53
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Chemicals, Health and Environment Monitoring Trust and Health & Environment Alliance

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 Health & Environment Alliance

8 Dec 2021 · EU Chemicals Strategy for Sustainability and PFAS

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and Chemicals, Health and Environment Monitoring Trust and Health & Environment Alliance

8 Dec 2021 · To discuss the EU Chemicals Strategy for Sustainability and PFAS

Response to Commission Regulation amending Annex XIV to REACH

5 Jan 2021

Arnika Association welcomes the initiative of the European Commission and ECHA to update the entries for the phthalates DEHP, DBP, BBP and DIBP (plasticisers) due to their endocrine disrupting properties. Phthalates and specifically DEHP in medical devices have been regarded as highly problematic substances for over 20 years. Progressive hospitals including those in the Czech Republic have demonstrated their ability to substitute PVC as well as phthalates-containing PVC medical devices with safer alternatives. Majority of EU medical devices manufacturers offer viable and cost-competitive alternatives. The proposal to update the entries in Annex XIV to the REACH Regulation for DEHP specifically will accelerate the move towards substitution of this harmful chemical. A recent comprehensive and critical review addressed the health hazards posed by phthalates on children and adolescents, including reproductive toxicity in women and men, cancer, insulin resistance and type II diabetes, overweight and obesity, allergy and asthma. Growing evidence suggests that prenatal phthalate exposures may have neurodevelopmental consequences and can affect IQ, attention, hyperactivity, and social communication of children. Aggregate exposure to phthalates is also of concern. Excluded from estimates of average adult exposure has been exposure to other phthalates with similar reproductive and developmental effects as DEHP: including di-(n-butyl) phthalate (DBP), butyl benzyl phthalate (BBP), and di-isononyl phthalate (DINP). When analysed as a class of chemicals with similar adverse health effects, the aggregate levels of phthalates for the highest exposed (95th percentile) women of reproductive age are considerably higher than for individual compounds. A growing number of studies suggest the link between exposure of patients to phthalates from medical devices and adverse effects in exposed patients. There is emerging evidence that the use of medical devices containing DEHP is potentially harmful for the brain development and function of critically ill children. Belgian clinicians identified a clear link between previously hospitalized children’s long-term neurocognitive test results and their individual exposure to the phthalate DEHP during their stay in intensive care. Critically ill children had very high circulating levels of phthalate metabolites, explained by leaching from medical devices, and these levels were associated with the significant attention-deficit observed four years later. Last but not least, the use of phthalates containing PVC medical devices creates a substantial problem once it becomes waste. The incineration of PVC medical devices contributes to the creation of dioxins and other persistent organic pollutants accumulating in incineration residues including highly toxic ash. These have a detrimental impact on human health and the environment.
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Response to Update of concentration limit values of persistent organic pollutants in waste

7 Aug 2020

The International Pollutants Elimination Network (IPEN), a global network of 600 Participating Organizations in over 120 countries, has followed the Stockholm Convention (SC) development since its beginning and considers “Hazardous waste - updated concentration limits for chemical pollutants“ an important step. Re-evaluation of the limits for selected POPs under this initiative can contribute to the protection of human health and the environment if set in their favour and if their setting will not be based more on the economic interests of industrial groups. Some of the limits for POPs in waste as they are today lead to contamination of the recycling chain and their occurrence in recycled products undermines public support for the recycling process. POPs poison the circular economy. Studies have shown the presence of high concentrations of PBDEs in toys or kitchen utensils made from recycled plastics. The same phenomenon occurs by recycling ash from incinerators containing high concentrations of dioxins. Civil society organizations promote recycling as good option for certain wastes management, however “toxic recycling” should not be the way forward as it only supports further spread of toxic chemicals into the environment and can lead to significant costs for cleaning up sites contaminated with POPs. The costs for remediation of contaminated sites were not yet considered when establishing certain levels for the definition of hazardous POPs wastes. Some industries might argue that stricter limits will be more costly for them, but this is simply a cost externalization onto the European taxpayers that undermines the SC obligations and is inconsistent with sound economic principles and the goal of a clean circular economy. For example, the 10,000 mg/kg proposed limit for SCCPs does not protect EU residents and was advocated with the full knowledge that it will lead to contaminated consumer products. The same happens when the trace contamination limit for the sum of PBDEs is set at 500 ppm. PBDEs technical mixtures are accompanied by PBDD/Fs (brominated dioxins) as by-products during their whole life cycle, including recycled plastics sourced from electronic waste. To show this movement of toxic by-products into recycled plastic a recent study established that high levels of brominated dioxins measured in toys made from recycled plastic exhibited toxic effects on human cells. Current legislation limits for both PBDEs and PBDD/Fs are insufficient to protect children’s health. By setting insufficient limits for the definition of POPs waste the EU contributes to the creation of places such as Agbogbloshie in Ghana, seriously contaminated by POPs due to burning imported e-waste plastics. Such places are the result of weak regulation of toxic waste’s transboundary movements. It is also a question of how the POPs waste is defined (by which values), as that also regulates the international trade with it. Following the above-mentioned concerns, regarding the impact of POPs waste on human health and the environment in particular, IPEN strongly supports lower, more protective POPs content limits: • 100 ppm for HBCD • 50 ppm for the sum of PBDEs (incl. Deca-BDE) • 100 ppm for SCCPs • 10 ppm for the sum of PFOA/PFHxS and related substances, and • 1 ppb (WHO-TEQ) for PCDD/Fs + dl-PCBs with an additional limit of 50 pg WHO-TEQ/g of these substances for untreated waste used on land surfaces. To make POPs waste management more sustainable and closer to the ultimate goal of POPs elimination, we deem it necessary to change the legislative conditions to be more open to other technologies for destruction of POPs waste (e.g. GPCR, BCD or SCWO), that do not create new POPs as waste incineration or co-incineration does, in order to meet the obligations set in Article 5 of the Stockholm Convention. We find these conditions crucial for meeting the SC objectives “to protect human health and the environment from persistent organic pollutants“.
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Response to Chemicals strategy for sustainability

19 Jun 2020

Arnika and IPEN is concerned that the current legal framework on chemicals and waste is not sufficiently adapted to the challenges of a clean circular economy. Information gaps along supply chains, the presence of legacy chemicals and diverging standards place huge strains not only on recycling but create even more challenges for protecting people and the environment from exposure to hazardous substances for future generations. RECYCLING WITHOUT TOXIC CHEMICALS Our primary concern is the persistent organic pollutants (POPs) and their continuous presence in material cycles. Recycling is the preferred option for management of waste but it cannot lead to recycling of substantial volumes of toxic chemicals without any further control mechanism – limits for recycled products must be set at the same level as virgin products. Limits for toxic chemicals content set as definition of hazardous waste must be based on prevention of food chain contamination and/or health protection and not on economic interest of industry or waste management capacities. TOXICS-FREE FUTURE NOT ONLY FOR EUROPE BUT GLOBALLY There is a growing concern among European as well as non-EU NGOs that the EU chemicals policy does not prevent the hazardous chemicals contamination outside of the EU. A number of practices especially relating to waste exports largely contribute to the spread of toxics worldwide. One of the major routes of toxic chemicals contamination is the export of plastics waste, e-waste and automotive waste that is partially legal, partially illegal. Products such as electronics at its end of life cannot be exported to countries with no or poor capacities for their safe further management and EU should promote more strict definitions of “waste” and “non-waste”. Export of waste containing hazardous chemicals must be prohibited through EU regulations as well as international standards and the EU should promote very strict regulations to stop EU waste export that is often labelled incorrectly as “used products” or “materials intended for recycling”. EU CHEMICALS AND WASTE EXPORTS: DOUBLE STANDARDS  The EU legislation should guarantee that the same standards and regulations in the EU are implemented and followed when chemicals and products are exported to other countries, especially of low- and middle-income countries (LMICs). Waste should not be exported to LMICs, especially in the name of aid. SUPPORTING TECHNOLOGIES TO DECONTAMINATE HAZARDOUS WASTE Technologies and policies preventing POPs waste creation should be prioritized; e.g. prioritize prevention and zero waste strategies before waste incineration and economic incentives for non-toxic material over those, such as PVC, leading to creation of dioxins and other harmful chemicals. EU should promote investment and implementation of technologies for POPs waste destruction with higher destruction efficiencies than waste incineration or co-incineration in cement kilns, for example Gas Phase Chemical Reduction (GPCR), Alkali Reduction, BCD or Supercritical Water Oxidation (SCWO) as their use seems to prevent creation of unintentionally produced POPs during waste management and therefore preferable. Chemical Recycling of polymers (plastics), and/or depolymerization or pyrolysis should not be viewed as a solution to the plastic crisis e.g. since it creates toxic waste streams, has a very large carbon footprint and seems to be very problematic with regards to its products and performance overall. PLASTIC: CHEMICALS ADDITIVES Every stage of the life-cycle of plastic involves hazardous chemicals. Therefore, non-essential uses of plastics must be phased out and the remaining plastic produced in a way that does not cause harm. The EU should lead the way by both banning non-essential uses of plastics as well as use of hazardous chemicals in plastic. A tax on plastics containing toxic chemicals shall be considered in order to achieve ambitious recycling goals set in the Circular Economy Action
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