Women Engage for a Common Future

WECF

Women Engage for a Common Future is an ecofeminist network promoting a healthy environment.

Lobbying Activity

WECF demands rejection of carbon credits and industrial agriculture

15 Sept 2025
Message — WECF urges the EU to reject carbon credits and technological solutions like BECCS or DACCS. They call for a transition from industrial agriculture to locally-owned agroecology with specific targets. International offsets should not be used to reach the 2040 climate goals.123
Why — The network would secure a transition to a sustainable and gender-just future.4
Impact — Large multinational corporations would lose their dominance over the agricultural sector.5

Response to European Democracy Shield

26 May 2025

In the creation and implementation of the Democracy Shield, we encourage the Commission to: ensure that innovative and inclusive participatory and deliberative democratic formats are promoted as a central element of the defence of democracy; ensure that a European Democracy Shield does not inadvertently weaken the protection of civil society and innovative democratic structures; remain vigilant to the risks which ill-formulated foreign agents' laws can pose to democracy and civic space, and act against all efforts to shrink civic space or freedom of speech, association and assembly in the Union including any attempt to limit funding for CSOs or any other additional measures seeking to limiting the operating space of CSOs; aim for a EU Strategy to support, protect, and empower civil society, which ensures holistic protection against direct attacks (such as SLAPPs), reduces administrative burdens, and provides structural support to address power imbalances (encouraging Member States to provide structural support), including: o Structured civil dialogue, in line with the recommendations in EU Civil Dialogue: The Foundations of an Institutional Framework; o Protection mechanism for human and environmental rights defenders as well as CSOs, according to the mapping and pathways papers of Civil Society Europe; o Operational support to enable CSOs to be structured and effectively engaged in EU policy development and implementation. The preservation of LIFE operating grants and the CERV fund, for example, is paramount to enable civil society participation and guarantee their transparency and accountability. Engage in any revision or adoption of EU legislation to ensure full respect for the legal requirements set out under the Aarhus Convention and best practices in the field, and in line with fundamental rights
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Meeting with Hildegard Bentele (Member of the European Parliament) and Bund für Umwelt und Naturschutz Deutschland e. V. and Health and Environment Justice Support

25 Sept 2024 · Plastic Policy

Meeting with Jutta Paulus (Member of the European Parliament) and European Environmental Bureau and

23 Jan 2024 · REACH

WECF urges EU to ban export of toxic chemicals

31 Jul 2023
Message — WECF urges authorities to stop exporting toxic chemicals to developing countries. They demand corporate due diligence to prevent companies from producing banned substances globally.12
Why — This policy would help protect women and vulnerable groups from hazardous chemical exposure.3
Impact — The chemical industry loses export revenue while its claims about food security are dismissed.4

WECF calls for stricter toxic chemical rules in packaging

24 Apr 2023
Message — The group demands stricter regulations on harmful chemicals to protect health and the environment. They seek gender-sensitive risk assessments and the total avoidance of hazardous substances in packaging materials.123
Why — This would help the organization achieve its core goal of ensuring a toxic-free future.45
Impact — Chemical and packaging companies would face much tougher restrictions on their production processes.6

WECF Demands Gender Perspective in Revised EU Chemical Rules

30 Mar 2023
Message — WECF calls for stronger regulations to better protect vulnerable groups from harmful chemicals. They propose specific pictograms to warn pregnant women about endocrine disruptors in products. They suggest integrating gender considerations into hazard classes to reflect biological differences.123
Why — This ensures policy protection reflects the unique biological vulnerabilities of women and children.4
Impact — Chemical manufacturers face higher costs from stricter labels and potential non-compliance sanctions.5

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

Women engage for a Common future (WECF) welcomes this consultation on the evaluation of the principle of the polluter pays principles in the EU. WECF has been working on chemicals & health related issues since its beginning in 1994 and advocates for non-chemical alternatives worldwide, based on three principles which includes polluter pays, reversal of the burden of proof and the precautionary principle. The polluter-pays principle is key in enforcing environmental measures and ensuring social justice. Part of the EU environmental principles of article 191§2 TFEU, its implementation is insufficient to ensure a healthy environment for all. Hence WECF demands, see www.wecf.org/our-submission-for-the-new-european-chemicals-strategy-for-sustainability/ The report of the European Court of auditors, the reports of the European Environmental Agency or projects like the European Human Biomonitoring Program (HBM4EU) show that soils, water, people are polluted everywhere across Europe. Even though the EU has a strong environmental legal framework, the compliance mechanism is deficient. This has an adverse effect on peoples health and environment but also on the weight of their mental health. By not applying the principle, strong injustices are being perpetuated and a transition towards a healthier, more just and more sustainable environment for all is not possible.The polluter pays principle is not integrated in EU external relations. This means that EU legal entities pollute for free outside its borders by exporting toxic chemicals and waste, encouraging deforestation etc Pollution does not border and often this double standard politics will end up harming the environment and the health of the citizens in the EU. We suggest that measures are taken to integrate this principle in EU external policies such as EU trade policies, development and cooperation policies or neighborhood policies. This could be implemented by writing in those legal texts that the EU respects the polluter pays principles but also by assuring that the financial incentives are sufficient for operators to respect this principle. The polluter-pays principle is also an important element to ensure social justice. It is often the more powerful and richer entities that pollute and often the more vulnerable groups (children, pregnant women, lower socio-economic classes, minorities) are the most heavily impacted by these pollutions. By not applying the polluters pays principle on a local, national or Europe scale, harm is caused to the EU populations and its environments. A solution to better apply the polluter-pays principle would be to facilitate access to justice on a local/national scale but also European scale, to enable people to claim damages that have been made. One solution is reducing the burden of proof on the environmental damage and also adding to the list of environmental regulations that are being breached (eg chemical regulations such as REACH/CLP). Another aspect is that sanctions are often not dissuasive enough. The polluters will at times prefer to pay the fine in silence because it would be cheaper than to repair the polluted area or take measures forehand to avoid the pollution. When it comes to access to justice, Civil society organizations also have difficulty to bring cases on national and the European level in front of the judge to ask for application of the polluter pays principle. This is problematic especially regarding the Aarhus convention under which the EU and its Member States have committed to grant access to justice in environmental matters. The polluter pays principle should also be better applied by administrations on a local level. Reports have shown that very often local administration will not pursue administrative procedures against local industries that pollute. More trainings can be made towards the local enforcers on explaining how to apply the polluter pays principle and show them what are good/ bad practices.
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Meeting with Jutta Urpilainen (Commissioner) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and

1 Dec 2022 · Speech at the 2nd GAP III Structured Dialogue with CSOs

Meeting with Frans Timmermans (Executive Vice-President) and Climate Action Network Europe and

15 Nov 2022 · Progress of COP27 negotiations

WECF demands faster bans on endocrine disrupting hazardous chemicals

17 Oct 2022
Message — WECF calls for reducing the implementation timeline from 42 to 18 months. They want gender-differentiated data included and hazardous chemicals banned from consumer products. Furthermore, they demand easily understandable danger pictograms on all products containing these substances.12
Why — This accelerates their mission to protect women and workers from toxic exposure.3
Impact — Chemical manufacturers would face much shorter deadlines to comply with new labeling rules.4

Meeting with Jutta Paulus (Member of the European Parliament)

22 Sept 2022 · More women in renewables and energy communities: safeguarding an enabling policy framework

WECF demands binding pesticide targets and toxic substance bans

19 Sept 2022
Message — WECF demands Commission-led pesticide targets and bans on individual sales. They also urge accelerating the substitution of the most toxic substances.123
Why — This proposal would help the organization promote healthier agri-food systems and environments.4
Impact — Private individuals lose the ability to purchase pesticides for non-professional home use.5

Response to Safety requirements to be met by European standards for certain children products (excluding toys)

2 Sept 2022

Women engage for a Common future (WECF) accueille la proposition de décision de la Commission pour règlementer les articles destinés aux enfants. En tant qu’organisation écoféministe travaillant dans le domaine de la santé et l’environnement, WECF est engagée à travers son projet Nesting dans la création d’un environnement sain pour les enfants. Les enfants sont une population particulièrement vulnérable : leurs systèmes immunitaires, hormonaux, cérébraux en cours de développement sont fragiles lorsqu’il s’agit des expositions à des substances ou des matériaux dangereux. Leur environnement doit être sain possible pour santé. Aujourd'hui, la législation, même basée sur le marché intérieur, ne peut être sourde à ces questions d'environnement-santé et au principe de précaution qui est un outil juridique effectif de protection. WECF estime que la proposition de la Commission ne reflète pas suffisamment ce besoin de protéger les générations futures. Tout d’abord l’approche par les classes de toxicité ne font pas de référence au principe de précaution, essentiel pour garantir un environnement sain aux enfants (et à tout le monde plus largement). Le Comité des Droits de l’Homme des Nations Unies en déclarant que le droit à un environnement sain est un droit humain, a lié ce principe à l’intérêt supérieur de l’enfant. Le principe de précaution est indispensable pour que les textiles, les produits en contact alimentaire ou en contact avec l’épiderme ou les muqueuses soient exempts de substances dangereuses et potentiellement dangereuses. L’annexe de la Commission ne renvoie pas aux catégories Cancérigènes Mutagènes Reprotoxiques (CMR), aux perturbateurs endocriniens ou aux Persistants bioaccumulables et toxiques (PBT). La rubrique concernant les retardateurs de flammes devrait elle aussi être plus explicite concernant les dangers liés à l’utilisation de retardateurs de flamme chimiques sur les produits pour enfants. Le projet HBM4EU a mis en avant le manque de connaissances des effets néfastes des produits retardateurs de flamme, omniprésents dans nos environnements (certains seraient perturbateurs endocriniens). Enfin, dans la rubrique concernant la dangerosité liée à l’hygiène, le paragraphe ne met pas suffisamment l’accent sur la dangerosité de l’utilisation des biocides sur les articles destinés aux enfants. Ce mésusage des biocides favorise la résistance antimicrobienne surtout chez les plus petits dont le système immunitaire n’est pas encore mature. Le contenu de ce paragraphe devrait, selon nous, contenir des dispositions explicites pour que l’utilisation de biocides soit l’exception en matière d’articles pour enfants et non la règle. Les normes élaborées par les organismes de normalisation ont une valeur juridique indéniable dans l’UE, à l’échelle nationale et dans le monde. Leur respect vaut accès aux marchés pour les entreprises et sont gages d’une certaine qualité. Or, cette qualité ne peut se définir sans le respect d’un haut niveau de protection de la santé et l’environnement. Il faut donc que les annexes soit le plus exigeantes possible quand il s’agit de la santé de nos enfants. Nous demandons qu’il soit explicitement demandé que les substances interdites dans les jouets pour enfants le soient aussi dans les articles destinés aux enfants et de manière rapide. Nous demandons que la Commission fasse plus de références à sa stratégie pour la durabilité des produits chimiques et aux ambitions du Pacte Vert pour l’Europe, ainsi qu’à la Stratégie de l’UE pour les droits de l’Enfant. Ce sont des politiques clefs pour garantir à nos générations futures un environnement sain. Le texte actuel n'y fait référence que très brièvement et sans en tenir compte concrètement.
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Ecofeminists urge open chemical data to speed up safety bans

11 Aug 2022
Message — WECF supports making existing chemical data easily accessible to accelerate evaluation processes and ban harmful substances. They advocate for including gender-differentiated data and using diverse sources, including academic research.123
Why — The proposal enables civil society to scrutinize decisions without facing lengthy administrative procedures.4
Impact — Industry actors face faster product bans and continued pressure to provide detailed data.56

Meeting with Alice Kuhnke (Member of the European Parliament, Shadow rapporteur) and The European Region of the International Lesbian, Gay, Bisexual, Trans and Intersex Association and

20 Jun 2022 · Anti-discrimination and Intersectionality

WECF urges gender equality inclusion in forest monitoring framework

4 May 2022
Message — WECF requests a focus on gender equality that accounts for the specific needs of marginalized women. They demand accessible information for local communities and a ban on corporate carbon offsetting schemes.12
Why — This inclusion would empower marginalized women to influence forest policy and protect their livelihoods.3
Impact — Extractive industries would face higher hurdles to project approvals and greenwashing attempts.4

Response to Revision of the Toy Safety Directive

2 Nov 2021

Protecting children from unsafe toys and strengthening the Single Market – revision of the Toy Safety Directive Women Engage for a Common Future, WECF, welcomes the European Commission’s plan to revise the EU Toy Safety Directive (TSD), in relation to widening the scope of toxic chemicals to be banned for children's toys and products intended for children use. As an international ecofeminist network of 150 women and civil organizations NGOs committed to build a healthy environment and be active at EU level for moving towards a toxic-free future, Women Engage for a Common Future (WECF) calls the EU authorities to stronger regulations in context of harmful chemicals, especially for children. All products used by children should be subject to the precautionary principle. Toys are not justified of having any essential use, that would allow for the use of harmful chemicals or other threats to children`s safety or health. The protection of children and the realization of the rights of the child and the right to live in a clean and healthy environmental should be of the most important goals for the EU, as it has been laid down in the EU Strategy on the Rights of the Child. As an organisation focusing on gender, women and children's aspects of chemicals safety, protection of vulnerable populations, such as pregnant women and children, must be a priority. As long as there is no guarantee that only safe products enter the market, WECF raises awareness and informs consumer about better protection from harmful chemicals, including toys. Children must be protected from potential leaching of chemicals of concerns from toys as they are using them from a very early stage of its development. Products used by children should be subject to the precautionary principle and should not contain toxic chemicals. Therefore, we welcome the strengthening of the Toy Safety Directive and with it the safety requirements that toys must meet before they can be marketed in the EU. Many extremely hazardous substances continue to be permitted for use in toys, in some cases in even higher concentrations then in the early version of the directive. Also, after the UN included the human right for a clean, healthy and sustainable environment in its Resolution 48/12, the future and health of children cannot be compromised. Products surrounding a baby at this early stage of its development, and in particular their chemical content, and baby’s exposure to it, determine to a large extent how healthy these surroundings are. Toys are developed and sold solely for the education and entertainment of children. Toys are not justified of having any essential use, that would allow for the use of harmful chemicals or other threats to children`s safety or health. Children are not only exposed to toxins from toys. Furniture, personal care products, clothes, plastic products, food containers and many more are sources for exposure. Combined exposures leading to mixture effects and a sum effect must be considered. Safe levels of chemicals e. g. in toys should not be set by one chemical alone. We agree to broaden the scope of the TSD toward all endocrine disruptors and substances that are persistent and bio accumulative. Endocrine disruptors (EDCs) are especially for children from high danger because they can disrupt their hormonal status, which affects a healthy growth and development Please find more in the file attached.
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Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

31 Oct 2021

Women Engage for a Common Future, France (Wecf France) se félicite du projet de la Commission européenne de réviser le règlement UE sur les produits cosmétiques. En tant que bureau français du réseau écoféministe international WECF regroupant 150 femmes et organisations civiles non gouvernementales engagées dans la construction d'un environnement sain et actives au niveau de l'UE en vue d'un avenir sans produits toxiques, Wecf France appelle les autorités européennes à renforcer les réglementations relatives aux produits chimiques dangereux. Les études de Wecf France ont montré que de nombreux produits cosmétiques contiennent des substances très préoccupantes à préoccupantes pour la santé humaine. Nous demandons l’interdiction de certains ingrédients sans tarder : benzyl salicylate, BHT, butylphenyl methylpropional, ethylhexyl methoxycinnamate, ethylparabène, méthylparabène, octocrylène, cyclohexasiloxane, cyclopentasiloxane, dioxyde de titane, homosalate, octocyclane, oxyde de zinc et phenoxyethanol. Ces derniers ont été jugés par nos rapports comme étant des substances extrêmement préoccupantes . Ainsi, à partir de l’instant où la substance n’est pas jugée comme essentielle aux produits celle-ci ne devrait pas faire partie de sa composition. Parmi les critères, l’emploi dans des produits destinés à être employés sur des enfants ou des femmes enceintes doivent appartenir aux critères d’évaluation des substances. Nous demandons également une réglementation par famille de substances/substances à la structure similaire, afin d’éviter les substitutions regrettables, et d’accélérer les évaluations, comme le recommande l’ECHA . Enfin la révision de la règlementation devra intégrer en vertu du principe de précaution, non seulement les substances préoccupantes, mais aussi les effets « cocktails » des différentes substances. La réattribution de l’évaluation des ingrédients cosmétiques à l’ECHA permettrait une évaluation scientifique plus poussée aux vues des moyens dédiés à l’Agence. Pour autant, cette réattribution des tâches devra aussi intégrer comme dans d’autres comités d’expertises au sein de l’ECHA, la présence de représentants de la société civile. Les études menées par Wecf France, mais aussi par la DGCCRF en France, ont montré que pour l’heure, l’évaluation des produits étaient déficiente. Des produits solaires destinés aux enfants contiennent des produits préoccupants tels que des perturbateurs endocriniens, des nanoparticules ou des substances parfumantes, ne faisant pas l’objet d’évaluation spécifique par rapport à l’usage de ces produits . Nous accueillons la proposition de la Commission d’intégrer une définition plus cohérente des nanomatériaux dans la révision du règlement sur les produits cosmétiques. Les différentes terminologies des règlements de l’UE devraient être alignées. Afin de rendre la définition la plus effective possible, celle-ci devrait contenir l’obligation pour les fabricants de signifier la présence de nanomatériaux dans les cosmétiques. La révision de l’étiquetage des produits cosmétiques est essentielle à l’effectivité du règlement pour la protection de la santé et de l’environnement. Le rapport de Wecf France sur les produits cosmétiques féminins a mis en lumière l’insuffisance des informations dédiées aux consommatrices et leur manque de clarté . En effet, nombreux sont les produits féminins contenant des ingrédients avérés ou suspectés d’être des perturbateurs endocriniens. Dans l’attente de l’interdiction de ces substances, nous demandons de signaler la présence des perturbateurs endocriniens dans les cosmétiques par un logo mettant en garde les femmes enceintes, similaire à celui existant pour l’alcool.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

Chemical legislation – Revision of the REACH Regulation and the Inception Impact Assessment Women Engage for a Common Future, WECF, welcomes the opportunity to comment on the revision of the REACH Regulation and the Inception Impact Assessment (IIA). As an international ecofeminist network of 150 women and civil organizations NGOs committed to build a healthy environment and be active at EU level for moving towards a toxic-free future, Women Engage for a Common Future (WECF) calls the EU authorities to stronger regulations in context of harmful chemicals. To better protect environment and human health from harmful of concern and to and meet the EU chemicals strategy for sustainability (CSS) objective of a toxic-free environment an upgrade of REACH is necessary. This upgrade must also take into account that women are differently impacted by hazardous chemicals, not even during pregnancy. So far, the words “gender”, “woman”, “girl” cannot be found in either of the legal texts. The word “female” is found when referring to laboratory animal testing. WECF strongly supports the ambition in the Chemicals Strategy for Sustainability to introduce 1) endocrine disruptors, 2) persistent, mobile and toxic and 3) very persistent and very mobile substances as important categories of chemical substances of very high concern within REACH. We also see urgent need to strengthen the focus per- and polyfluoroalkyl substances (PFAS) because of their persistent negative impacts on health and environment. A study conducted by the German Environment Agency found out that one-fifth of the children and adolescents tested had levels of the PFAS chemical PFOA in their blood that exceeded the HBM-I-value, which indicates an exposure at which harmful effects cannot be excluded with sufficient certainty. PFAS are widely used in everyday products and end up in drinking water and food, including breast milk. They have impacts on reproduction and the development of certain cancers. The reality is that if persistent and mobile chemicals are released into the environment it is impossible to remove them if they are later found to be toxic. To ensure a high level of protection of human health and the environment all polymers should be registered in a process, starting with those produced in high volumes and those polymers to whom people and the environment are most exposed to due to their uses (plastics, paints, textiles, etc.). Registration requirements should also include those polymers which can generate micro and nano-plastics. Registration of polymers is an important step to reduce the plastic pollution crisis. Humans and the environment are exposed to multiple chemicals to different sources at the same time. The risks from such combined exposure are not adequately taken into account in the current REACH regulation and prevent adequate protection of human beings and the environment. WECF supports introducing a generic Mixtures Assessment Factor (MAF) and its use in the chemical’s safety assessment of registrants. Transparency is crucial for on the way of a toxic-free environment. The EU needs to hold industry manufacturers and importers responsible for their obligations under REACH. Munich, 31st May 2021
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

31 May 2021

Women Engage for a Common Future, WECF, welcomes the European Commission’s plan to revise the CLP Regulation. As an international ecofeminist network of 150 women and civil organizations NGOs committed to build a healthy environment and be active at EU level for moving towards a toxic-free future, Women Engage for a Common Future (WECF) calls the EU authorities to stronger regulations in context of harmful chemicals. We strongly support the strengthening of the CLP in order to better protect environment and human health, especially for the most vulnerable groups such as pregnant women, children and adolescents from harmful chemicals. We also support of holding companies making economic profit from the manufacture of hazardous chemicals accountable. In relation with the commitments in the Green Deal, the Chemicals Strategy for Sustainability (CSS), the EU Beating Cancer plan, the Zero Pollution Action plan and the EU Strategy on the Rights of the Child, ambitious policy options are needed to make sure that the review of the CLP offers the necessary legal certainty to minimise the exposure of harmful chemicals. The actions relevant for the CLP revision included in the Chemicals Strategy for Sustainability should be the basis of the IIA of the CLP revision. From WECF’s point of view the revision of the EU chemicals policy framework should focus on policy areas which had been overseen for a long time: introducing new hazard classes for endocrine disruptors (EDs) with different sub-categories is crucial and urgently needed. Together with our campaign partners from the EDC-Free-Europe-Coalition we have advocated for many years for a better identification of EDs, followed by necessary protective measures to minimize exposure. Horizontal criteria for the identification of EDCs (endocrine disrupting chemicals) and stronger and coherent regulations have to be incorporated to guarantee a high level of health and environment protection can and should be considered as well. A large number of studies shows that EDCs are found in many of our daily products, thus also in our bodies as well as the environment (see EU biomonitoring programHBM4EU citizen’s corner). EDCs are linked with diseases such as cancer, reprotoxic disorders, diabetes, neurological disorders, birth defects and many more. They can be harmful in very low doses. Pregnant women, foetus and children are especially vulnerable. Meanwhile worldwide children are born pre-polluted. (full submission pl. see pdf attached)
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Response to Mercury – review of EU law

31 Mar 2021

As an NGO network focussing on a toxic free environment and the impacts of toxins, including mercury, on health, especially women’s and children health, WECF, Women Engage for a Common Future, is calling for phasing out dental amalgam by 2025. This is technically and economically feasible, and therefore should be implemented without delay. This is an important step to committed to promote the toxic-free environment goal of the European Green Deal. We know that dental amalgam is one of the largest remaining uses of mercury in Europe. Amalgam’s mercury can end up back in the environment via cremation, dental clinic emissions, waste incineration, human waste, and burials, among other pathways. The high cost of mercury pollution from dental amalgam falls on taxpayers, governments, and community members, besides the unaccounted costs for the health and wellbeing of all (humans and non-humans). Because: There is scientific evidence that when dental amalgam’s mercury enters the environment it can convert to methyl-mercury that can contaminate the fish eaten by humans. Prenatal exposure to mercury can cause severe birth defects, brain damage and congenital malformation. Studies and government health authorities have repeatedly conducted risk assessments that confirm mercury-free dental fillings are safe for both health and the environment. For all these reasons, WECF is calling for action – now! 2025 already is far too late. It is time to set the stage for the change to a non-toxic future for all. There are no economic, environmental or social reasons that can justify the prolongation of the use of dental amalgam with mercury and the pollution of environment and health, including the health of future generations.
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Response to Revision of EU rules on food contact materials

29 Jan 2021

Women Engage for a Common Future, WECF Response to the European Commission public consultation on the inception impact assessment for the review of the Food Contact Materials legislation January 2021 Women Engage for a Common Future, WECF welcomes the opportunity to comment on the European Commission’s plans for revisions of the EU Food Contact Materials (FCM) legislation. As an international ecofeminist network of 150 women and civil organizations NGOs committed to build a healthy environment and be active at EU level for moving towards a toxic-free future, Women Engage for a Common Future (WECF) calls the EU authorities to ban the negative health effects from FCMs. For WECF one point is non-negotiable: hazardous chemicals must never be allowed in whatever FCM. This is in the spirit of the new EU Chemical Strategy for Sustainability as well in the Zero-Pollution Ambition of the EU Green Deal. As an organisation focusing on gender and women aspects of chemicals safety, protection of vulnerable populations, such as pregnant women and children must be a priority. They must be protected from potential leaching of chemicals of concerns from the food contact articles and materials into the food. Following the submission of our NGO colleagues from HEAL, where WECF is a member organisation, in terms of many loopholes identified in the current regulation, and the European Commission’s acknowledgement of some of the important limitations of the current regulation, we support a new regulatory approach (Option 2 “Develop a new regulatory framework, replacing the current Regulation”), which opens the possibility of creating better rules without being limited by the current framework. Please find her some main points for a new FCM from our perspective:
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Response to Commission Regulation amending Annex XIV to REACH

5 Jan 2021

WECF – Women Engage for a Common Future supports the proposed update of the entry of four phthalates (DEHP, DBP, BBP and DIBP) on the authorization list of substances of very high concern under the REACH regulation to reflect their endocrine disrupting properties in the environment. As humans we are part of the environment, and decades of independent research shows that the disruption of the endocrine system is also a risk in humans, in particular for the developing child, and can lead to irreversible health damage that impact our ability to reproduce, to live with our full mental capabilities and free from diseases. The list of possible diseases linked to the use of endocrine disrupting chemicals is extremely worrying, including reproductive dysregulation, early puberty, endometriosis, infertility, altered fetal development, breast and skin cancer, obesity, type II diabetes, attention-deficit hyperactivity, disorder, autism spectrum disorders, cardiotoxicity, hepatotoxicity, nephrotoxicity, asthma and allergies. this justifies the inclusion of DEHP, DIBP, DBP and BBP to annex XIV, as it is essential that these chemicals of concern can no longer be used without prior consent in products such as plastics and food contact materials. We refer to our extensive information material on this topic in several languages on our websites, in particular our platform ‘nesting’ which informs parents on ways to protect their children from exposure to chemicals of concern, such as endocrine disrupting substances, in our daily lives https://www.projectnesting.org
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Response to Chemicals strategy for sustainability

20 Jun 2020

Contribution to the European Commission Consultation on the Roadmap on Chemicals Strategy for Sustainability As an international ecofeminist network of 150 women and civil organizations NGOs committed to build a healthy environment and active at EU level for moving towards a toxic-free future, Women Engage for a Common Future (WECF) welcomes the publication by the European Commission of a Chemicals Strategy for Sustainability. Such a Strategy was long awaited, and increasingly urgently needed, both in view of the too many years of delay of the adoption of EU EDCs criteria, and while the adaptation of EU legislative, implementation and control instruments has become urgent to ensure that current chemicals rules applicable at EU level, that are adequate in protecting the health of European populations and ecosystems from hazards generated by the increasing production and use of chemicals-of-concern. Our 10 key demands for Chemicals Strategy for Sustainability: 1) Deliver by 2030 ambitious reduction targets of production and use/consumption of chemicals hazardous for health and the environment 2) Make eco-design and healthy products a priority in substitution of chemicals of concern 3) Grouping chemicals with the same chemical structure for evaluation 4) Urgently and adequately regulate Endocrine Disrupting Chemicals (EDCs) to protect the health of present and future generations 5) A healthy and non-toxic food, without traces of pesticides of concern, must be a priority 6) Protect in priority vulnerable groups like pregnant women, children, and others, and better address women’s health by banning chemicals of concern for human health including PFAS 7) New kinds of substances that are hazardous to health and/or the environment must be regulated: we cannot remain stuck in the last century 8) Apply the polluter-pays principle to generate resources for substitution/innovation and save immense health and environmental decontamination costs 9) Address the specificities of nanomaterials to prevent uncontrollable and irreversible damages to health and the environment 10) Reducing the sheer volumes of hazardous chemicals, waste and plastic production, and stop exporting (toxic) waste More information can be found in the attached pdf file. WECF, 19th June 2020
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Response to EU Action Plan of Gender equality and women’s empowerment in external relations for 2021-2025

3 Apr 2020

BUILDING ON GAP II The EU GAP II is a good and ambitious basis for the GAP III and roadmap. The concrete objectives, the three-pronged approach, the indicators and financial targets of GAP II were strong and effective. The fact that the GAP II was incompletely implemented is an additional reason for the EU to build on the structure, objectives and indicators of GAP II and expand it in GAP III. One of the essential targets of GAP II was to aim for 85% of all funding to have an OECD DAC Gender Marker 1 or 2 by 2020 (see indicator 5.3.2), meaning that one of the sub-objectives of the action or the main objective of the action should be to help improve gender-equality. Even if this target was not achieved, it needs to remain as a key target for GAP III. Additionally, an increase of the number of programmes that have gender equality as a main objective (Gender Marker 2) should be set as a target (ideally 20%) under GAP III. NEW EMERGING ISSUES: FEMINIST ORGANISATIONS, ECOFEMINISM AND INTERSECTIONALITY We suggest that GAP II is extended with new emerging areas of action, and push for further implementation and related funding for this implementation. We are pleased to see that the GAP III tries to bring a more intersectional focus. We would like to see stronger commitments to an intersectional and ‘ecofeminist’ analysis and approach. We see it as essential that the roadmap and the new GAP III uses inclusive language, such as “women in all their diversity”.    1. Engage women’s rights and feminist organisations • The roadmap should allow time for consultation with local feminist and women’s rights organisations in partner countries. Many EU delegations are not in contact with feminist organisations and have not yet consulted local women’s rights and feminist organisation. • Women’s rights and feminist organisations should be included throughout the development of the roadmap and the design and implementation as well as the monitoring of the GAP III. Engaging and supporting local feminist and women’s rights oragnizations should be a key priority: a stand-alone goal on the engagement of these organisations should be introduced. 2. Take an ‘ecofeminist‘ and integrated approach to ensure policy coherence • GAP II called for the participation of women in environmental decision-making (e.g. regarding climate change), however it lacked an ‘ecofeminist’ approach on environmental and natural resources protection. Throughout the roadmap and the GAP III an ‘ecofeminist’ approach and analysis has to be taken, such as making the link between all Sustainable Development Goal areas and gender equality targets. See for an ecofeminist approach our Gender Impact Analysis tool: GIM tool:https://www.wecf.org/the-gender-impact-assessment-and-monitoring-tool/. • The integrated approach is quite weak and has to be expanded to natural resources protection; more commitment is needed in terms of policy coherence to support the local transformation of economies to become climate-positive, circular and gender-just. • Fiscal policies must give the right incentives, i.e. subsidies not be given to extractive industries and fiscal havens, but instead incentives for local gender-just renewable energy and agro-ecology cooperatives. 3. Cultural shift and intersectionality: GAP III should • deliver on the objective of GAP II to strengthen the EU/EEAS internal institutional capacities: it is crucial that the political leadership presents the intersectional, ‘ecofeminist’ and gender approach inside and outside of its institutions. • Include GAPIII into other EU policies and its relevant objectives should be priorities in partnerships with partner countries and specific country strategies. • address the role of men as feminists: changing attributed gender roles as well as barriers created by toxic-masculinities. This can be reached by the use of non-sexist, non-gender-stereotyped language in all EU external policies and programmes.
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Meeting with Jutta Urpilainen (Commissioner) and European Youth Forum and

20 Feb 2020 · Africa Strategy

Response to Fitness Check on endocrine disruptors

10 Jul 2019

Thank you for giving the opportunity to comment to the European Commission Roadmap for the Fitness Check on EDCs. WECF is an NGO network working since more than 20 years on EDCs on national (Germany, France, the Netherlands), EU and international level. WECF is member of the EDC-free Europe Coalition. In our work we focus on the health impact from the exposure to EDCs on women, pregnant women and their foetus and children. Our comments on European Commission Roadmap for the Fitness Check on Endocrine Disrupting Chemicals go along with and refer to the comments of EDC-Free Europe. General Comments WECF is concerned with the additional delay resulting from this procedure, especially considering that the current Commission has failed to deliver the protective measures as defined by the 7th EU Environment Action Programme (7th EAP). Released in 2013, the 7th EAP aims to ensure minimisation of exposure to endocrine disruptors. Several Commission reports have already pointed out the gaps in various pieces of EU legislation regarding these harmful hormone disruptors . As emphasised by the European Parliament Resolution on EDCs adopted on 18 April 2019 , and by the 26 June 2019 Environment Council conclusions "Towards a sustainable chemicals policy for the Union" , it is now urgent for the European Commission to uphold its commitments as per the 7th EAP and effectively reduce people’s exposure to EDCs in a comprehensive way throughout Europe. The 2018 European Commission Communication "Towards a comprehensive European Union framework on endocrine disruptors" should in no way be considered as an update of the 1999 Community Strategy for EDCs. This eleven-page document fails to provide any proposal for specific measures, a timeline, targets, an action plan, or a budget. In order to have a real added value, and given the magnitude of the health and environment concerns at stake as well as the many fitness checks on EU chemicals regulations undertaken over the last few years, it is essential the EDC Fitness Check focuses on assessing how to strengthen protection against EDCs through improved and new EU regulations. In this way, the EU can deliver on its objectives to protect human health and the environment from endocrine disruptors, and in particular vulnerable groups, such as pregnant women and children. This approach should also be reflected in the international dimension foreseen in this exercise. Effective control of EDCs to ensure a high level of health and environment protection is not only essential for the purpose of imported products in the EU, but also in respect to the positions the EU is taking in multilateral initiatives for safer chemicals . Finally, the Fitness Check must also ensure that future provisions on EDCs will be fit for purpose to guarantee a clean circular economy and a non-toxic environment. Our detailed contribution can be found in the PDF attached.
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WECF Urges EU to Regulate Groups of Toxic Chemicals

19 Jul 2018
Message — They request shifting from individual chemical reviews to regulating entire chemical groups to increase protection. The group demands transparent labeling and awareness campaigns to help families minimize toxic exposure.12
Why — A stricter strategy would help the organization protect pregnant women and children from toxic substances.3
Impact — Chemical producers would face higher costs if the EU adopts a group-based regulatory approach.4

WECF urges EU to strengthen endocrine disruptor identification criteria

27 Jul 2016
Message — WECF wants to identify disruptors using presumed effects rather than requiring absolute proof. They support classifying substances into three groups based on the strength of scientific evidence. The group also opposes the introduction of safety assessments that would allow limited chemical exposure.123
Why — Stricter standards would benefit the group's agenda by stimulating innovation and development of safer alternatives.4
Impact — Pesticide manufacturers lose access to the proposed loophole that would permit continued chemical usage.5

WECF Urges Stricter Identification Criteria for Endocrine Disruptors

27 Jul 2016
Message — WECF recommends identifying disruptors when they are presumed harmful, not just known. They propose a three-category system including confirmed, suspected, and potential disruptors.12
Why — Tougher standards would reduce healthcare costs and protect citizens from hormone-related diseases.34
Impact — Manufacturers of biocides would be forced to invest in new, safer product alternatives.5