Disrupted Criteria

The report criticizes the European Commission's 2016 proposal for EDC identification criteria, arguing that its sector-specific focus on pesticides and biocides creates regulatory gaps and legal uncertainty. The authors contend that this approach deviates from international GHS standards, ignores the 7th Environmental Action Programme's mandate for harmonised criteria, and risks lower levels of protection in consumer products like cosmetics and medical devices.

• The European Commission's proposed criteria for identifying EDCs are designed specifically for pesticides and biocides, deviating from the Commission's 2014 goal to develop 'horizontal' criteria applicable across all sectors.
• The draft criteria deviate from the United Nations Globally Harmonised System of Classification and Labelling of Chemicals (GHS) and the EU CLP Regulation by failing to use hazard categories based on the strength of evidence (known, presumed, and suspected).
• The use of the term 'non-target organisms' in the draft criteria is specific to the pesticides and biocides sectors and is not relevant to other EU legislation, potentially leading to the failure to identify certain EDCs.
• Applying sector-specific criteria to other frameworks like REACH could result in lower levels of protection, delayed identification of substances of very high concern (SVHC), and inconsistencies between different regulatory lists.
• The sector-specific approach may lead to inadequate protection in cosmetics and water quality management, as it may fail to identify EDCs in products not used as pesticides or biocides.
• The proposed criteria are identified as a breach of the 7th Environmental Action Programme (7th EAP), which explicitly called for the development of 'harmonised hazard-based criteria for the identification of endocrine disruptors' across all relevant Union legislation.
• The report asserts that the Commission's approach violates 'Better Law Making' principles and Better Regulation Guidelines due to a lack of internal coherence and inconsistency with other EU actions like the REACH and non-REACH fitness checks (REFIT).

APA

Center for International Environmental Law (2017). Disrupted Criteria. https://www.ciel.org/wp-content/uploads/2017/02/Disrupted-Criteria_EDCs_Final_14feb2017.pdf

Chicago

Center for International Environmental Law. Disrupted Criteria. 2017. https://www.ciel.org/wp-content/uploads/2017/02/Disrupted-Criteria_EDCs_Final_14feb2017.pdf.

Wikipedia

{{cite report |author=Center for International Environmental Law |title=Disrupted Criteria |date=February 2017 |url=https://www.ciel.org/wp-content/uploads/2017/02/Disrupted-Criteria_EDCs_Final_14feb2017.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centerforinternationalenvironmentallaw2017disrupted, author = {{Center for International Environmental Law}}, title = {{Disrupted Criteria}}, institution = {Center for International Environmental Law}, year = {2017}, month = feb, url = {https://www.ciel.org/wp-content/uploads/2017/02/Disrupted-Criteria_EDCs_Final_14feb2017.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }