Disrupted Criteria

This report by the Center for International Environmental Law (CIEL) and ClientEarth criticizes the European Commission's 2016 proposal for scientific criteria to identify endocrine disrupting chemicals (EDCs). The authors argue that the Commission adopted a 'sector-specific' approach limited to pesticides and biocides, rather than the 'horizontal' criteria required by the EU's 7th Environmental Action Programme (7th EAP). The report contends that this narrow approach creates legal uncertainty, risks inconsistent identification of EDCs across different regulatory frameworks, and may lower the level of protection for human health and the environment in consumer products such as cosmetics and medical devices.

• The European Commission's proposed criteria for identifying EDCs are designed exclusively for pesticides and biocides, deviating from its 2014 roadmap which aimed for 'horizontal' application across all regulatory settings.
• The draft criteria fail to use a category-based system for the strength of evidence (known, presumed, and suspected), which contradicts the United Nations Globally Harmonised System of Classification and Labelling of Chemicals (GHS) and the EU's CLP Regulation.
• The use of the term 'non-target organisms' in the draft criteria is specific to the pesticides and biocides sectors and is irrelevant to other EU legislation, potentially leading to the failure to identify chemicals as EDCs if they are intended to harm target organisms.
• Applying sector-specific criteria to the REACH Regulation could result in lower levels of protection by failing to identify certain chemicals as 'substances of very high concern' (SVHC) and could delay the goal of listing all relevant SVHCs by 2020.
• The report identifies risks that sector-specific criteria will lead to inadequate protection in other areas, including the Cosmetics Regulation, the Water Framework Directive, and proposed Medical Devices Regulations, due to inconsistencies and the lack of hazard categories.
• The Commission's approach is described as a breach of the Inter-institutional Agreement on 'Better Law Making' and the 'Better Regulation' Guidelines because it creates unnecessary complexity and lacks internal and external coherence.
• The proposal contradicts the 7th Environmental Action Programme (7th EAP), which explicitly mandates the development of 'harmonised hazard-based criteria' for the identification of EDCs across all relevant Union legislation.

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} }