Summary
The report argues that the ACC-CEFIC proposal for chemical regulatory cooperation under TTIP is designed to benefit the chemical industry by slowing the regulation of toxic substances, bypassing democratic processes, and prioritizing trade over public health and environmental protection. It specifically warns that the proposal could freeze progress on endocrine disrupting chemicals (EDCs), undermine the EU's 'no data, no market' principle under REACH, and restrict the public's right to know through expanded confidential business information (CBI) protections.
Key insights
- The ACC-CEFIC proposal seeks to establish a Chemical Sector Joint Cooperation Committee (CSJCC) and a broader Regulatory Cooperation Council (RCC) which the authors argue would slow or freeze the regulation of toxic chemicals by creating onerous consultation requirements and removing policy choices from the public sphere.
- The proposal's call for mandatory 'regulatory impact assessments' and cost-benefit analyses is viewed as a mechanism to prioritize international trade over public health, potentially creating legal obstacles to protective measures.
- The authors argue that the proposal to allow mutual recognition of notifications and registrations would undermine the EU's REACH principle of "no data, no market" by allowing companies to use the less stringent US TSCA pre-manufacture notice (PMN) process to gain EU market access.
- The proposal's approach to confidential business information (CBI) is criticized for disregarding the EU's obligations under the Aarhus Convention, which presumes environmental information should be publicly available.
- The report claims that the proposal would stifle innovation in safer chemicals by removing the regulatory pressure (such as hazard-based listing) that currently drives the industry toward sustainable substitutes.
- The authors assert that the proposal would exploit differences in carcinogen classification between the EU and US, potentially allowing products that must be labelled as carcinogens in the EU to be imported from the US without such labels.
- The proposal is seen as a threat to the regulation of emerging scientific issues, specifically endocrine disrupting chemicals (EDCs) and nanomaterials, by adding layers of coordination that would delay the EU's current progress in these areas.
Cite the original document
- APA
- Center for International Environmental Law (2014). Toxic partnership. https://www.ciel.org/wp-content/uploads/2015/06/ToxicPartnership_Mar2014.pdf
- Chicago
- Center for International Environmental Law. Toxic partnership. 2014. https://www.ciel.org/wp-content/uploads/2015/06/ToxicPartnership_Mar2014.pdf.
- Wikipedia
- {{cite report |author=Center for International Environmental Law |title=Toxic partnership |date=March 2014 |url=https://www.ciel.org/wp-content/uploads/2015/06/ToxicPartnership_Mar2014.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{centerforinternationalenvironmentallaw2014toxic, author = {{Center for International Environmental Law}}, title = {{Toxic partnership}}, institution = {Center for International Environmental Law}, year = {2014}, month = mar, url = {https://www.ciel.org/wp-content/uploads/2015/06/ToxicPartnership_Mar2014.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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