Toxic partnership

A critique of the ACC-CEFIC proposal for chemical regulatory cooperation under TTIP, arguing that the industry seeks to lower safety standards, bypass democratic oversight, and delay the regulation of toxic substances by exploiting differences between EU and US laws.

• The ACC-CEFIC proposal seeks to use TTIP to minimize non-tariff barriers, but the author argues its true intent is to exploit regulatory differences between the US and EU to slow the regulation of toxic chemicals, specifically endocrine disrupting chemicals (EDCs), and to block the substitution of harmful substances with safer alternatives.
• The proposed creation of a Regulatory Cooperation Council (RCC) and a subsidiary Chemical Sector Joint Cooperation Committee (CSJCC) could freeze progress in chemicals regulation by introducing onerous consultation requirements and shifting decision-making away from democratic public processes to unelected trans-Atlantic regulators.
• The industry's push for mandatory cost-benefit analyses (impact assessments) is viewed as a mechanism to prioritize trade interests over public health, as these analyses often ignore externalized costs like natural resource damage and health-related productivity loss.
• The proposal for mutual recognition of notifications and registrations would undermine the EU's REACH principle of "no data, no market" by allowing companies to use the weaker US TSCA pre-manufacture notice (PMN) process to gain EU market access without providing the required safety data.
• The author argues that the proposal's approach to Confidential Business Information (CBI) disregards the EU's obligations under the Aarhus Convention, which presumes environmental information should be public, and would protect industry secrets at the expense of the public's "right to know."
• The proposal to align classification and labelling through mutual recognition could lower protection levels in the EU; for example, the EU database contains 4,089 carcinogens, while the US EPA's IRIS includes only 103.
• The document highlights a fundamental divergence in the burden of proof: REACH requires companies to prove a substance is safe before market entry, whereas the US TSCA places the burden on regulators to prove a chemical poses an "unreasonable risk."
• The author contends that the proposal would stifle innovation in safer chemicals by removing the regulatory pressure (such as hazard-based listing) that currently drives companies to develop non-toxic alternatives.
• The proposal for a Trans-Atlantic Scientific Advisory Committee (TSAC) is criticized as a tool for further delaying regulation by manipulating scientific uncertainty and resisting the precautionary principle.

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} }