Summary
This report by the Center for International Environmental Law (CIEL) critiques a joint proposal by the American Chemistry Council (ACC) and the European Chemical Industry Council (CEFIC) regarding regulatory cooperation on chemicals within the Trans-Atlantic Trade and Investment Partnership (TTIP). CIEL argues that the industry's proposals are designed to exploit regulatory differences between the US and EU to slow the regulation of toxic chemicals, bypass democratic processes, and prioritize commercial interests over public health and environmental safety.
Key insights
- The joint proposal by the American Chemistry Council (ACC) and the European Chemical Industry Council (CEFIC) aims to use TTIP to slow regulatory developments, prevent the regulation of endocrine disrupting chemicals (EDCs), and obstruct the substitution of harmful substances with safer alternatives.
- The proposed creation of a Regulatory Cooperation Council (RCC) and a Chemical Sector Joint Cooperation Committee (CSJCC) could freeze progress in regulating toxic chemicals by creating bureaucratic layers that slow down the implementation of legislation and the determination of scientific evidence requirements.
- The industry proposal threatens democratic governance by removing public policy choices from the public sphere and subjecting them to a trans-Atlantic body where stakeholders and civil society are excluded.
- Mandatory cost-benefit analyses and impact assessments proposed by the industry risk prioritizing trade and economic impacts on the regulated industry over the protection of human health and the environment.
- 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 access to the EU market.
- The industry's approach to confidential business information (CBI) conflicts with the EU's obligations under the Aarhus Convention, which presumes that environmental information should be publicly available.
- The EU and US have profoundly different regulatory triggers for safety data: REACH requires manufacturers to prove a substance is safe before it enters the market, whereas the US TSCA places the burden of proof on regulators to show a chemical poses an unreasonable risk.
- Mutual recognition of product labels could erase EU protections by allowing products that must be labeled as carcinogens in the EU to be exported from the US without such labels.
- The report notes a significant disparity in the identification of carcinogens: the EU database contains 4,089 carcinogens, while the US EPA's Integrated Risk Assessment System (IRIS) includes 103.
- The industry's proposal to align regulations on emerging issues like nanomaterials and EDCs would likely delay progress in the EU, where legislative processes are already more advanced than in the US.
Cite the original document
- APA
- Center for International Environmental Law (2014). Toxic partnership. https://www.ciel.org/wp-content/uploads/2014/10/ToxicPartnership_Mar2014.pdf
- Chicago
- Center for International Environmental Law. Toxic partnership. 2014. https://www.ciel.org/wp-content/uploads/2014/10/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/2014/10/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/2014/10/ToxicPartnership_Mar2014.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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