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The report argues that the ACC-CEFIC proposal for regulatory cooperation under TTIP is designed to benefit the chemical industry by slowing the regulation of toxic substances, undermining democratic processes, and prioritizing trade over public health and environmental safety.

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  • 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 and, in many cases, freeze chemicals regulation' by creating bureaucratic hurdles for critical regulatory decisions.
  • The report contends that the proposed regulatory structures would 'Create an industry bypass around democracy' by removing public policy choices from the public sphere and subjecting them to regulators without a mandate from the affected citizens.
  • The proposal's call for mandatory 'regulatory impact assessments' focusing on international trade is viewed as a mechanism to prioritize commercial interests over health, potentially adding a 'time-consuming, imbalanced, and costly stage to the regulatory process'.
  • The authors argue that the proposal would 'Stifle innovation in safer chemicals' by resisting stricter rules that typically drive the transition away from hazardous substances.
  • The proposal suggests mutual acceptance of notifications and registrations, which the report claims would undermine the EU's REACH principle of 'No data, no market' by allowing companies to use weaker US data requirements to gain EU market access.
  • The report highlights a deep divergence in the burden of proof: under EU REACH, manufacturers must prove a substance is safe before market entry, whereas under the US TSCA, regulators must prove a chemical poses an 'unreasonable risk'.
  • The ACC-CEFIC proposal on 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 asserts that the proposal would impede the regulation of 'emerging issues' such as endocrine disrupting chemicals (EDCs) and nanomaterials by adding layers of consultation that delay progress.

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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