SUBMISSION OF CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH, SIERRA CLUB AND CENTER FOR BIOLOGICAL DIVERSITY BEFORE THE U.S. SENATE COMMITTEE ON FINANCE HEARING ON THE TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP: ACHIEVING THE POTENTIAL

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The Center for International Environmental Law (CIEL), on behalf of several environmental organizations, warns the U.S. Senate Committee on Finance that TTIP may prioritize trade interests over public health. The document highlights the divergence between the EU's hazard-based REACH regulation and the U.S.'s risk-based Toxic Substances Control Act (TSCA), arguing that harmonization or mutual recognition could lead to a 'lowest-common denominator' approach to chemical safety. It specifically opposes investor-state dispute settlement (ISDS) mechanisms, which it claims allow corporations to sue governments over public interest laws, and warns that TTIP could preempt protective sub-federal laws in the U.S. and national laws in EU member states. Finally, it suggests that a restrictive TTIP could discourage other nations, particularly BRIICS countries, from adopting more stringent chemical safety standards.

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  • There is a fundamental conflict between the EU's hazard-based approach to chemicals under the REACH Regulation, which drives innovation toward safer alternatives, and the U.S.'s risk-based approach under the Toxic Substances Control Act (TSCA), which the document describes as leaving the EPA "almost paralyzed to take action."
  • Mutual recognition provisions in the chemicals sector are deemed inappropriate because they could effectively erase restrictions that exist in only one jurisdiction, potentially exposing citizens to hazardous substances that are banned in the EU but legal in the U.S.
  • The inclusion of investor-state dispute settlement (ISDS) is strongly opposed because it allows foreign corporations to bypass domestic courts and sue governments over policies that reduce expected profits, creating a "chilling effect" on future public health and environmental regulations.
  • TTIP may preempt protective sub-federal regulations in the U.S. (such as those in California, Maine, and Washington) and national-level precautionary measures in EU member states, including moratoria on hydraulic fracturing (fracking) in countries like France, Germany, and Spain.
  • The document warns that TTIP could be used by the chemical industry to establish a global regulatory standard that discourages non-OECD countries, particularly BRIICS nations, from adopting more stringent chemical safety laws than those in the U.S. or EU.

Cite the original document

APA
Center for International Environmental Law (2013). SUBMISSION OF CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH, SIERRA CLUB AND CENTER FOR BIOLOGICAL DIVERSITY BEFORE THE U.S. SENATE COMMITTEE ON FINANCE HEARING ON THE TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP: ACHIEVING THE POTENTIAL. https://www.ciel.org/Publications/TTIP_Hearing_30Oct2013.pdf
Chicago
Center for International Environmental Law. SUBMISSION OF CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH, SIERRA CLUB AND CENTER FOR BIOLOGICAL DIVERSITY BEFORE THE U.S. SENATE COMMITTEE ON FINANCE HEARING ON THE TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP: ACHIEVING THE POTENTIAL. 2013. https://www.ciel.org/Publications/TTIP_Hearing_30Oct2013.pdf.
Wikipedia
{{cite press release |author=Center for International Environmental Law |title=SUBMISSION OF CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH, SIERRA CLUB AND CENTER FOR BIOLOGICAL DIVERSITY BEFORE THE U.S. SENATE COMMITTEE ON FINANCE HEARING ON THE TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP: ACHIEVING THE POTENTIAL |date=30 October 2013 |url=https://www.ciel.org/Publications/TTIP_Hearing_30Oct2013.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{centerforinternationalenvironmentallaw2013submission, author = {{Center for International Environmental Law}}, title = {{SUBMISSION OF CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH, SIERRA CLUB AND CENTER FOR BIOLOGICAL DIVERSITY BEFORE THE U.S. SENATE COMMITTEE ON FINANCE HEARING ON THE TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP: ACHIEVING THE POTENTIAL}}, publisher = {Center for International Environmental Law}, year = {2013}, month = oct, url = {https://www.ciel.org/Publications/TTIP_Hearing_30Oct2013.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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