Oral comments at public hearing on the Transatlantic Trade and Investment Partnership (TTIP)

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The Center for International Environmental Law (CIEL) warns that TTIP's push for regulatory cooperation on chemicals may weaken environmental and health protections by favoring the U.S. risk-based approach over the EU's hazard-based REACH regulation. CIEL highlights that REACH drives innovation toward safer alternatives and that the externalized costs of chemical pollution far outweigh the costs of regulation. The statement also cautions against strengthening trade secret protections and calls for greater transparency and public participation in the TTIP negotiation process.

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  • There is a fundamental divergence between EU and U.S. chemical regulation: the EU uses a hazard-based approach under REACH to identify substances of very high concern and drive innovation toward safer alternatives, while the U.S. uses a risk-based approach under the Toxic Substances Control Act (TSCA) of 1976, which CIEL describes as 'high-risk' and flawed.
  • The economic arguments against stringent chemical regulation are often overstated; CIEL notes that both U.S. and EU chemical industries expanded after the enactment of REACH, and the externalized costs of pollution—such as over 15 billion USD for PCBs in Europe—significantly exceed the costs of implementing REACH (estimated at EUR 2.8-5.2 billion over 15 years).

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APA
Tuncak, B. (2013). Oral comments at public hearing on the Transatlantic Trade and Investment Partnership (TTIP). Center for International Environmental Law. https://www.ciel.org/wp-content/uploads/2014/10/TTIP_USTR_Comments_29May2013.pdf
Chicago
Tuncak, Baskut. Oral comments at public hearing on the Transatlantic Trade and Investment Partnership (TTIP). Center for International Environmental Law, 2013. https://www.ciel.org/wp-content/uploads/2014/10/TTIP_USTR_Comments_29May2013.pdf.
Wikipedia
{{cite press release |last1=Tuncak |first1=Baskut |title=Oral comments at public hearing on the Transatlantic Trade and Investment Partnership (TTIP) |publisher=Center for International Environmental Law |date=29 May 2013 |url=https://www.ciel.org/wp-content/uploads/2014/10/TTIP_USTR_Comments_29May2013.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{tuncak2013oral, author = {Tuncak, Baskut}, title = {{Oral comments at public hearing on the Transatlantic Trade and Investment Partnership (TTIP)}}, publisher = {Center for International Environmental Law}, year = {2013}, month = may, url = {https://www.ciel.org/wp-content/uploads/2014/10/TTIP_USTR_Comments_29May2013.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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