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

Oral comments delivered by Baskut Tuncak of the Center for International Environmental Law (CIEL) on May 29, 2013, regarding the proposed Transatlantic Trade and Investment Partnership (TTIP). The statement warns against "enhanced regulatory cooperation" on chemicals that might undermine the European Union's more stringent hazard-based regulatory approach in favor of the United States' risk-based approach.

• The European Union and the United States employ fundamentally different approaches to chemical regulation: the EU uses a hazard-based approach, while the U.S. uses a risk-based approach. The EU's REACH regulation requires the industry to provide information on intrinsic hazards, which CIEL asserts is "the driver for change at the present" and encourages innovation toward safer chemicals. In contrast, the U.S. Toxic Substances Control Act (TSCA) of 1976 is described as a "high-risk" piece of legislation that presumes the safety of over 60,000 existing chemicals and has resulted in the regulation of only five existing chemicals since its enactment.
• CIEL argues that the economic costs of chemical regulation are overstated by industry and are far lower than the externalized costs of pollution. For example, the total costs of the EU's REACH regulation were estimated at EUR 2.8-5.2 billion over 15 years, whereas the cost of late action on PCBs in Europe alone is estimated to exceed 15 billion USD. Furthermore, REACH is credited with generating 90 billion in cost savings through the reduction of dermal and respiratory illnesses.
• The statement expresses concern that TTIP could lead to stronger protections for trade secrets and confidential business information (CBI), which would impair the development of safer chemical alternatives and limit public access to health and safety information. CIEL emphasizes that the EU and U.S. must retain the right to determine their own levels of health protection, citing a WTO Appellate Body ruling that upheld France's ban on asbestos.
• CIEL calls for the TTIP negotiations to be conducted with a commitment to transparency and public participation, noting that previous trade negotiations by the U.S. and EU have not satisfied the requirements of a constitutional democracy. They specifically request broad public access to negotiating documents and positions.

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} }