A Trojan horse in the identification of endocrine disruptors
Summary
The document argues that the European Commission exceeded its legal mandate by proposing a clause that would exempt chemicals intended to act as endocrine disruptors from the ban established by the 2009 Pesticides Regulation. ClientEarth asserts that the Commission is using the process of defining scientific criteria as a 'Trojan horse' to weaken environmental and health protections for economic reasons, thereby violating the balance of power between EU institutions.
Key insights
- The European Commission's proposal includes a clause that would exempt substances from being identified as endocrine disruptors if their intended mode of action is to control target organisms other than vertebrates via their endocrine systems. This effectively creates a new derogation that allows chemicals which are, by definition, endocrine disruptors to escape the ban set by the 2009 Pesticides Regulation.
- ClientEarth contends that the Commission exceeded its implementing powers because its mandate was limited to adopting scientific criteria for identification, not deciding which substances should be authorized or banned. The proposed exemption is viewed as an alteration of 'essential elements' of the Pesticides Regulation, which are strictly reserved for the legislature.
- The document claims the Commission knowingly bypassed its legal boundaries for economic reasons, citing a 'methodological bias' in its Impact Assessment that favored options banning fewer substances to reduce negative impacts on the single market.
- The 2009 Pesticides Regulation originally established a ban on endocrine disruptors that cause adverse effects on humans or non-target organisms, with only two narrow derogations: cases where exposure is 'negligible' or temporary use to address a serious danger to plant health.
Cite the original document
- APA
- ClientEarth (2017). A Trojan horse in the identification of endocrine disruptors. https://www.clientearth.org/media/0d3jincq/a-trojan-horse-in-the-identification-of-endocrine-disruptors-ce-en.pdf
- Chicago
- ClientEarth. A Trojan horse in the identification of endocrine disruptors. 2017. https://www.clientearth.org/media/0d3jincq/a-trojan-horse-in-the-identification-of-endocrine-disruptors-ce-en.pdf.
- Wikipedia
- {{cite press release |author=ClientEarth |title=A Trojan horse in the identification of endocrine disruptors |date=September 2017 |url=https://www.clientearth.org/media/0d3jincq/a-trojan-horse-in-the-identification-of-endocrine-disruptors-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{clientearth2017trojan, author = {{ClientEarth}}, title = {{A Trojan horse in the identification of endocrine disruptors}}, publisher = {ClientEarth}, year = {2017}, month = sep, url = {https://www.clientearth.org/media/0d3jincq/a-trojan-horse-in-the-identification-of-endocrine-disruptors-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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