Comments on the guidance on the identification of endocrine disruptors for pesticides and biocides (public consultation)

ClientEarth argues that the draft guidance from ECHA and EFSA exceeds its legal mandate by lowering the level of environmental and health protection established by EU co-legislators. The organization specifically criticizes the requirement for a detailed understanding of the mode of action as a pre-condition for EDC identification, asserting that this creates an excessive evidentiary burden that risks 'false negatives' and contradicts the precautionary principle. ClientEarth also contends that the guidance illegally attempts to extend its scope beyond pesticides and biocides and fails to sufficiently mandate the inclusion of all available relevant scientific data, including novel test methods.

• ClientEarth asserts that ECHA and EFSA have exceeded their legal mandate by adopting a method for identifying endocrine disruptors that lowers the level of protection set by EU co-legislators.
• The requirement in the guidance to demonstrate a detailed understanding of the mode of action linking endocrine activity to adverse effects is viewed as an excessive requirement that may make the identification of EDCs impossible or excessively difficult.
• ClientEarth argues that the guidance should prioritize the avoidance of 'false negatives' (falsely identifying a substance as safe) in accordance with the precautionary principle, which allows for regulatory action when scientific uncertainties remain.
• The document claims that the guidance illegally extends its scope by suggesting its principles may be applicable to substances outside the specific framework of pesticides and biocides.
• ClientEarth recommends that the guidance explicitly state that 'all available relevant scientific data' must be considered, including data from novel test methods and knowledge available at the time of dossier submission, regardless of whether such methods existed when the guidance was adopted.

APA

ClientEarth (2018). Comments on the guidance on the identification of endocrine disruptors for pesticides and biocides (public consultation). https://www.clientearth.org/media/p2bmbh0t/clientearths-comment-on-the-efsa-echa-guidance-document-for-the-identification-of-edcs-in-pesticides-and-biocides-ce-en.pdf

Chicago

ClientEarth. Comments on the guidance on the identification of endocrine disruptors for pesticides and biocides (public consultation). 2018. https://www.clientearth.org/media/p2bmbh0t/clientearths-comment-on-the-efsa-echa-guidance-document-for-the-identification-of-edcs-in-pesticides-and-biocides-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Comments on the guidance on the identification of endocrine disruptors for pesticides and biocides (public consultation) |date=January 2018 |url=https://www.clientearth.org/media/p2bmbh0t/clientearths-comment-on-the-efsa-echa-guidance-document-for-the-identification-of-edcs-in-pesticides-and-biocides-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2018comments, author = {{ClientEarth}}, title = {{Comments on the guidance on the identification of endocrine disruptors for pesticides and biocides (public consultation)}}, publisher = {ClientEarth}, year = {2018}, month = jan, url = {https://www.clientearth.org/media/p2bmbh0t/clientearths-comment-on-the-efsa-echa-guidance-document-for-the-identification-of-edcs-in-pesticides-and-biocides-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }