ClientEarth's contribution to the Public consultation on the Roadmap 'Towards a more comprehensive EU framework on endocrine disruptors'

ClientEarth criticizes the European Commission's claim that the existing EU regulatory framework for endocrine disruptors (EDCs) is 'comprehensive', highlighting significant gaps in the identification and prevention of adverse effects. The organization argues that EDCs should be established as an independent regulatory class, similar to carcinogenic, mutagenic, and reprotoxic (CMR) substances, to ensure systematic risk management across all sectors, including toys and cosmetics. ClientEarth further notes that the current substance-by-substance approach leads to problematic substitutions, such as replacing Bisphenol A with Bisphenol S, and calls for a grouping approach to regulation.

• ClientEarth disputes the European Commission's characterization of the EU regulatory framework as 'comprehensive', asserting that it fails to provide a high level of protection and ignores gaps identified by stakeholders and Commission-funded studies.
• There is a significant gap in the identification of EDCs because testing requirements under REACH and CLP Regulations are not designed to detect all potential adverse effects of endocrine disruptors, and no such tests are required for toys, childcare products, or food contact materials.
• The current framework lacks a legal mechanism to ensure that identifying a chemical as an EDC under one piece of legislation, such as REACH, automatically triggers risk management measures in other sectoral laws like those governing cosmetics or toys.
• EDCs are not treated with the same regulatory stringency as carcinogenic, mutagenic, and reprotoxic (CMR) substances; for instance, the Cosmetics and Toys Regulations exclude CMRs by principle but do not do the same for EDCs.

APA

ClientEarth (2018). ClientEarth's contribution to the Public consultation on the Roadmap 'Towards a more comprehensive EU framework on endocrine disruptors'. https://www.clientearth.org/media/iavlksn5/clientearths-contribution-to-the-public-consultation-on-the-roadmap-towards-a-more-comprehensive-eu-framework-on-endocrine-disruptors-ce-en.pdf

Chicago

ClientEarth. ClientEarth's contribution to the Public consultation on the Roadmap 'Towards a more comprehensive EU framework on endocrine disruptors'. 2018. https://www.clientearth.org/media/iavlksn5/clientearths-contribution-to-the-public-consultation-on-the-roadmap-towards-a-more-comprehensive-eu-framework-on-endocrine-disruptors-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth's contribution to the Public consultation on the Roadmap 'Towards a more comprehensive EU framework on endocrine disruptors' |date=July 2018 |url=https://www.clientearth.org/media/iavlksn5/clientearths-contribution-to-the-public-consultation-on-the-roadmap-towards-a-more-comprehensive-eu-framework-on-endocrine-disruptors-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2018clientearths, author = {{ClientEarth}}, title = {{ClientEarth's contribution to the Public consultation on the Roadmap 'Towards a more comprehensive EU framework on endocrine disruptors'}}, publisher = {ClientEarth}, year = {2018}, month = jul, url = {https://www.clientearth.org/media/iavlksn5/clientearths-contribution-to-the-public-consultation-on-the-roadmap-towards-a-more-comprehensive-eu-framework-on-endocrine-disruptors-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }