Disrupted Criteria

The report criticizes the European Commission's 2016 proposal for EDC identification criteria, arguing that limiting these criteria to pesticides and biocides violates the 7th Environmental Action Programme's mandate for harmonized, hazard-based criteria. The authors contend that this sector-specific approach creates legal uncertainty, risks inconsistent identification of chemicals across different regulatory frameworks (such as REACH and the Cosmetics Regulation), and may lower overall health and environmental protections. They recommend that the Commission adopt horizontal criteria based on the UN Globally Harmonised System (GHS) and the CLP Regulation, utilizing three hazard categories based on the strength of evidence: known, presumed, and suspected EDCs.

• The European Commission's proposed criteria for identifying EDCs are designed exclusively for pesticides and biocides, deviating from an earlier 2014 roadmap that aimed for 'horizontal' application across all regulatory settings.
• The draft criteria are considered problematic because they omit the 'building blocks approach' used in the UN Globally Harmonised System (GHS) and the EU CLP Regulation, which classifies hazards into categories (1A, 1B, and 2) based on the strength of evidence.
• The use of the term 'non-target organisms' in the draft criteria is specific to the pesticides and biocides sectors and is irrelevant to other EU legislation, potentially leading to the failure to identify certain EDCs.
• Applying sector-specific criteria to the REACH Regulation could result in lower levels of protection, delayed implementation of the 2020 roadmap for identifying substances of very high concern (SVHC), and inconsistencies in how EDCs are identified compared to other regulations.
• The sector-specific approach may lead to a lower level of protection in the cosmetics sector because it prevents the identification of 'suspected' EDCs, whereas suspected CMRs (carcinogenic, mutagenic, or toxic for reproduction) are already banned in cosmetics.
• Under the Water Framework Directive (WFD), the draft criteria could limit the identification of 'main pollutants' because the WFD focuses on properties that 'may affect' endocrine functions, while the draft criteria require proof of 'adverse effects'.
• The proposed criteria are argued to be in breach of the 7th Environmental Action Programme (7th EAP), which explicitly requires the development of 'harmonised hazard-based criteria for the identification of endocrine disruptors' across all relevant Union legislation.

APA

ClientEarth (2017). Disrupted Criteria. https://www.clientearth.org/media/cwgjej1t/disrupted-criteria-the-criteria-to-identify-endocrine-disruptors-implications-beyond-pesticides-and-biocides-coll-en.pdf

Chicago

ClientEarth. Disrupted Criteria. 2017. https://www.clientearth.org/media/cwgjej1t/disrupted-criteria-the-criteria-to-identify-endocrine-disruptors-implications-beyond-pesticides-and-biocides-coll-en.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=Disrupted Criteria |date=February 2017 |url=https://www.clientearth.org/media/cwgjej1t/disrupted-criteria-the-criteria-to-identify-endocrine-disruptors-implications-beyond-pesticides-and-biocides-coll-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2017disrupted, author = {{ClientEarth}}, title = {{Disrupted Criteria}}, institution = {ClientEarth}, year = {2017}, month = feb, url = {https://www.clientearth.org/media/cwgjej1t/disrupted-criteria-the-criteria-to-identify-endocrine-disruptors-implications-beyond-pesticides-and-biocides-coll-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }