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The document examines the implications of the Bayer-Monsanto merger, asserting that it creates a global powerhouse in seeds and pesticides that undermines food security. It highlights the decline of crop diversity, the rise of corporate patenting of plant varieties, and the resulting imbalance of power between multinational agro-chemical firms and farmers, particularly within the European Union.

The report asserts that CETA facilitates trade expansion by reducing regulatory burdens, which leads to the harmonization of regulations toward the lowest common denominator and the elimination of precautionary measures. It highlights four areas of concern: domestic regulatory disciplines that limit licensing authority, increased pressure from Canadian mining companies on Greek regulations, vulnerabilities in EU industrial pollution controls, and the restriction of Member States' ability to regulate toxic pesticides.

The report examines how corporate activities—including water extraction by Coca-Cola in El Salvador, hydroelectric projects in Honduras, pineapple monocultures in Costa Rica, and sugarcane production in Guatemala—disproportionately affect women's health, labor, and access to resources. It details the specific burdens placed on women, such as increased domestic labor due to water scarcity and health risks from agrotóxicos, while showcasing the emergence of women-led resistance movements and community-based research to challenge corporate power and state negligence.

ClientEarth argues that Canada's chemical and pesticide regulations are significantly less restrictive than those of the EU, citing the continued use of 46 active agents banned elsewhere and more lenient maximum residual limits for pesticides in food. The organization warns that the Regulatory Cooperation Forum (RCF) under CETA could allow Canadian business interests to pressure the EU to weaken its environmental protections, specifically regarding endocrine disruptors and the precautionary principle. ClientEarth contends that regulatory cooperation on environmental issues should occur in international environmental fora rather than trade agreements focused on trade facilitation.

ClientEarth argues that the draft guidance from ECHA and EFSA exceeds its legal mandate by lowering the level of environmental and health protection established by EU co-legislators.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.

The Canadian Association of Physicians for the Environment (CAPE) supports the draft guiding principles for Canada's next food guide, particularly the shift toward plant-based proteins and unsaturated fats. However, CAPE argues that the current draft incorrectly treats human health and the environment as separate entities. They advocate for a 'planetary health' approach that recognizes the ecosystem as a fundamental determinant of health and suggests incorporating Indigenous wisdom regarding sustainability and seven-generation planning. Additionally, CAPE highlights the absence of guidance on cultivation methods, citing research that links organic foods to higher antioxidant levels and lower pesticide residues, while warning that pesticide exposure is associated with neurodevelopmental deficiencies and certain childhood cancers.

The document synthesizes findings from the Ontario College of Family Physicians (2007, 2012) and the Prince Edward Island Chief Public Health Office (2015) regarding the health risks of pesticides. It identifies significant associations between pesticide exposure and various cancers, reproductive issues, neurological disorders, and respiratory problems, with a particular emphasis on the vulnerability of pregnant women and children. The authors advocate for the precautionary principle and the banning of non-essential cosmetic pesticide use.

The document synthesizes findings from systematic reviews to argue that pesticide exposure is linked to various cancers, reproductive issues, neurological disorders, and respiratory problems, particularly in vulnerable populations like children and pregnant women. It advocates for the reduction of pesticide use and the banning of cosmetic pesticides in Canada.

The report finds that pollution imposes very significant costs on Canadian families, businesses, and governments, with direct welfare costs alone estimated at $39 billion in 2015. It highlights substantial data gaps regarding persistent organic pollutants, heavy metals, and climate change, while detailing specific impacts such as urban smog, algal blooms in Lake Erie, and the long-term liabilities of contaminated sites and nuclear legacy wastes.

The Center for International Environmental Law (CIEL) argues that the EU is undermining environmental and health protections by securing long-term exemptions for the use of the toxic flame retardant DecaBDE in the automotive and aerospace sectors, and by proposing similar loopholes for biocides and pesticides in its endocrine disruptor criteria.

The document argues that the PMRA has failed to meet legal requirements under the Pest Control Products Act (PCPA) to assess cumulative pesticide risks since 2006. While welcoming the proposed framework, the signatories recommend that cumulative assessments be integrated into individual pesticide registration and re-evaluation decisions, rather than occurring after them. They call for a precautionary approach to grouping pesticides by common mechanisms of toxicity, the inclusion of epidemiological data for outcomes like cancer and endocrine disruption, and the expansion of the framework to cover cumulative environmental risks. Additionally, the authors contest the PMRA's characterization of the 'PCPA factor' as a policy rather than a scientific uncertainty factor and urge for improved monitoring of human and environmental pesticide exposures.

The author contends that the 'Feed the World' narrative used by agribusiness multinationals masks a system that exacerbates hunger and poverty. Industrial agriculture is criticized for destroying the natural resources it depends on, promoting dependency through food dumping and seed monopolies, and contributing significantly to greenhouse gas emissions. The text asserts that food insecurity is primarily caused by poverty rather than structural shortages. It proposes a shift toward endogenous development, intercropping, and agroecology to ensure a resilient, high-quality, and accessible food system.

The report argues that the European Commission and various Member States are undermining the 2013 bans on four bee-harming pesticides, including neonicotinoids and fipronil, by exploiting a legal loophole for 'emergency authorisations'. Analysis of 62 notifications reveals that these authorisations are frequently granted without evidence of a genuine emergency, without considering alternative pest control methods, and are often driven by the pesticide and seed industry. The document highlights Romania as a primary example of this abuse, noting it granted one-third of all EU derogations for neonicotinoids between 2014 and 2016 despite evidence of bee colony losses and a lack of research into sustainable alternatives. The authors call for the Commission to increase transparency, systematically scrutinise notifications, and reject industry-led requests.

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.

Friends of the Earth International criticizes COP 13 for failing to protect biodiversity, alleging that the conference prioritized corporate interests and economic growth over environmental safety and indigenous rights. The organization highlights the continued promotion of harmful technologies like GMOs and pesticides, the erosion of the precautionary principle, and the increasing influence of the private sector through the 'financialization of nature'.

ClientEarth contends that the European Commission is attempting to unlawfully modify the derogation mechanism for endocrine disruptors in pesticides. The organization argues that the approval mechanism is an 'essential element' of Regulation (EC) No 1107/2009, meaning it can only be changed by co-legislators through the ordinary legislative procedure, not by the Commission via delegated powers under Article 290 TFEU. Furthermore, ClientEarth asserts that the Commission's proposed shift toward a risk-analysis-based approach is less protective of human health and the environment than the existing system of limiting exposure to negligible levels.

Community groups Moms On a Mission Hui and Pō‘ai Wai Ola allege that HDOA and ADC have failed to implement Title VI compliance programs, leading to discriminatory adverse effects on Native Hawaiian populations. The complaint highlights the lack of pesticide registration limits, the absence of mandatory buffer zones, and a failure to enforce federal and state pesticide laws. It specifically points to the high concentration of genetically engineered seed crops in West Kaua‘i and Moloka‘i, where Native Hawaiian populations are proportionally higher than the state average. Additionally, the complaint cites ADC's operation of an unpermitted drainage ditch system on the Mānā Plain that discharges pollutants into waters used by Native Hawaiians. The complainants request that the EPA and USDA conduct compliance reviews and require the agencies to develop implementation plans to mitigate these discriminatory impacts.

The Alberta Pesticide Survey Report details a public opinion poll conducted in August 2016. A majority of respondents expressed concern that pesticides used on lawns and gardens pose threats to children (66%), pets (68%), and the general environment (50%). Consequently, 62% of those surveyed supported a law to phase out the use and sale of all but the safest pesticides for lawns and gardens in Alberta, excluding agriculture, forestry, and mosquito control.

The letter argues that the European Commission is ignoring European Parliament recommendations regarding public health, environmental protection, and democratic oversight in TTIP negotiations.

The report concludes that the European Commission failed to follow the European Parliament's recommendations on TTIP, specifically by negotiating in areas with divergent EU-US rules, infringing on the EU regulatory process, and failing to meaningfully reform the investor-state dispute settlement (ISDS) mechanism.