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Dear MEP,

As a membership network of over 70 public interest organisations aiming to promote and protect people’s health through environmental action, the Health and Environment Alliance (HEAL) would like to thank the Environment Committee for looking critically at the European Commission proposed identification criteria for endocrine disrupting pesticides.

Today, we are urging you to reject these criteria, which we and millions across Europe believe will jeopardize our health, when you vote on September 28th.

HEAL, alongside international scientific societies, major public health voices such as non-profit health insurers representing 200 million Europeans and the European cancer leagues, as well as hundreds of public interest groups, have been very critical of this proposal, which will leave people highly exposed to toxic chemicals and consequently at a higher risk of serious health problems such as hormonal cancers, infertility and developmental disorders. This is all the more disappointing as there is a significant public health and fiscal opportunity to reduce the economic burden arising from such diseases – which is estimated to be of at least 163 billion euros in the European Union every year. Our concerns are shared by almost half a million European citizens, who have signed a petition in rejection of the proposal on the table.

The proposed European Commission identification criteria for endocrine disruptors are far from delivering the ambitious approach that we need to address this public health and economic challenge (1).

We ask you to use your right to reject the European Commission proposal for the following reasons:

- 1. The burden of proof requested in the European Commission proposal is so high that it will make it nearly impossible to identify a pesticide as an endocrine disruptor, leaving hundreds of toxic chemicals off the hook. Failure to identify endocrine disruptors will delay regulatory actions in order to ban or phase out those chemicals, when people and workers are exposed to them every day and urgent action is needed.

- 2. The European Commission proposal introduces an unlawful exemption for substances designed to have an endocrine mode of action (Annex of the proposal, point 2, final paragraph – proposed exemption for non-target organisms). This exemption is equivalent to “de-identifying” substances that technically qualify as endocrine disruptors, and therefore constitutes an illegal derogation, whereby the European Commission is exceeding its mandate to establish science-based criteria for identification (2).

In making up your mind, please consider the real-life impacts of the ill-designed identification of endocrine disruptors. These not only include the adverse health impacts detailed above and the associated burden of addressing these for public budgets, but they also mean a huge toll on the European current and future workforce at a time of severe economic and planetary crisis.

We remain available for any question that you might have, including through a face-to-face meeting.

Yours sincerely,

Ms. Génon K. Jensen, Executive Director
Health and Environment Alliance (HEAL)


1. HEAL editorial:

2. See ClientEarth and CIEL legal analyses of the proposed criteria:

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