main banner
You are here: Home page » Resources » Letters

Joint NGO letter on the 7th EAP to EU environment ministers

To: EU Environment Ministers

5 April 2012, Brussels

Dear Minister of Environment,

Our thirteen organizations are writing to you ahead of the informal meeting of EU Environment Ministers on 17-19 April, to ask you to include measures to address endocrine disruptors (EDCs), chemical mixtures and nanomaterials, as well as a better protection from substances of very high concern (SVHC) in the 7th Environment Action Programme (7th EAP). Recent studies have brought to light alarming evidence showing that urgent action is needed to protect human health and the environment, and public concern continues to be high across the EU. As Environment Minister we ask you to raise these concerns at the April meeting, in order to promote a healthy environment and healthy communities.

We are highly concerned about the lack of protection for wildlife and human health due to exposure to EDCs, chemical mixtures, SVHCs, and nanomaterials. Such exposures particularly threaten development in early life and exposure to mixtures of EDCs, in particular, are considered to contribute to the alarming trends in many diseases.

It is critical that the future 7th EAP contains concrete and time specific targets, clear objectives, and solution oriented policy recommendations. The 7th EAP should close existing loopholes and provide for better enforcement of existing regulation. In the Annex you may find further information on these four crucial issues.

In asking you to ensure that these issues are addressed within the 7th EAP, we do not wish to imply that all action on these topics should await the adoption of the 7th EAP. On the contrary, we consider that certain steps should be taken more urgently, such as the prevention of exposures to hazardous chemicals trough national and EU measures.

However the 7th EAP should establish a longer term framework for ensuring that the new scientific findings are fully taken up through the development of specific measures relating to emerging health threats, such as combination effects of chemicals, EDC, SVHC, and nanomaterials. These issues are far from being sufficiently addressed under current EU legislation.

We ask you to strongly support these issues and raise them at the informal ministers meeting to ensure that the 7th EAP will protect public health and the environment by swiftly preventing and reducing exposures to hazardous chemicals and making sure the EU will be the front-runner in delivering substitution with better alternatives for both human health and for the environment.

In view of the public interest in this matter, we intend to make the contents of this letter more widely available. Thank you for your attention to the matters raised in this letter.

Yours sincerely,

  • WECF – Women in Europe for a Common Future, Sascha Gabizon, International Director
  • HEAL – Health and Environment Alliance, Genon Jensen, Executive Director
  • EEB – European Environmental Bureau, Jeremy Wates, Secretary General
  • PAN-Europe (Pesticide Action Network), Hans Muilerman, Chemicals Officer, Pesticides & Alternatives
  • ClientEarth, James Thornton, Chief Executive Officer
  • Health Care Without Harm Europe, Anja Leetz, Executive Director
  • ChemSec – International Chemical Secretariat, Anne-Sofie Andersson, Director
  • CHEM Trust (Chemicals, Health and Environment Monitoring Trust), Gwynne Lyons, Director
  • RES – Réseau Environnement Santé, André Cicolella, Président et porte-parole
  • Swedish Society for Nature Conservation, Mikael Karlsson, President
  • The Danish Ecological Council, Eline Aggerholm Kristensen, Policy officer – chemicals
  • CCOO, Comisiones Obreras, Carlos Martínez Camarero, Confederal Environment Secretariat
  • Bund für Umwelt und Naturschutz Deutschland (BUND), Patricia Cameron, Head of Substances and Technologies

Endocrine Disrupting Chemicals (EDCs)

Endocrine disruptors are a major environmental health threat. There is a growing body of science which links many harmful human health effects with EDC exposure, such as hormone-related cancers (breast, testicular, prostate), obesity, diabetes, cardiovascular diseases, reproductive health problems and disrupted human brain development. The recent report on the State of the Science on EDCs [1], published by the EU Commission provides alarming evidence that the negative impacts of EDCs are currently being underestimated and that EU legislation is currently not properly addressing this problem. The report highlights the shortfalls in existing test methods but also outlines a way forward.

Chemicals Mixtures

Every day we are exposed to a mixture of synthetic chemicals, via the air we breathe, the food we eat and the water we drink. And even when the exposure to individual chemicals is below the level where they cause an effect by themselves, new science is now showing that together they can ‘add up’ and cause a potentially dangerous “cocktail effect”.

The State of the Art report on mixtures toxicity (Kortenkamp et al, Dec. 2009), commissioned by the European Commission’s DG Environment, states that “there is a consensus in the field of mixture toxicology that the customary chemical-by-chemical approach to risk assessment might be too simplistic. It is in danger of underestimating the risk of chemicals to human health and to the environment”. Current Risk Assessment approaches need urgent revising.


Nanomaterials can be found in a wide range of everyday products such as cosmetics, clothes, sports equipment, paints, food packaging and additives. Because of their novel properties, nanoparticles may present unique risks for human health and the environment. Potential toxicity and ecotoxicity of certain nanoparticles includes damage to DNA, damage to foetal development due to transfer via the human placenta, asbestosis-like diseases and damage to aquatic and terrestrial organisms. The safety tests performed on ‘bulk’ materials are not appropriate for extrapolating to the ‘nano’ level, leaving safety levels unpredictable.

The current EU legislative framework is failing to address the risks posed by nanomaterials. REACH does not contain any nano-specific provisions regarding threshold, data requirement, safety assessment or the traceability of nanomaterials [2]. Despite strong pressure from civil society groups, from the European Parliament and a few Member States, the European Commission still refrains from proposing new, adequate tools that would ensure the safe production, use, and end-of-life treatment of nanomaterials. Now that a definition of the term “nanomaterial“ has finally been proposed, the Council must ask the European Commission to take action without further delay.

Substances of very high concern (SVHC) in REACH

REACH is a great achievement in chemicals management in the EU. However it has some gaps that urgently need to be addressed, in particular the slow pace of implementing the provisions on Substances of Very High Concern (SVHC). We therefore call on you to include in the 7th EAP an affirmation of the policy goal to have by 2020 all “known and suspected” SVHC substituted. It should ensure that sustainable chemistry (and its use) be promoted, in line with the resource efficiency agenda, and that economic instruments be introduced, e.g., a SVHC self-financing mechanism at no cost to government to support achieving objectives in line with the polluter pays principle. Additionally it is necessary to address the gaps in product legislation regarding SVHC. These concerns follow the current 6 EAP goal that “by 2020 chemicals are only produced and used in ways that do not lead to a significant negative impact on health and the environment”.

1 See:

2 See CIEL report “Just out of REACH – How REACH is failing to regulate nanomaterials and how it can be fixed”, available at:

3 Policy makers agreed at the 2002 Johannesburg World Summit on sustainable development that the European Union shall achieve by 2020 that chemicals are produced and used in ways that lead to the minimisation of significant adverse effects on human health and the environment. This political commitment to implement substitution of SVHC by 2020 at the latest is re-affirmed in recitals 4 and 6 of the REACH Regulation.

4 Sustainable use of "sustainable" chemicals aims at providing necessary functions for society as a whole whilst preventing, or where not feasible, minimise negative environmental and health impacts throughout its lifecycle, such as linked to resource consumption and avoidance of hazardous substances. Constant improvements through research and innovation will not only bring advantages to the "knowledge based" EU industry to be leader in sustainable market models, but also protect our workers, consumers and the environment. For more information please consult the EEB/BEUC discussion paper "The path to sustainable use of chemicals in products: the European Ecolabel as a signpost"

5 The concept is a self-financing mechanism with no cost to the government, that operationalises the polluter pays principle by incorporating external costs, drives the solution of substitution while providing solution resources, and saves the government public tax revenue. The result would be a significant financial gain for the government due to no governmental costs, and massive savings through reduced human health costs, and environmental measures/costs. SVHC manufacturers would be subject to a minimal fee, increasing over time, to provide incentives and resources for research, development and implementation for substitute alternative substances that are non- or less-hazardous. The proceeds would go to a “SVHC solutions” fund administered by a government agency.

Last updated on 24 April 2012

About HEAL

The Health and Environment Alliance (HEAL) is a leading European not-for-profit organisation addressing how the environment affects health in the European Union (EU). We demonstrate how policy changes can help protect health and enhance people’s quality of life. Read more »


HEAL has over 70 member organisations, representing health professionals, not-for-profit health insurers, doctors, nurses, cancer and asthma groups, citizens, women’s groups, youth groups, environmental NGOs, scientists and public health institutes. Members include international and Europe-wide organisations, as well as national and local groups. Read more »

Contact us

Health and Environment Alliance (HEAL)
28 Boulevard Charlemagne
B1000 Brussels, Belgium
Phone: +32 2 234 3640
Fax: +32 2 234 3649
Press: Elke Zander

Direct telephone numbers: HEAL team page.

HEAL website privacy policy