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Twelve Public Health and Environment NGOs Share Concerns On BPA and DEHP Ahead Of REACH Committee

HEAL is disappointed at the EU REACH Committee’s decision to grant EDC phthalate DEHP the green light for use in recycled PVC goods like vinyl flooring. Prior to the vote, HEAL joined a multi-NGO open letter urging its rejection, stating that this authorisation undermines REACH’s aim to replace toxic substances with safer alternatives. The letter also covers BPA in thermal paper.

Brussels, 15th April 2016

Dear Sir/Madam,

We would like to share with you our views with regard to two decisions regarding the exposure of people and the environment to two endocrine disrupters, BPA and DEHP, that will be discussed during the next REACH Committee in Brussels on 20 April. These decisions will have particular implications for vulnerable populations such as babies in the womb, young babies and children.

Restriction of the use of BPA in thermal paper

The restriction proposal presented by France to ban the use of BPA in thermal paper will be on the agenda for discussion. It is important that member states make clear at this meeting their support for this restriction so that it can be brought to a vote as soon as possible.

The intention is to reduce BPA exposure in the general population, but especially in workers, such as cashiers, who regularly handle thermal receipts. Since the greatest risk is to the developing foetus, the proposed restriction is also targeted at reducing BPA exposure for women who are or may be pregnant.

ECHA’s Committee for Risk Assessment (RAC) broadly agreed with France’s conclusion that BPA may affect the liver, the kidney, and have other adverse effects on reproduction, on the mammary glands (breast cancer), the immune system, metabolism and neuro-behavioural development. However, it disagreed with the approach used by France to calculate the risks and carried out its own estimations, concluding that while the risks to consumers are adequately controlled, those to workers are not. We consider that RAC’s assessment of the risk to consumers is not correct (see reasoning in attached briefing).

SEAC re-evaluated the cost-benefit assessments submitted by France and concluded that the “restriction of BPA in thermal paper is considered unlikely to be proportionate”. In other words, the costs of the proposed restriction to industry may outweigh the monetised benefits to society. However, this conclusion depends strongly on the substitutes used after the restriction and on their costs. Furthermore, SEAC pointed out that it did not attempt to quantify all benefits to society, hence it underestimated the societal benefits of the restriction. We consider that SEAC has conducted a very poor estimate of the true costs and benefits of the proposed restriction (see reasoning in attached briefing).

SEAC found the proposed restriction to be affordable, in the sense that industry can afford to pay the cost of changing to safer alternatives since it would involve an estimated price increase of no more than €0.05-0.18 to each roll of thermal paper, or €4–15 per year per cashier. SEAC also noted that “there may be favourable distributional and affordability considerations” since the proposed restriction is expected to reduce the risks for the disproportionately exposed group (pregnant cashiers), while sharing the costs broadly across the entire EU population.

In short RAC and SEAC agreed that EU-wide action is justified, and that the proposed restriction is implementable, enforceable, manageable, and monitorable, even if they were more dismissive of the benefits than we believe is merited.

Breast cancer accounts for the highest health-care costs (€6.73 billion or 13%) of all cancer-related healthcare costs in Europe. It is hard to imagine that any citizen of the EU would not pay €0.1–€0.2 per year to stop girls being exposed to BPA in their mothers’ wombs and thereby potentially avoiding them having to suffer breast cancer later in life. Indeed, there is already a strong preference among consumers for products labelled as “BPA-free.

Authorisation of the use of DEHP in recycled consumer articles

The Commission has presented a reviewed proposal to grant authorisation to Vinyloop Ferrara, Stena Recycling and Plastic Planet to use DEHP in recycled soft PVC-containing articles. The new proposal imposes stricter conditions on these companies in order for them to reapply for authorisation after the review period. It obliges downstream users to make monitoring and biomonitoring information available to ECHA before 31 December 2016. The proposed review period expires on 21 February 2019.

However, granting authorisations for these applications would still not be in keeping with the provisions of Title VII of REACH, in particular Articles 60, 62 and 64 of REACH as:

- The risks related to the uses of DEHP are not adequately controlled.

- There are suitable alternative substances and technologies.

- The applicants did not demonstrate that the socio-economic benefits of continued use outweigh the risk to human health or the environment.

Granting an authorisation that does not meet the requirements established by REACH would not only breach the Regulation but would also establish a very negative precedent that would compromise upcoming decisions and undermine the aims of the REACH Regulation.

Therefore, we would ask you to support the restriction of the use of BPA in thermal paper and to reject the Commission’s proposal to grant authorisation for the use of DEHP in consumer articles made with recycled PVC.

Yours faithfully,

Jeremy Wates,
Secretary General of the European Environmental Bureau

On behalf of:

Armenian Women for Health and Healthy Environment (AWHHE)

Breast Cancer UK


CHEM Trust

Danish Ecological Council


Ecologistas en Acción

European Environmental Bureau (EEB)

Health and Environment Alliance (HEAL)

Swedish Society for Nature Conservation (SSNC)

Wemos Foundation

Women in Europe for a Common Future (WECF)

Other resources:
A similar coalition of NGOs also voiced their concerns regarding these endocrine disrupting chemicals in a letter to Member State representatives earlier this month (

Last updated on 26 April 2016

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