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Position papers

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Find HEAL’s position papers from all of our activity areas here, we update this page regularly.

The papers are listed chronologically, but you can also search by subject area in the box on the right.

Date Title
26/07/2018 HEAL’s response to public consultation on ambient air quality
19/07/2018 HEAL’s response to public consultation on the 7th Environment Action Programme (EAP)
17/07/2018 HEAL’s response to public consultation on EDC Roadmap
07/06/2018 Industrial competitiveness as ’societal challenge’? Ensuring accountability and societal impact in Horizon Europe
09/05/2018 HEAL’s comments on ECHA’s draft strategic plan 2019-2023
22/02/2018 Public consultation on EDC guidance document - HEAL reaction
01/02/2018 HEAL joins NGO proposal for a protocol on Chemicals in Products
29/01/2018 Benefit assessment methodologies for the LCP BREF implementation (by Mike Holland, EMRC)
03/01/2018 European Commission roadmap on the review of the food contact materials legislation - HEAL’s response to public consultation
02/11/2017 Five EU actions to take Europe Beyond Coal
02/11/2017 HEAL supports position paper which calls for greater civil engagement in defining research priorities EU
03/07/2017 HEAL supports civil society perspective on next EU Research Framework Programme (FP9)
27/06/2017 HEAL supports NGO recommendations on sustainable chemistry
27/06/2017 Health professional societies send joint statement on diesel NOx emissions to members of German Parliament
14/06/2017 HEAL Healthy Energy Paper
10/06/2017 Healthy Energy Position Paper (Czech version)
09/12/2016 EDCs Criteria - Technical Briefing for Member States
05/12/2016 Healthy Energy Position Paper
27/09/2016 HEAL comments to “Overview Report I: A compilation of lists of chemicals recognised as EDCs or suggested as potential EDCs 2016”
12/09/2016 A new Europe for people, planet and prosperity for all
08/09/2016 The Case for Flame Retardant Free Furniture
20/10/2015 Poland: High health costs from public financing for coal power
20/10/2015 Financement pour les centrales à charbon en Pologne – une menace actuelle et future pour la santé
20/10/2015 The threat of increased mercury exposure in the Western Balkans
14/10/2015 Phase Out Amalgam Use in the European Union
29/06/2015 Doctors and public health experts call on French authorities to give greater priority to health at COP21 climate summit
30/04/2015 Joint position paper (HEAL, Eco Forum, WECF): European Environment and Health Process Mid Term Review
01/04/2015 Joint statement: EU trade secrets directive threat to free speech, health, environment and worker mobility
23/03/2015 Joint position paper: Cutting mercury emissions, improving people’s health
10/03/2015 HEAL submission on consultation: Future of the Energy Community
28/02/2015 Joint position paper: Recommendations to clean up air pollution from Medium Combustion Plants
10/02/2015 Statement by 166 civil society organisations on regulatory cooperation in EU-US trade talks
15/12/2014 Cleaner air would offer major health benefits in the Balkans
25/11/2014 Joint position paper on DEHP in PVC plastic
18/11/2014 Joint position paper: Principles for transparency, excellence and independence in scientific advice to EU Commission
31/10/2014 Green10: A New Impetus for Europe: Urgent Actions and Priorities for the new EU Commission
31/10/2014 Joint position paper: Revision of the NEC Directive
28/10/2014 Green 10 position on TTIP
10/10/2014 Green10 statement: President-elect Juncker must do more than a vague commitment to ‘sustainability’
07/10/2014 Green10 reaction: European Parliament should reject Juncker’s environmentally unsustainable Commission
15/09/2014 Green10 appeal: Why the European Parliament should block Jean-Claude Juncker’s attempt to undermine the EU’s environmental policies
12/09/2014 Green10: Why the European Parliament should block Jean-Claude Juncker’s attempt to undermine the EU’s environmental policies
01/09/2014 Green 10 top ten demands for the new European Parliament
25/06/2014 Joint position paper on CO2 standards for power plants
21/05/2014 Joint statement of European Civil Society groups working against the TTIP threat
11/04/2014 EU-US Free Trade Agreement: A Race Down to the Lowest Common Denominator?
07/04/2014 HEAL submission to draft environmental and social policy of EBRD
27/03/2014 HEAL Media briefing: Serious health conditions caused by pesticides in France
12/03/2014 HEAL and CHEM Trust joint briefing: How TTIP could harm our health by affecting chemicals regulation
06/03/2014 Joint contribution to Energy Community Treaty revision consultation
09/01/2014 NGO Assessment of the European Year of Air
17/12/2013 HEAL media briefing: Summary of scientific statements on EDC’s (German)
02/12/2013 HEAL Briefing: What does coal cost health in the United Kingdom?
13/07/2013 Joint NGO comments on review of air policies
07/07/2013 HEAL response to public consultation on 2030 climate and energy package
31/05/2013 NGO comments to EU Commission on review of EU air policies
08/05/2013 Joint NGO comments on review of air policies
03/05/2013 CHEM Trust & HEAL’s view on the report of the ED Expert Advisory Group
25/04/2013 NGOs Position Paper on the EC proposal for a Medical Device Regulation COM(212) 542
11/04/2013 HEAL position paper on the 7th EU Environment Action Programme
02/04/2013 Joint position paper: NGO recommendations: Encouraging 3rd Party participation in the REACH authorisation process
05/03/2013 Joint position paper: NGO priorities for the review of the Thematic Strategy on Air Pollution
30/01/2013 EU vehicle noise emission standards: health evidence and concerns
15/01/2013 HEAL response to consultation on Rio +20
21/12/2012 HEAL submission to the consultation process on the EIB energy lending policy review
23/11/2012 Joint declaration: A Sound Investment to Reduce Vehicle Noise
23/11/2012 Joint statement: Calling EFSA to reform
25/10/2012 HEAL response to public consultation on EU noise policy
20/08/2012 HEAL response to public consultation on an EU strategy on adaptation to climate change
30/05/2012 HEAL reponse to public consultation on 7th EAP
24/04/2012 Joint position statement on shale gas, shale oil, coal bed methane and ‘fracking’
13/04/2012 HEAL response to consultation on chronic disease policy
12/04/2012 Joint Position Paper on new EU vehicles noise limits
02/04/2012 Call on industry to provide substitution case stories
03/02/2012 Joint NGO comments on the analysis underpinning the review of EU air pollution policy review
04/12/2011 COP17: Durban Declaration on Climate and Health
04/12/2011 COP17 Durban: Protecting Public Health From Climate - A Global Call to Action
03/11/2011 HEAL response to the UN Rio+20 consultation
19/10/2011 Joint NGO recommendations for EP ENVI Committee’s 2nd reading on the biocide regulation (COM (2009) 267)
15/04/2011 HEAL Position Paper: Preventing cancer through environmental policy change
08/04/2011 Final assessment of the 6th Community Environment Action Programme: Written Submission on stakeholder consultation
07/04/2011 HEAL Briefing paper: Children’s health and the environment
04/04/2011 Endocrine Disrupting Chemicals under REACH: Four Priority Areas for Regulation
03/04/2011 NGO Position paper: Requirements for the proper regulation of chemicals with endrocrine disrupting properties
15/03/2011 HEAL Briefing paper: Reducing cancer through environmental policy change
15/12/2010 NGO Position paper: Cancun Climate and Health Statement (French)
15/12/2010 NGO Position paper: Cancun Climate and Health Statement (ENGLISH)
15/12/2010 NGO Position paper: Cancun Climate and Health Statement (SPANISH)
13/09/2010 NGO Position paper: Sixtieth session of the WHO Regional Committee for Europe
12/03/2010 NGO Interventions: WHO Fifth Ministerial Conference on Environment and Health
15/02/2010 NGO Position Paper on RoHS revision
30/10/2009 Green 10 Position paper:
Nature and health briefing for the Parliament
22/12/2008 HEAL Position paper: Cancer Prevention and the Environment - examples and opportunities for national and EU policy makers
24/06/2008 NGO Position paper: Climate change and health - Engaging the regions Conference Recommendations
15/04/2008 Green 10 Position paper: Sustainability - Our vision for a new EU budget
15/04/2008 Green 10 Position paper: Ten green principles for the EU budget review
13/02/2008 NGO Consultation response: RoHS Directive - technical changes to the scope of the directive, definitions and facilitating implementation
15/12/2007 HEAL Consultation response: European Commission Green Paper on Climate Change 2007
15/09/2007 NGO Position paper: Pesticides and health
15/07/2007 HEAL Consultation response: Response to EC consultation on access to documents
12/02/2007 HEAL Consultation response: discussion document for a health strategy – “Health in Europe: a strategic approach”
31/08/2006 HEAL Consultation response: the European Transparency Initiative (ETI) Green Paper
11/05/2006 HEAL Position paper: EU thematic strategy and air quality health limit values
15/03/2006 NGO Position paper: Priorities for REACH second reading (ES)
15/03/2006 NGO Position paper: Priorities for REACH second reading (EN)
15/03/2006 NGO Position paper: Priorities for REACH second reading (FR)
28/02/2006 Green 10 Position paper: The creation of a high level group on competitiveness
13/07/2005 Green 10 Position paper: A revised sustainable development strategy for the EU
16/06/2005 HEAL Position paper: Community strategy concerning mercury
16/05/2005 HEAL Position paper: EU climate change and health
16/03/2005 NGO Position paper: Five key demands to improve REACH
16/02/2005 Green 10 Position paper: Policy challenges and budgetary means of the enlarged union 2007 - 2013
16/12/2004 HEAL Position paper: Children´s special health vulnerability to environmental hazards and REACH
03/12/2004 HEAL Position paper: ‘The European Environment & Health Action Plan 2004-2010’
25/11/2004 HEAL Consultation response: ‘The European Environment & Health Action Plan 2004-2010” (full version)
16/11/2004 Green 10 Position paper: The EU’s new Constitution - assessing the Environmental Perspective
16/10/2004 HEAL Consultation response: ‘The European Environment & Health Action Plan 2004-2010” (short version)
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The Health and Environment Alliance (HEAL) is the leading not-for-profit organisation addressing how the environment affects human health in the European Union (EU) and beyond. HEAL works to shape laws and policies that promote planetary and human health and protect those most affected by pollution, and raise awareness on the benefits of environmental action for health. 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 »

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