In an article published on July 16, 2020, non-governmental organization (NGO) Health and Environmental Alliance (HEAL) reported on a leaked draft document from the European Commission (EC) outlining the upcoming chemicals strategy for sustainability. The story was originally covered by Le Monde.

Drafted by the EU’s Directorate-General for the Environment (DG Environment), the chemicals strategy was proposed to include an action plan on per- and polyfluoroalkyl substances (PFAS), a framework on endocrine disrupting chemicals (EDCs), new hazard classes to manage environmental toxicity, endocrine disruption, persistency, and mobility, as well as application of a new mixture assessment factor for use in risk assessments to consider the mixture toxicity of combined exposures.

However, visible comments on the draft made by representatives from the EU’s Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG Grow) make it very clear that there are strong disagreements within the EC on many of the aspects being proposed in the strategy. Overall, DG Grow called for the wording in the communication to be “less definitive and committing” and to also change it to be more “enabling” and “inviting.” The organization also called for considering product-specific legislation and a strategy to shift away from animal testing. It also clearly communicated that it does not support the use of a mixture assessment factor and argued that proper discussion has not yet been completed.

NGOs are finding the draft document concerning. The Corporate European Observatory writes that the comments in the document by DG Grow “reflect the industry concern that the DG Environment draft as it stands would disrupt their sales of toxic chemicals, and the document provides clear evidence of DG Grow championing the views of industry over the public interest.” HEAL writes that they call “on President Von der Leyen and Vice-President Timmermans to guarantee that the strategy being developed lives up to the Commission’s commitments towards the zero pollution ambition for a toxic-free environment and improved health. The new strategy must provide an honest picture of the current scientific evidence about all health and environment effects of chemicals and put forward provisions to effectively address them.”

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HEAL (July 17, 2020). “Revealed European Commission frictions over the Chemicals Strategy for Sustainability – HEAL’s concerns for health protection.”

Corporate Europe Observatory (July 16, 2020). “Chemical industry cheerleader: how DG Grow puts industry above public interest regulation.”

European Environmental Bureau (July 16, 2020). “Chemicals cheerleader: how DG Grow puts industry above public interest regulation.”

Clelia Oziel (July 16, 2020). “DG Grow draws battle lines on draft EU future chemicals strategy.” Chemical Watch

Stéphane Mandard (July 16, 2020). “Produits chimiques: bataille au sein de la Commission sur la nouvelle « stratégie durable ».” Le Monde

HEAL (July 24, 2020). “Re: Time to ensure that the Chemicals Strategy for Sustainability delivers a toxic-free environment.” (pdf)

Kathryn Carlson (July 28, 2020). “DG Grow blasted for ‘undermining’ draft EU chemical strategy.” Chemical Watch

Luke Buxton (July 29, 2020). “Industry fears ‘root and branch’ REACH reform in EU chemical strategy.” Chemical Watch

Kathryn Carlson (September 10, 2020). “DG Grow, Cefic outline views on chemicals strategy as final talks take place.” Chemical Watch


EC (July 2020). “Draft: Communication from the Commission to the European Parliament, the Council, and the European Economic and Social Committee and the Committee of the Regions – Chemicals Strategy for Sustainability.” (pdf)