On November 8, 2019, a group of 24 non-governmental organizations sent a letter addressed to the incoming president of the European Commission, Ursula von der Leyen, to act on hazardous chemicals. Led by the European Environmental Bureau, the letter highlights what the organizations see as shortcomings by the European Union (EU) to act on chemical pollution and the continued use of hazardous substances. The letter says that “Europe has rightly charted a course towards a circular economy,” however, “harmful and even banned chemicals are increasingly found in consumer products made from recycled content, including toys, frequently because firms do not know the chemicals content of the materials they are handling.” The signatories further say that “the EU strategy to address endocrine disrupting substances (EDCs) is now 20 years old. Yet the Commissions [have] largely failed to deliver on the commitment to manage the risks from these chemicals.”

On the REACH regulation, the organizations note that it was set up to help “phase out 1,400 of the most dangerous substances and to provide a powerful spur for firms to develop less harmful alternatives.” However, after more than a decade with REACH regulation already in place, “only 43 [substances] are subject to authorization while the almost blanket authorizations being granted by the EU of continued use of substances of very high concern (SVHCs) is disincentivizing the use of safer alternatives. Furthermore, some of these SVHCs such as phthalates are currently allowed in food contact materials.”

The letter specifically calls on the incoming Commission to prioritize three “zero pollution goals in the sphere of chemicals.” These include: (i) making the EU the global leader of a non-toxic circular economy and sustainable innovation through full disclosure of chemical composition in products and promoting restrictions on families of chemicals, (ii) protecting vulnerable populations by preventing chemicals with severe and long-term effects from entering the market and environment, and (iii) taking action on early warning signs of chemical pollution and holding polluters accountable.

The letter includes a technical annex that further outlines the demands. “Promises of sustainability while business continues as usual is not an option,” the letter reads. “The EU needs to be more specific on what a strategy is aiming for, and to clarify that this includes moving towards reducing exposure to hazardous chemicals, to phase out and substitute the most problematic ones and support research and innovation towards safer alternatives.”

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EEB (November 8, 2019). “Biggest ever human screening for toxic chemicals in Europe.”

Clelia Oziel (November 12, 2019). “NGOs outline ‘urgent’ actions needed for EU zero-pollution goal.” Chemical Watch


EEB (November 8, 2019). “A chemicals strategy as part of the European Green Deal: time to deliver.”