Yannick Vicaire, Chemicals Policy Officer of the Réseau Environnement Santé and Vice president of the Health and environment Alliance, two NGOs, comments in an article published in the online magazine Health & Environment that it takes a long time from the identification of an endocrine disrupting chemical (EDC) to its ban. He argues that firstly the insufficient data requirements and tests under the European Registration, Evaluation, Authorisation and Restriction of Chemical substances (REACH) legislation do not allow efficient identification of EDCs. Secondly, he states, evaluation is limited by the budget of the European Chemical Agency and member states. Thirdly, chemicals for which adequate control can be proven are allowed for use irrespective of their endocrine disrupting properties. Finally, an EDC may be authorized because the socio-economic evaluation concludes that the advantages of its use outweigh the disadvantages. Vicaire reasons that considering the obstacles in the way of banning an EDC, the definition of an EDC should be broad, seemingly hinting at the more limiting definition recently advocated by the European Food Safety Authority (EFSA).
While REACH is not applicable to the food contact end product, it is still relevant for the production, transport and environmental impact of substances used in food contact materials. Substances that are used in food contact materials may also require registration under REACH for their use in other consumer products.