In a commentary published online on July 22, 2021, in the peer-reviewed journal Archives of Toxicology, Matthias Herzler and co-authors from the Federal Institute for Risk Assessment (BfR), Berlin, discuss selected aspects of the European Chemicals Strategy for Sustainability (CSS, FPF reported) from their perspective as employees of the German risk assessment agency. The commentary focuses on consumer health protection in connection with chemical and product safety regulatory approaches.

In the guest editorial, the eight co-authors allege that chemical risk assessment experts have not been involved in the development of the CSS, nor were they represented in expert committees accompanying the Strategy’s implementation. For instance, the authors are of the opinion that the publicly perceived risk of chemicals present in everyday products has been translated into regulatory action without convincing scientific facts and evidence underpinning these, in their view, unfounded concerns. The authors believe that such regulatory action has limited effectiveness to protect public and environmental health and, in addition, may waste time and effort, lead to disappointment, and belittle the authorities’ scientific credibility.

Some members of the international scientific community supported the position of the BfR employees in a letter to the editor published online in Archives of Toxicology on August 7, 2021. Several of these authors have known ties to the chemical industry (FPF reported) and have involved themselves in chemical regulation at EU level in the past, creating controversies (FPF reported). The CSS was launched in October 2020 as part of the European Green Deal with the aim to increase the protection of humans and the environment against hazardous chemicals (FPF reported). The Food Packaging Forum (FPF) hosted a webinar series discussing the challenges and opportunities of the CSS for food contact materials (FPF reported) that is  available online (here).

The news provider Chemical Watch consulted NGOs and an expert on the risk assessment of chemical mixtures that rejected the BfR employees’ criticism. In the Chemical Watch article Ninja Reineke (CHEM Trust) highlighted that “it is wrong to suggest that the strategy is not based on science.” Scientific institutions in the EU such as the Joint Research Council (JRC) have recommended the tools included in the CSS. Tatiana Santos (European Environmental Bureau) said that the authors of the editorial defended “outdated traditional risk assessment models, partially ignoring scientific evidence.” And Olwenn Martin (Brunel University London) commented that “The onus ought to be instead on demonstrating safety, not harm.”



Herzler, M., et al. (2021). “The “EU chemicals strategy for sustainability” questions regulatory toxicology as we know it: is it all rooted in sound scientific evidence?.” Archives of Toxicology. DOI: 10.1007/s00204-021-03091-3

Barile, R. A., et al. (2021). “The EU chemicals strategy for sustainability: in support of the BfR position.Archives of Toxicology. DOI: 10.1007/s00204-021-03125-w

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Chemical Watch (July 15, 2021). “BfR: ‘Inherent scientific shortcomings’ hampering EU chemicals strategy.