To: Members of the Council Working Group for Environment.
Re. Joint NGO recommendations for the forthcoming considerations of Council Working Group for Environment concerning the biocide regulation (COM (2009) 267)
Joint NGO recommendations for the forthcoming considerations of Council Working Group for Environment concerning the biocide regulation (COM (2009) 267)
Brussels, 12 October 2010
Dear Members of the Council Working Group for Environment,
You are currently discussing the Commission’s proposal for a biocide regulation (COM (2009) 0267), which was recently voted on by the European Parliament in first reading. This act proposal will revise the current Biocidal Products Directive 98/8/EC and establish new provisions for the authorisation and use of, for example, disinfectants, preservatives, products for pest control and other biocidal products.
Pesticide Action Network (PAN) Germany, BUND/ Friends of the Earth Germany, Fédération Inter- Environnement Wallonie, Health and Environment Alliance (HEAL), Health Care Without Harm Europe (HCWH), National Movement Friends of the Earth Bulgaria, PAN Europe, PAN UK and Women in Europe for a Common Future (WECF) welcome the revision of the biocides legislation, but see an urgent need to improve the current European Commission draft, the European Parliament resolution as well as the relevant suggestions of the former Council Presidency in order to ensure the protection of the environment and human health against hazards and risks stemming from the use of biocidal products.
While taking into account our key NGO demands and recommendations on the biocide regulation, we suggest highlighting the following issues in view of the coming Council Environment Working Group considerations on this dossier:
- Ensure a consistent and enforceable cut-off regime without unnecessary loopholes on EU and on national level.
- Guarantee a sufficient substitution regime and consider non-chemical measures and preventive measures within the comparative assessment.
- Ensure the protection of vulnerable groups from hazardous biocides and the substitution of developmental neurotoxic and immunotoxic biocides.
- Confirm appropriate labelling provisions for all treated articles.
- Support consistent measures for the sustainable use of biocides.
- Demand for consistent data requirements for evaluation and authorization.
- Confirm a sufficient low-risk approach to promote less hazardous alternatives.
- Facilitate consistent measures concerning nano-biocides. We provide more details in our comments and recommendations attached.
Please do not hesitate to contact us in case of any question. We should be most grateful if you consider our recommendations.
Pesticide Action Network Germany Christian Schweer (Biocide Coordinator EU)
Health and Environment Alliance Anne Stauffer
Health Care Without Harm Europe Anja Leetz
Fédération Inter-Environnement Wallonie Valérie Xhonneux
Women in Europe for a Common Future Elisabeth Ruffinengo (Advocacy Officer)
Bund für Umwelt und Naturschutz Deutschland e.V. (BUND) Friends of the Earth Germany
National Movement Friends of the Earth Bulgaria Valentina Lukova
Pesticide Action Network UK Nick Mole (Policy Officer)
Tony Tweedale, M.S.
Uppsala University hospital Clinical Microbiology, Eva Haxton
PAN Europe Gergely Simon (board member)
Last updated on 13 June 2011