Re: NGO recommendations for the EP vote on ENVI report (Biocide Regulation)
To Members of the European Parliament
NGO recommendations for the EP vote on ENVI report (Biocide Regulation (COM (2009) 0267)), Strasbourg 22 September 2010
Brussels, 21 September 2010
Dear Member of the European Parliament,
On 22 September 2010 you will decide in the first reading about the position of the European Parliament concerning the Commission’s proposal of a biocide regulation which shall replace the current Biocidal Products Directive (Directive 1998/8/EC). The regulation will fundamen-tally change the authorisation system of biocidal products. Among other things biocides, also in nano-form, are used in the area of hygiene, pest control and material protection, in order to control unwanted organisms. Although products like insecticides, disinfectants or textile pre-servatives can be linked to significant risks for humans and the environment they are often applied. Despite the fact that many biocides belong to the group of hazardous chemicals, the current drafts focuses on allowing easy approval of them all over the EU. The signed envi-ronmental and health NGOs believe that the report of the leading Environment Committee does not ensure the protection of consumers and the environment from biocide risks even though it includes some improvements. For this reason and in support of the recommenda-tions of the international scientific network Collegium Ramazzini1 and of the joint position of 20 European NGOs2 we urge you to consider the following amendments:
- Clarify the purpose of the regulation: Protect human and the environment from biocide risks. Article 1 shall be in line with the precautionary principle of the current EU chemical laws (like REACH, Regulation (EC) 1107/2009) and with the general aim of the EU to ensure a high level of protection of human health. Please support amendment 341.
- Encourage comparative assessment and substitution for the development of safer products for children: Problematic products such as developmental neurotoxic and immunotoxic biocides can severely harm the nervous system and brain development of children and cause irreversible, long term damages. Please support the substitution of these products where safer alternatives are available. Consider also non-chemical options and reject attempts to weaken the comparative assessment. Please support amendments 61, 62, 94, 106, 127, 353 and reject amendments 68, 122, 123, 126, 336, 337 D, 339, 340.
- Strengthen the cut-off regime and Member States flexibility: All efforts should be consistent enough in order to phase out highly hazardous biocides in the EU. It is necessary to restrict active substances like with PBT, endocrine disruptive or carcinogenic properties to real cases of emergency and to ensure their proper use. Member States should also have the flexibility to adjust authorizations to their national circumstances. Please support amendments 146, 342, 343, 351, 352
- Establish sufficient data requirements and evaluation criteria for the authorisation scheme in order to ensure that potential hazards and risks of biocides and nano-biocides can be identified as well as combination effects of biocide mixtures. For instance, establish requirement of specific methods to assess the safety of nanomaterials. Please support amendments 88, 89, 97, 200, 203, 204, 272, 323, 324, 329, 346, 347, 348, 354 and reject amendments 245, 251, 260-265, 268, 270-271, 273, 275, 277, 289, 294, 301, 307, 313-315, 356 .
- Guarantee transparency for consumers: All biocidal products and biocide-treated articles should have a sufficient labeling which shall inform about all active ingredients and risks. This is particularly needed for parents to make informed choices about protecting their children. It is all the more necessary since biocide-treated products are numerous and consumers often use them on an everyday basis. We fear that some of the amendments tabled create unnecessary administrative burden and do not lead to clear and transparent labeling rules. Please support amendment 344 and reject amendments 183, 184, 185, 186.
- Initiate EU-provisions and strategies for the sustainable use of biocides: A Community framework for measures and objectives could contribute to minimise risks like of antimicrobial resistances due to overuse, improper use, environmental impacts or accidents. Please support amendments 84 and 221.
Please do not hesitate to contact us in case of any questions. We should be most grateful if you consider our recommendations.
Pesticide Action Network Germany, Christian Schweer (Biocide Coordinator EU)
BBU - Federal Association of Environmental Ac-tion Groups, Harald Gülzow
Det Økologiske Råd, Christian Ege
BirdLife International, Tatiana Nemcova, Boris Barov
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), Jurek Vengels
National Movement Friends of the Earth Bulgaria, Valentina Lukova
Pesticide Action Network UK, Nick Mole (Policy Officer)
PAN Europe, Gergely Simon (board member)
MDRGF, François Veillerette & Angelo San Filippo
Grüne Liga e.V., Bundeskontaktstelle Wasser, Michael Bender
1 Cf. Collegium Ramazzini (2010, 17 September): Control of Biocides in the European Union. The Co legium Ramazzini Calls for Action to Protect Human Health. Hyperlink: http://www.collegiumramazzini.org/d... 2 Cf. NGO recommendations for the ENVI vote on Klaß report (Biocide Regulation (COM (2009) 0267)), Brussels 22 June 2010. Hyperlink: http://www.pan-germany.org/download...
Last updated on 13 June 2011