The EU chemicals strategy for sustainability : critical reflections on proposed regulatory changes for endocrine disruptors and mixture toxicity

Abstract

Currently, the European Commission is pursuing a new "Chemicals Strategy for Sustainability" (CSS) (COM (2020) 667 final). This strategy is part of the European 'Green Deal'. As scientists, we support the European Chemicals Strategy for Sustainability and therefore welcome the efforts to further increase the protection of human health and the environment from hazardous chemicals and to promote innovations for the development of sustainable chemicals. However, some of the anticipated actions would have far-reaching regulatory consequences of questionable added value and that need to be discussed (also see recent considerations in Herzler et al. 2021 and Barile et al. 2021).

In particular, two issues are critical from the perspective of scientists working in the field of human toxicology. These two issues concern (i) substances with endocrine effects and (ii) the question of how to deal with combination effects of chemicals, i.e., mixture toxicity.