Dec. 7, 2017
Canada submitted a document to the WTO on 17 November, expressing it concern about the EU's proposed criteria for identifying compounds as Endocrine Disruptors.
In the document, Canada argues, “hazard-based cut-offs, without giving any consideration to exposure or without performing a complete risk assessment, can unnecessarily restrict trade. There is a growing number of examples where active ingredients are prevented from going through the re-authorization process in the EU based on hazard-based cut-offs, such as glufosinate ammonium, and now possibly propiconazole.”
“Even more concerning is the hazard-based approach to regulatory decision-making once a compound is identified as an endocrine disruptor, or meets other hazard-based cut-offs, such as for reproductive toxicants. Such European Chemical Agency classification decisions trigger regulatory non-approval and default maximum residue limits (MRLs), regardless of actual risk, in the opinion of the European Food Safety Authority,” said in the document.
Canada would agree that the hazard identification of a chemical is an important first step in the scientific risk assessment framework. However, they think it is even more imperative that potential adverse effects be put into context with consideration of potency, and the level of likely human and environmental exposure based on the conditions of use.
More broadly, Canada seeks concrete assurance from the EU that decisions on setting MRLs and import tolerances will continue to be made on the basis of complete risk assessments, as set out in Regulation 396/2005.
Canada urges the EU to take its international trade commitments into account when determining its approach to setting import tolerances, for the categorization of compounds as endocrine disruptors, and for establishing all import tolerances.