Contribution to the European Commission’s Public Consultation on Defining criteria for identifying Endocrine Disruptors in the context of the implementation of the Plant Protection Product Regulation and Biocidal Products Regulation

The American Chemistry Council (ACC) 1 is pleased to provide the following comments on the EC’s Public Consultation on “Defining criteria for identifying Endocrine Disruptors in the context of the implementation of the Plant Protection Product Regulation and Biocidal Products Regulation” (the “Consultation”). While the Consultation addresses defining the criteria for identifying endocrine disruptors (EDs) for purposes of plant protection and biocidal product regulations, ACC understands the proposed criteria could set a precedent for other EU regulatory programs. 2 ACC is also concerned that certain proposed EC approaches for identifying EDs, including the proposed regulatory categorization of ED chemicals, would trigger unnecessarily negative and far-reaching impacts on global commerce. These comments address those concerns and suggest approaches for minimizing unwarranted negative trade impacts and improving U.S.EU regulatory cooperation.