By Erik Millstone and Peter Clausing
European Journal of Risk Regulation (2023), 1–15
doi:10.1017/err.2022.41
Abstract
The European Commission’s 2020 draft Chemicals Strategy for Sustainability set the ambitious goal of
achieving a “Toxic-Free Environment”. Those ambitions were harshly criticised by a team based in
Germany’s Federal Institute for Risk Assessment (or BfR); they claimed that toxicological risks from
chemicals had already been minimised and were optimally regulated. This paper outlines evidence to
support the Commission’s implication that the European Union’s chemicals regulatory regime is suboptimal.
It also criticises the BfR team’s contentions by reference to empirical findings (eg concerning
tumours, congenital anomalies and the toxicity of mixtures) and by disentangling their
conceptual confusions.