G/TBT/W/550  
6 July 2018 
(18-4266) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  Spanish  
 
  
EUROPEAN UNION – REVISED PRO POSAL FOR THE CATEGORIZATION  
OF COMPO UNDS AS ENDOCRINE DISRUPTORS OF  
19 FEBRUARY 2013 BY DG ENVIRONMENT  
STATEMENT BY ARGENTINA TO THE COMMITTEE ON  
TECHNICAL  BARRIERS  TO TRADE , 
20 AND 21 JUNE 2018  
The following communication, dated 6 July 2018, is being circulated at the request of the 
delegation of Argentina . 
 
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1.  Argentina wishes to refer once again to the EU's policy on pesticides , in order to reiterate its 
concerns with respect to the approach taken by the EU for identifying substances with 
endocrine -disrupting properties.  
2.   In this regard, on 2 0 April 2018 Regulation (EU) 2018/605 , amending Annex II to 
Regulation  (EC) No. 1107/2009 by setting o ut scientific criteria for the determination of 
endocrine -disrupting properties , was published in the Official Journal of the EU . Its provisions will 
be applicable as from 1 0 November  2018. 
3.  As has been reiterated on a number of occasions, it is within the rights of each WTO Member to 
ensur e a high standard of protection for human health and the environment ; however, this right is 
not unlimited and has to be exercised within the framework of multilateral commitments . In this 
sense, it is necessary that the m easures adopted be based on a full risk assessment  and not solely 
on "hazard" identification, without even considering potency as a factor in characterizing 
the hazard.  
4.   With the approval of Regulation (EU) 2018/605, the EU has chosen the most restrictive 
alternative in terms of commercial and agricultural impact, ruling out  options that would have been 
less restrictive  while at the same time ensur ing the same level of protection of human health, as is 
shown by the European Commission's own impact assessmen t. In the light of the provisions of 
the TBT Agreement, in particular Article 2.2, we wish to underscore the obligation for every 
WTO Member to refrain from creating unnecessary obstacles to international trade when pursuing 
legitimate objectives, such as the protection of human health and the environment . 
5.  We also wish to refer to the Commission's pro posal relating to "derogations", work on which 
was suspended pending approval of the "criteria" . The latter having been approved on 
19 April 2018, we wish to c onsult the Commission as to when the proposal relating to 
"derogations" will be put forward for consideration by the experts of the Standing Committee on 
Plants, Animals, Food and Feed (SCoPAFF) . There has to date been no notification of the proposal 
havin g been placed on the agenda  of the relevant SCoPAFF committees, despite the Commission's 
express commitment to deal with this proposal as soon as  the "criteria" initiative  had been 
approved . It is recalled that the scope of the "derogations" included cases  of insignificant risk due 
to low exposure.  
6.   This state of uncertainty is deeply worrying because, if the proposal on derogations is not 
adopted, the use of those substances exposure to which represents "insignificant risk" of endocrine 
disruption would be  prohibited without any scientific justification.  G/TBT/W/550  
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  7.   Lastly, and without prejudice to the above -mentioned inconsistencies, we urge the Commission 
to expedite  its consideration  of the proposal on "derogations", in the interests of exempting at 
least those sub stances that represent insignificant risks to human health, having regard to the 
undertaking given to the Members by the Commission in previous committee  meetings . 
8.  In addition, we request the Commission, in regard both to substances with endocrine -disrupting 
properties and to any other substance coming under the cut -off criteria, to maintain maximum 
residue levels and the application of import tolerances on the basis of risk assessments, having 
regard to the provisions of Regulation No. 396/2005 . Otherwise, we will be faced with the creation 
of more significant, unnecessary and disproportionate  barriers to international trade in agricultural 
products, without any scientific justification.  
 
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