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Endocrine Disruptors
According to the 2002 World Health Organization definition, “an Endocrine Disruptor (ED) is an exogenous substance or mixture that alters function(s) of the endocrine system and consequently causes adverse health effects in an intact organism, or its progeny, or (sub)populations.” A wide range of substances, both natural and man-made, may be classified as endocrine disruptors.
In Europe, hazard-based criteria for identifying endocrine disruptors in Plant Protection Products (Reg. (EU) 2018/605) and Biocidal Products (Reg. (EU) 2017/2100) have applied since 2018. Since April 2023, the EU has also introduced dedicated endocrine disruptor hazard classes under the CLP Regulation (Reg. (EU) 1272/2008) through Commission Delegated Regulation (EU) 2023/707, allowing substances and mixtures to be classified as endocrine disruptors for human health (ED HH) or the environment (ED ENV) in Category 1 (known or presumed) or Category 2 (suspected). These classifications carry new EUH statements—EUH380/381 for human health and EUH430/431 for the environment—reflecting identified or suspected endocrine‑disrupting properties. Mandatory application dates are 1 May 2025 for substances and 1 May 2026 for mixtures, with transitional periods extending to 1 November 2026 and 1 May 2028, respectively. ECHA’s updated CLP Guidance, published in November 2024, provides practical criteria and detailed case handling for applying the new ED hazard classes.
Under REACH (Regulation (EC) 1907/2006), endocrine disruptors may be identified as substances of very high concern (SVHCs) under Article 57(f). The European Commission has announced a REACH revision for Q4 2025.
In North America, the US Environmental Protection Agency (EPA) uses a risk-based approach to screen pesticides, chemicals, and environmental contaminants for their potential effect on estrogen, androgen, thyroid and steroidogenesis (EATS) pathways under the Endocrine Disruptor Screening Program (EDSP).
Our staff in both Europe and North America have considerable practical and regulatory experience in conducting ED assessments under both EU and US legislation, including the provision of advice on assessment strategies, the design, conduct and interpretation of studies to support ED evaluations and the analysis of evidence.
Experienced Support For:
- CLP ED classification support — assembling weight‑of‑evidence for ED HH/ED ENV (Cat 1/2), deriving EUH phrases, and advising on SDS/label and C&L notification implications.
- PPP/BPR ED assessments — strategies aligned to EFSA/ECHA 2018 Guidance and EFSA’s 2025 technical learnings on recurring ED issues.
- REACH & portfolio monitoring — SVHC identification (Art. 57(f)), horizon scanning (ED Lists portal), and monitoring REACH revision (Q4 2025).
- Agency/Member State liaison — structured engagement with RMS/EFSA/ECHA.
- Study design, placement & monitoring — GLP/OECD‑aligned ED studies.
- Evidence assembly — integrating guideline studies, literature and NAMs into regulatory WoE.
- Literature & database searching (systematic review) — EFSA/ECHA‑compliant, reliability appraisal, evidence grading.
- QSAR/read‑across & in vitro bioassays — aligned to OECD CF/GD 150; EPA CompTox used as supporting evidence.
- EATS and beyond — AOP‑anchored analysis across estrogen, androgen, thyroid and steroidogenesis pathways.
Development of ED Assessment Strategies & Advice on Testing Options
- Development of tailored ED assessment strategies to support EU/UK PPP, BPR, REACH, and CLP (ED HH/ED ENV) regulatory requirements, including the 2023 introduction of CLP endocrine disruptor hazard classes (Reg. (EU) 2023/707).
- Advice on data requirements and testing options for evaluating potential ED effects in humans, mammals, and non‑target organisms in accordance with the OECD Conceptual Framework and OECD Guidance Document 150, including updated approaches for EATS and non‑EATS pathways.
- Identification of optimal testing pathways using a weight‑of‑evidence approach, integrating guideline studies, mechanistic data, and relevant new approach methodologies (NAMs).
- Regulatory liaison with EU/UK Member State competent authorities to define the appropriate scientific and regulatory approach for ED‑related evaluations.
Study Design, Placement & Monitoring
- Design, placement, and monitoring of ED‑relevant studies conducted under GLP and following OECD Test Guidelines, including endocrine‑specific in vitro and in vivo studies.
- Advice on validated versus non-validated testing options.
- Troubleshooting of study design challenges (e.g., sensitivity, biological variability, solubility/stability issues highlighted by recent EFSA assessments) to ensure robust ED endpoints.
- Independent interpretation and scientific review of ED study results.
Preparation of ED Assessments in Accordance with 2018 EFSA/ECHA Guidance
- Preparation of ED assessments for EU active substance approvals/renewals and co‑formulant assessments under PPP and BPR frameworks, following the EFSA/ECHA 2018 ED identification criteria.
- Conduct of systematic literature reviews compliant with EFSA/ECHA principles, including transparent search strategies, reliability appraisal, and evidence integration.
- Evaluation of non‑test data (e.g., (Q)SAR, read‑across) and in vitro bioassays, incorporating resources such as EPA CompTox as supporting evidence within an IATA framework.
- Assembly and evaluation of all evidence streams, including mechanistic and apical endpoints, and assessment of EATS‑mediated and non‑EATS mode‑of‑action pathways.
- Preparation of ED assessment review reports and expert statements that clearly demonstrate adverse effect, endocrine activity, and the biologically plausible link required under EU ED criteria.