News Our Feedback to EC 5 December 2022

Have your say - Polluters Pay Principle

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.

Polluter Pays Principle – fitness check of its application to the environment

About this initiative: The Polluter Pays Principle means polluters pay for measures to prevent, control and remedy pollution and for the cost to society of pollution. This fitness check will look at the application of the principle at Member State level.

Feedback period: for stage 2 it is 11 November 2022 - 09 December 2022


Feedback from Europeans for Safe Connections

Europeans for Safe Connection welcome the opportunity to give feedback on this very important issue.

It is written that the PPP must respond to new or emerging environmental issues and changes in technology and therefore the PPP must include RF EMF (radiofrequency) and ELF EMF (extremely low frequency) as a pollutant to humans and nature.

On the grounds that the PPP is a key principle underlying EU environment legislation and policies, as set out in Article 191(2) of the Consolidated Version of the Treaty on the Functioning of the European Union – it is very important that all forms of pollution are recognised and taken into account and must therefore include RF EMF and ELF EMF.

In our proposal 15 we write: Recognize all biologically harmful parameters of RF EMF as a pollutant. Include them in all relevant EU Policies and Directives.

RF EMF exposure has increased from extremely low natural levels by about 1018 times and this radiation can cause reactive oxygen species (ROS) and cellular or systemic oxidative stress in all life forms.

Arguments for accepting RF EMF as a potential pollutant

Citation from Planetary electromagnetic pollution: it is time to assess its impact published in

The rise in planetary electromagnetic pollution due to the exponential increase in the use of wireless personal communication devices (eg, mobile or cordless phones and WiFi or Bluetooth-enabled devices) and the infrastructure facilitating them, levels of exposure to radiofrequency electromagnetic radiation around the 1 GHz frequency band, which is mostly used for modern wireless communications, have increased from extremely low natural levels by about 1018 times. It is plausibly the most rapidly increasing anthropogenic environmental exposure since the mid-20th century, and levels will surge considerably again, as technologies like the Internet of Things and 5G add millions more radiofrequency transmitters around us.

Find more arguments:

Arguments for RF EMF being potentially biologically harmful

Citation from Manmade Electromagnetic Fields and Oxidative Stress—Biological Effects and Consequences for Health published in The International Journal of Molecular Sciences, March 2021:

"Concomitant with the ever-expanding use of electrical appliances and mobile communication systems, public and occupational exposure to electromagnetic fields (EMF) in the extremely-low-frequency and radiofrequency range has become a widely debated environmental risk factor for health. Radiofrequency (RF) EMF and extremely-low-frequency (ELF) MF have been classified as possibly carcinogenic to humans (Group 2B) by the International Agency for Research on Cancer (IARC). The production of reactive oxygen species (ROS), potentially leading to cellular or systemic oxidative stress, was frequently found to be influenced by EMF exposure in animals and cells. In this review, we summarize key experimental findings on oxidative stress related to EMF exposure from animal and cell studies of the last decade. The observations are discussed in the context of molecular mechanisms and functionalities relevant to health such as neurological function, genome stability, immune response, and reproduction. Most animal and many cell studies showed increased oxidative stress caused by RF-EMF and ELF-MF.”

Legal Arguments for our proposal are:

Given the above arguments and art. 1, 2, 3, 6, 7, 24, 35, 37, in the Charter of Fundamental Rights of the EU it is imperative to accept RF EMF and ELF EMF as pollutants that must be monitored and restricted for proper protection of all life on Earth.

Systematic measurement of RF EMF and ELF EMF in all parts of society and in the wild must be initiated to provide an overview of all parameters of RF EMF and ELF EMF pollution in order to determine the source of the pollution and who are responsible for the damages.

Best regards
Pernille Schriver
on behalf of Europeans for Safe Connections
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