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Justice for our Health



Mon 30 Aug 2010



The European Commission (EC) should not have launched the PL037712 Carcinogenomics project because the methods intended to be developed in the project are already well-established and known to the scientific community.

All associations willing to give their support can print the summary below on their letterhead paper, complete and sign it, and send it to:

Antidote Europe
25 rue Jacques Callot
66000 Perpignan


  • 124 associations have signed
  • 12 countries are represented: 10 European countries as well as Canada and the Philippines
  • More than 1 million European citizens are represented

Many thanks to all associations which have already signed (see list below)!

Complaint to the European Commission concerning administrative mismanagement Presented by Antidote Europe to the European Mediator

This complaint refers to a project of the European Union ‘PL037712 Carcinogenomics’, whose aim ‘is to develop in vitro methods for assessing the carcinogenic potential of compounds […] based on the application of “omics” technologies’, at an estimated cost of 10,440,000 euros, spanning five years.

The complaint will show that the European Commission (EC) should not have launched this project since the methods intended to be developed in the project are already well established and known to the scientific community. The EC is already aware of this fact, based on several written communications it has received from Antidote Europe (including a letter signed by 140 European-based organisations), in addition to meetings that have taken place between Antidote Europe and the European Centre for the Validation of Alternative Methods (ECVAM), based at EC quarters at Ispra. The launching of the project ‘PL037712 Carcinogenomics’ will thus have the effect of slowing down the application of a method that is known to be reliable, fast, and economical, that is already available.

The complaint points to the advantages of ‘high throughput toxicogenomics’ developed by Antidote Europe that has been suitably tailored to meet the needs of the REACH programme, which in fact recognises its significance. Therefore, Antidote Europe asks that the European Mediator recognise the EC’s administrative mismanagement and that the EC should instead have:

  1. Instructed ECVAM to recognise the significance of toxicogenomics as a scientific method in place of animal experiments and to expedite its validation at the European level;
  2. Mandated the use of toxicogenomics as an early screen for detecting carcinogenicity and toxicity of chemical compounds.

The precautionary principle, the preservation of public health, and the requirements of directive 86/609 would thus be met, contrary to the situation at present.

The more than 100,000 chemicals currently in our environment are thought to be the principal cause for the significant increase in cancer, neurodegenerative diseases, sterility and birth defects, even though it has not always been possible to establish a causal relationship between a disease and a particular chemical due to a lack of reliable toxicity assessment. The aim of REACH is precisely to identify the most dangerous chemicals, in order to remove them from the market. Current animal tests clearly cannot fulfil this objective, since there is no animal species that serves as a reliable model for humans. The director of ECVAM has publicly criticised toxicity testing using animals, as has the US Academy of Sciences, which stated that ‘human cell systems have the potential to largely supplant testing in animals’.

Articles of the EC Treaty, together with directive 86/609 and the REACH programme are therefore all being flouted, since the EC has not taken appropriate measures to test the carcinogenic (and otherwise toxic) potential of chemical compounds, using toxicogenomics, whose reliability and relevance have already been demonstrated (by Antidote Europe) and recognised (by the European Parliament).

I, the undersigned, Mr/Mrs/Ms ______________________
On behalf of my organisation _______________________
Would like to add our voice, in support of the complaint submitted by Antidote Europe to the European Mediator, in objecting to the European Project titled ‘PL037712 Carcinogenomics’.
Date : ____________
Signature :