To the European Commission, firstname.lastname@example.org, & Env-Mercury@ec.europa.eu
RE: 47 NGOs from Africa, Asia, and Africa ask you to recommend a ban on dental amalgam exports
Support banning dental amalgam exports from the EU
We, the undersigned NGOs from non-EU countries, support the workshop background document Assessment of the Feasibility of Phasing Out Dental Amalgam's conclusion that dental amalgam should not be exported to other countries: “The phase-out in OP1, OP2 and OP3 would not be applied only on the use of dental amalgam in restoration, but also the manufacturing, export and import of dental amalgam (including encapsulated items).” [i] We urge the Commission to recommend a ban on amalgam exports to our countries because:
1. Developing countries cannot control mercury waste from amalgam: Amalgam waste management is not affordable or practical in developing countries that have neither the infrastructure to collect, transport, and store mercury waste from amalgam, nor the resources to enforce regulations requiring it for generations to come. If the EU continues to export amalgam, it will contribute to the costly and dangerous mercury waste problem in other countries.
2. Dental mercury pollution crosses national borders: The largest user of dental mercury in the world is the European Union at 90 tonnes per year. [ii] The resulting mercury pollution crosses national borders, making it a concern in our countries too. Currently, amalgam use is low in many developing countries. If the EU continues to export amalgam, its use will increase and a part of the resulting mercury pollution could very well end up right back in the EU.
3. Our children deserve as much protection as EU children: The European Union has banned amalgam use in children, pregnant women, and breastfeeding mothers in addition to taking steps to protect them from future dental mercury pollution by phasing out all amalgam use. But if the EU continues to export amalgam, our children will be subjected to a double dose of amalgam's mercury: first when it is implanted in their teeth and a second time when it contaminates their environment.
We applaud the EU for working to phase out its own use of dental amalgam. But in order to lead the world effort to stop mercury pollution, we urge the EU to stop dumping dental amalgam in other countries via exports, especially to developing countries. Thank you in advance for taking our perspective into consideration.
Dr. Shahriar Hossain, World Alliance for Environmental Health (Alternative Secretariat, Dhaka)