Mercury: dental amalgam and other mercury-added products subject to manufacturing, import and export restrictions

My name is Servando Pérez-Domínguez. I do represent, since 2007, the totally independent Spanish national NGO MERCURIADOS.org (made up of patients who have scientifically proved that their very diverse health problems derive from dental Hg poisoning, mercurial allergy-hypersensitivity and/or oral electrogalvanism caused by these metal fillings).

Dental Health Association opinion is that EU need to stop using amalgam as soon as possible, we can’t wait until 2030. Mercury from dental amalgam will spread via air and wastewater from humans and from dental clinics. Mercury is highly toxic for nature and for people. We don’t need more mercury pollution and future EU need to stop amalgam in Dentistry immediately and it is possible at least until 2025.

Filed in Swedish · English published by the European Commission

CREPD Cameroon, applauds this proposal and welcomes the opportunity to comment! Worldwide, more than 30 countries have already phased out the use of amalgam to protect the environment and health and have proven that an amalgam phase-out is feasible due to the availability of effective and cost-efficient alternatives.

On the use of dental amalgam, the Impact Assessment concluded that the preferred policy option is to introduce an EU-wide obligation to phase-out the use of dental amalgam as from 2025, given that (i) it would lead to the greatest environmental and health benefits, including in terms of reductions in mercury emissions from crematoria, (ii) this timeframe is implementable as demonstrated by those Member States that…

Dental amalgam is the major remaining intentional use of Mercury in the EU. Only its phase-out by 2025 can avoid the release of approximately 10 tons of mercury into the environment by 2030. Any further use is unnecessary and contributes to the already elevated concentrations. The current environmental conditions are alarming.

The European Environmental Bureau welcomes the release of European Commissions proposal for revision the EU Mercury Regulation. We comment the Commission for taking responsibility for what it exports to developing countries; yet the ban on linear (LFL) and non-linear fluorescent lamps should take place much faster and as early as 2025, aligning them with domestic bans, and irrespective of global decisions, in line…

Why remove dental amalgam as soon as possible and for everyone? — Because, according to the IAOMT (International Academy of Oral Medicine and Toxicology), it is all the largest source of mercury poisoning. Mercury is a reprotoxic (passed down from generation to generation) a genotoxic (altering genes), a neurotoxic.

Filed in French · English published by the European Commission

The proposed deadline of 1 January 2025 is too short. In France, it does not allow the profession or the national care system to adapt in time to the disappearance of the product. Aware of the health and environmental challenges, the National Association of Dental Surgeons has, in its replies to previous consultations, outlined the well-known safety problems to be addressed and the exceptional situations of certain…

Filed in French · English published by the European Commission

CLASP thanks the European Commission for the opportunity to comment on the review of the EU law on Mercury. The EU has led the global transition to efficient and mercury-free lighting in recent years by phasing-out general-purpose fluorescent lighting across Europe in 2023, and supported by the regions extensive LED manufacturing sector.

On 14 July, the European Commission presented a proposal for a regulation to revise the EU mercury regulation with the aim of protecting EU citizens and the environment from toxic mercury. It aims to ban all forms of mercury in the EU, including the use, production and export of dental amalgam from 1 January 2025. The DSV welcomes the objective of improving environmental and health protection.

Filed in German · English published by the European Commission

The CED continues supporting the proactive and effective phase down of dental amalgam in Europe. Nevertheless, in light of the European Commission (EC) proposal for the revision of the Mercury Regulation ((EU) 2017/852), we would like to express several considerations, important for patients, dental care delivery and the dental profession.

This feedback is given on behalf of Armenian Women for Health and Healthy Environment (AWHHE), NGO from Armenia, which represents the civil society in the National Committee of the Minamata Convention on mercury. AWHHE is confident that it is feasible to prohibit the use, manufacturing, and export of amalgam and therefore endorses the phasing-out of dental amalgam in the EU by 2025.

ZERO is a Portuguese Environmental NGO that has followed the issue of mercury for several years and has been advocating for a fast phase out of dental amalgam containing mercury. We are totally in favour of the Commission's proposal to phase-out dental amalgam by 2025. We support this approach because we will be able to avoid 10 t of Mercury that would otherwise be released into the environment by 2030!

I, representing Asian Center for Environmental Health and Environment and Social Development Organization (ESDO), endorse the phasing-out of dental amalgam in the EU by 2025. The authorities will prohibit the use, manufacturing, and export of amalgam starting from January 1, 2025..

The Eco-UNIA Ecological Association of Wrocław has been in favour of and has been working for years to phase out the use, production and export of dental amalgam in Poland, the European Union and the World as soon as possible. We now call for the phase-out of amalgam across the European Union by 2025, which is not costly and good for health but also for the environment.

Filed in Polish · English published by the European Commission

“The Association of Medical Professionals supports the European Commission’s proposal to phase out amalgam 2025 In working with amalgam, mercury vapour is released in practice. As 99 % of dental specialists in Germany are female and mercury is harmful to both fertility and the unborn child, we are at particular risk.

Filed in German · English published by the European Commission

I'm an independent academic, having for several decades researched many aspects of mercury, ranging from environmental and health affetcs of mercury used in goldmining to dental amalgam, including the link between dental amalgam and illegal gold mining using mercury. The mercury is often imported legally into Latin American countries for use in goldmining by stating that the mercury will be used for dental use.

The German Society for Environmental Dental Medicine (DEGUZ) welcomes the Commission’s proposal to phase out amalgam in 2025 and supports the accompanying measures. The EU’s phase-out of amalgam is an important step towards greener and more healthy dentistry. Amalgam, which contains 50 % mercury, poses a potential risk to the environment and health, both to patients and dentists and dental practitioners.

Filed in German · English published by the European Commission

Joint opinion on the proposal for an amendment of the EU Mercury Regulation (Regulation (EU) 2017/852) [COM(2023) 395 final] of the European Commission of 14 July 2023 The Bundeszahnärztekammer (BZÄK), the Association of Statutory Health Insurance Dentists (KZBV) and the Deutsche Gesellschaft für Zahn-, Mund- und Kieferheilkunde (DGZMK) would like to make use of the possibility granted by the European Commission to…

Filed in German · English published by the European Commission

I have studied this issue for more than ten years, including dental amalgam alternatives, costs, etc. I have reviewed dozens of peer-reviewed papers, carried out research for the European Commission and others, presented my research findings to WHO and others, and I can say categorically that: - prevention and separators are not viable solutions to the dental mercury problem; - there are safe and affordable…

The Federal Association of Advisory Bodies for Environmentalgifts, in particular amalgam, heavy metals and wood preservatives e.V., supports the European Commission’s proposal to phase out amalgam in 2025. If I had known at that time that the highly toxic mercury vapour was released by the use of amalgam fillings in relevant quantities, I would not have had it left it.

Filed in German · English published by the European Commission

LightingEurope welcomes the European Commissions ambition to reduce the mercury amount that is put on the global market to limit environmental and social impacts. From our side, we are working in the Global Lighting Association with organisations from other regions to forge an industry consensus for a global ban of general lighting mercury containing lamps that works for all regions.

I am the deputy president of the Chronic and Environmental Intoxication Diseases Association and we help people harmed by the mercury of dental amalgams and the environment. There is an urgent need to ban the use of mercury in any sector where substitution by other materials and techniques is possible. The damage caused by mercury is irreversible and very serious.

Filed in Italian · English published by the European Commission

The review of mercury legislation is important and worthwhile, but its perspective is unnecessarily narrow and the proposed measures need to be more ambitious with timelines. Mercury is a major pollutant with major public health implications. The statements of the European Environmental Bureau (EEB) are supported and recommended. Combustion plants are significant source of mercury.

I am submitting this comment on behalf of the International Academy of Oral Medicine and Toxicology (IAOMT). Our non-profit organization represents over 1,000 dentists and other health professionals in more than 30 countries around the globe, and I serve as the Executive Chairperson of the IAOMT Board of Directors.

Hazardous Waste Europe welcomes the objectives of the Inception Impact Assessment. Regarding the phasing-out of the use of dental amalgam, the timetable must be clear in order to: 1-ensure that each Member States will have time to shape the right solutions in order to take care of the lower-income part of the population who can't access today to alternative solutions to dental amalgam, 2-ensure that there will be no…

Processes such as plastics extrusion operate at temperatures up to 400°C. Accurate measurement of the pressure of the melt plastic is necessary both for the efficiency of the manufacturing process and the safety of the machine operators.

Diffuse pollution remains a problem in Europe also because of both historical and current emissions of mercury to the atmosphere and subsequently surface waters. Strong action is needed to curtail remaining mercury use and emissions under the European Green Deal, as per the Chemicals Strategy for Sustainability and as part of the Zero Pollution Action Plan.

The European Chemical Society welcomes the Commission’s initiative to repeal Regulation (EU) 2017/852 of the EP and of the Council, in view of the Minamata Convention complementary ratification and supports its will to implement stricter restrictions if needed.

Statement by the German Social Security on the inception impact assessment on the revision of the Mercury Regulation and repealing Regulation (EC) No 1102/2008 On 5 March 2021, the European Commission presented an inception impact assessment on the revision of the Mercury Regulation and repealing Regulation (EC) No 1102/2008 in order to implement the Global Convention on Mercury, the United Nations Minamata…

Filed in German · English published by the European Commission

Mercury is still necessary in electronic melt pressure transmitters. There is no fluid alternative which could substitute mercury completly. Partially there are alternatives, like sodium potassium alloy, and or Galium based alloys, but there are stilll necessary sensors options and applications which are impossible to build with other substances.

LightingEurope Contribution to the EU Mercury Regulation 2017/852 Roadmap Consultation Recommendation The intention of Regulation (EU) 2017/852 of 17 May 2017 on mercury is to transpose the Minamata Convention on Mercury into EU law; its provisions “are aimed at ensuring the fulfilment by the Union and the Member States of the obligations of the Convention concerning trade of mercury”.

The timely phase-out of dental amalgam in Europe is of major relevance as the use of mercury in dentistry accounts for a significant share of total mercury emissions. The use of dental amalgam contributes to the adding to the existing stock of mercury in the environment in the EU and worldwide.

The EU should phase out amalgam use by 2025 because it will have beneficial economic, social, and environmental impacts. Phasing out amalgam will have beneficial economic impacts First, the technical superiority of mercury-free fillings eliminates any cost difference between amalgam and alternatives because… •Mercury-free fillings are long-lasting: Studies show composites last as long as – or longer than – amalgam…

Revision of the EU Mercury Regulation — Joint opinion on the European Commission’s Inception Impact Assessment Berlin, 31 March 2021 Bundeszahnärztekammer (BZÄK) and the Association of Statutory Health Insurance Dentists (KZBV) are grateful for the opportunity to comment on the planned revision of the EU Mercury Regulation as part of the Inception Impact Assessment. The joint opinion is attached in annex.

Filed in German · English published by the European Commission

As a dentist, I have not used amalgam since 1979• This mercury-based material is not needed in modern dental care. Some dentists used to claim placing mercury-free fillings was time-consuming and technique-sensitive especially in large posterior restorations which could increase costs. But studies and experience have shown that this is not true. 1.

As an NGO network focussing on a toxic free environment and the impacts of toxins, including mercury, on health, especially women’s and children health, WECF, Women Engage for a Common Future, is calling for phasing out dental amalgam by 2025. This is technically and economically feasible, and therefore should be implemented without delay.

Health Care Without Harm (HCWH) Europe appreciates the opportunity to provide feedback on the Inception Impact Assessment on the Revision of Regulation (EU) 2017/852 on mercury. An extremely toxic and persistent metal, mercury is one of the World Health Organization (WHO)’s top ten chemicals of major public health concern.

The Ordre National des Surgeurgien-Dentiste de France (ONCD) recommends a balanced and scientifically established approach. As a task of the legislator, it must ensure the quality of the care provided and the safety of the dental practice.

Filed in French · English published by the European Commission

Honorable Committee, today, during the pandemic, we know that protecting citizens, especially the most vulnerable, is a sign of our solidarity and caution. The epidemic situation in Poland is very serious, and air pollution is the highest in the EU. In Poland, mercury is also still emitted into the environment, although its use in dentistry, for example, is no longer necessary today!

Filed in Polish · English published by the European Commission

From our experience as an environmental NGO following mercury issues, we are confident to say that phasing out dental amalgam by 2025 is technically and economically feasible, and therefore should be implemented without delay. Furthermore, the EU should follow this path if it is truly committed to promote the toxic-free environment goal of the European Green Deal.

Conducted risk assessments confirm mercury-free dental fillings are safe for both health and the environment. Most of amalgam’s mercury eventually ends up back in the environment via cremation, dental clinic emissions, waste incineration, human waste, and burials, among other pathways.

The Regulation on Mercury, implementing the Minamata Convention, and addressing also dental amalgam, should be seen in the light of the EU Green Deal and its relevant Strategies such as the Zero Pollution Action Plan for a non-toxic environment and the new action plan on the circular economy.

As a dentist, I have not used dental amalgam in 25 years. This mercury-based material is not needed in modern dental care, because there are enough long-experienced alternative materials. In addition the increase of more prophylaxis and prevention concepts in dentistry since years we have less and smaller defects in teeth, so alternative materials e.g.

I am a mercury free dentist and have been for over 40 years. Dental amalgam is an inefficient environmentally polluting product that is proven to be damaging to the teeth and the general health of the patient. Dental amalgam has no place in modern restorative dentistry. The patient, the detal staff and the dentist all can have health problems from using dental amalgam.

I firmly believe that it is not yet time to completely eliminate dental amalgam because it is still necessary to save costs for the patient in different clinical situations. Dr Candria Francesco

Filed in Italian · English published by the European Commission

I am a dentist. I believe that dental amalgam should be banned WITH EFFETTO IMMEDIATE, both for marketing and use throughout the European Union. Mercury is extremely toxic and releases continuously, mainly in the form of steam, during the life of filling in the oral cavity and is breathed by entering the loop through the lungs and from the target organs.

Filed in Italian · English published by the European Commission