The accessibility of data on environmental risk assessment of pharmaceuticals - are environmental risk assessments information on emissions with respect to international and European environmental information law?

In the pharmaceutical sector, the right of access to environmental information is in most cases not feasible as the authorisation holders refer to commercially/industrial confidential information (CCI). However, CCI can not refuse access to environmental risk assessments (ERAs) if ERAs are to be classified as information on emissions. Pharmaceuticals inevitably enter the environment as a consequence of their intended use.