Appeal to MEPs on Amalgam Vote

The Irish Dental Association has written to all fifteen Irish MEPs to seek their support on an important vote which takes place in the European Parliament this Wednesday in regard to the use of dental amalgam.

The European Parliament and the Council have previously agreed to prohibit the use of dental amalgam in the EU for all persons from 1 January 2025, except when deemed strictly necessary by a dentist to address the specific medical needs of a patient.

However, a derogation on the prohibition is possible until 30 June 2026. This requires justification to the European Commission by member states having regard to negative repercussions for low-income individuals, who would be otherwise socio-economically disproportionally affected.

In Ireland, we know that the proportion of amalgam fillings is far greater for lower income groups such as the 1.5 million medical card holders whose dental scheme (as designed by the Department of Health) is predicated on the use of dental amalgam rather than composite (white) fillings.

We believe therefore that the introduction of a total phase-out of the use of dental amalgam from January 1, 2025 will disproportionately affect lower income groups such as medical card patients, given the complete absence of any ameliorating measures to address the particular needs of medical card patients by the Department of Health.

The Irish Dental Association has consistently sought the introduction of an entirely new scheme for medical card patients but this offer has been spurned for an extended period by successive Department of Health administrations here in Ireland.

We are therefore asking that the Irish MEPs would support in the European Parliament this Wednesday the application of a derogation on the prohibition on the use of dental amalgam until 30 June 2026 in the interests of lower income patients in Ireland.

Otherwise, we are concerned that the access of lower income patients to fillings will be seriously curtailed with the inevitable decline in their oral health.

Furthermore, it is important to explain that concrete and successful measures and recommendations to reduce the use of dental amalgam are already in place and being implemented among member states with the support of dentists:

• Robust and effective measures for phasing down of dental amalgam were already in place without this regulatory action - these efforts have so far led to a decrease of about 50% in dental amalgam use and envisioned a projected further, continuous decrease in the coming decades.

• The dental profession has been committed to addressing the existing environmental concerns regarding dental amalgam through the use of gamma 2 free form of amalgam, which is an extremely corrosion resistant form of amalgam as well as amalgam separators, as per the 2017 EU Mercury Regulation.

• The dental profession has also continuously underlined to both policy-makers and the general public that prevention is and will always be the answer to reducing amalgam use. Effective dental caries prevention and health promotion programmes, will reduce the use of current restorative materials, including dental amalgam.

In some member states, this upcoming revised legislation will bring a plethora of problems for healthcare and dental treatments in the immediate future:

• The choice of treatment and materials should remain within the mandate and expertise of the dentist, and should be based on informed decision by the respective patient – but it is questionable whether this will be the case with the upcoming legislation. The text is prohibiting the manufacture and import of dental amalgam in the EU. Even with the envisioned derogation (permitting for import and manufacturing for specific medical needs), this measure will lead to a chain reaction with supply lines of dental amalgam being disrupted/abandoned. Inevitably, this will result in restrictions in treatment choices.

• Amalgam remains the best possible option for specific treatment needs: while lasting and financially affordable alternative materials have been developed in recent years, they still entail increased costs and reduced longevity for large cavities. Such materials can be used but they are not a universal solution to replacing amalgam where it is required. This is especially relevant in treatment situations where large restorations of decayed posterior teeth are necessary.

• A phase-out by means of regulatory action in member states where amalgam fillings are still in use, would likely affect national reimbursements - and health care financing schemes. As such, the upcoming complete phase out of dental amalgam poses a threat to such services and threatens to widen oral health inequalities. The consequences would inevitably be an increase in dental diseases in parts of our already disadvantaged and vulnerable populations along with an increase in avoidable extractions. As such, this ban would likely have social consequences, especially considering the already strained healthcare systems in Europe.