The union's submission on the already hotly disputed proposals, which affect teachers throughout the United Kingdom, says that plans to pass the costs of early retirement on to individual councils and institutions will discriminate particularly against small employers.
The EIS contends that pension reforms have been rushed through as a cost-cutting measure and are ill-judged.
Ken Wimbor, assistant general secretary, said: "The major cause of concern relates to the additional financial burden to be placed on employers to fund part of the pension and lump sum of a teacher or lecturer who retires before reaching the age of 60.
'In addition, further restrictions are to be placed on teaching staff who, previously, would have had to retire as a consequence of their health breaking down."
Mr Wimbor describes the extra burden placed on local authorities as "gratuitous" and predicts the changes are not in the interests of employers or teachers.
He adds: "To now require staff, regardless of their circumstances, and in some cases, regardless of their health, to continue to work up to their normal retirement age is an insult to the profession and to the service. The Secretary of State must think again."