Nano & Me - Technology in our lives

Does the law cover nano chemicals?

Yes. REACH and CHIP do not distinguish between conventional-scale and nano-scale substances. The laws apply to nano and non-nano chemicals.

Why are people concerned?

Tonnage thresholds

REACH's registration requirements only apply to chemicals produced or sold in volumes of more than one tonne per year. Some people are concerned that nano chemicals may be excluded from registration because they are produced in such low volumes (below one tonne per year).

For more information, see:

Royal Commission on Environmental Pollution report, Novel Materials in the Environment: The Case of Nanotechnology

European Trade Union Confederation, Resolution on Nanotechnologies and Nanomaterials

Is anything being done about this?

A special committee has been set up (‘the Competent Authorities Subgroup on Nanomaterials’) to analyse how REACH applies to nano, and to advise the European Chemicals Agency on improving guidance for manufacturers and importers of nano-scale substances. To see the group’s recent report, Nanomaterials in REACH, click here

The European Commission says that it will carefully monitor the application of REACH to nanomaterials.

Are risk assessment methods adequate?

There is also concern that the methods currently used to assess the safety of chemicals under REACH might not be suitable for nano-scale substances.

This is a problem for other laws too. Without appropriate risk assessment techniques, it can be difficult to ensure that legal requirements are properly fulfilled.

Is anything being done about this?

Yes. There is lots of activity in this area.

A number of different bodies are involved in developing methods designed specifically for nanomaterials. Most of this work is being done by national and international standards committees, such as the British Standards Institute (BSI) and the International Organization for Standardization (ISO). These committees are currently developing standards on a range of nano-related topics. which companies can choose to follow.

The ISO, for example, is creating standards on techniques in nanomaterial measurement, risk characterisation and assessment. The Organisation for Economic Cooperation and Development (OECD) Working Party on Nanotechnology is also heavily involved in monitoring and addressing the challenges posed by nano.

Several nano-specific risk strategies have also been designed to help companies assess, monitor and manage the possible impacts of nano-based products and processes. For more information, see CENARIOS Managing Nano Risks and DuPont and Environmental Defense Fund Nano Risk Framework.

No nano-specific labelling requirements

Another area of concern is that manufacturers and suppliers are not obliged to label chemicals as nano (although new law has just been introduced for cosmetic products which says that all nanomaterial ingredients must be labelled). Again, this concern is not unique to chemicals law but extends to other areas where nano is used.

Is anything being done about this?

The British Standards Institute (BSI) has published guidelines on the labelling of products containing nanomaterials which companies producing or supplying nano can choose to follow.