Revision of REACH Annexes for Nanomaterials – Position Paper
REACH is the primary EU regulation on chemicals to address the health, safety, and environmental risks of substances produced or put on the market in the European Union. REACH and several of its Annexes flesh out the duties that producers and importers, as well as down-stream users, have to submit registration dossiers to the European Chemical Agency (ECHA) in which they identify, characterize, and evaluate their substances, mixtures, and products. So far no nano-specific provisions have been included in the REACH Annexes, and according to latest findings, the registration dossiers available so far do not contain information on nanoforms. REACH also does not stipulate a separate obligation to register the nano form of a substance from the associated non-nanoforms of the material. In May 2014, the European Commission presented a project of annexes amendment to the Competent Authorities Sub-group on Nanomaterials (CASG Nano) to ensure efficacy of nanomaterial registration. This position paper discusses these proposed amendments.