On December 5, 2016 several civil society organizations, including the European Environmental Citizens’ Organisation For Standardisation (ECOS) and the Center for International Environmental Law (CIEL), published a position paper entitled “Reset governance: Nanomaterials as a case study on negligence.” In a press release published on the same date, ECOS stresses that “the EU has still not agreed rules that will properly regulate nanomaterials.” ECOS further explains that “REACH is not fit-for-purpose to manage these substances as it does not set down a definition for nanomaterials, or thresholds for high tonnage chemicals.” Therefore, the organizations request “nanomaterials to be addressed in specific legislation.” In their paper, the signatories demand the following:

1) A framework regulation on nanomaterials governing human health and environmental protection for all potential uses of nanomaterials in a harmonized way,
2) the framework regulation to enshrine the “no data, no market” principle of REACH,
3) the governance of nanomaterials to take a lifecycle approach and include end-of -life management,
4) market data collected by the framework regulation to be made publicly available,
5) labelling of products containing nanomaterials to be mandatory,
6) harmonized definitions of terms relevant to nanomaterials to be included in the framework regulation,
7) research on nanomaterials to be required to consider environmental, health and safety (EHS) impacts and ethical, legal and social aspects (ELSA),
8) bio-monitoring of the environment, the public, and workers to be carried out,
9) REACH registrations featuring nano-forms to be placed on the Community Rolling Action Plan (CoRAP) list for evaluation, and
10) effective participatory procedures in the decision-making processes on nanomaterials to be set up.

Read more

ECOS (December 5, 2016). “Press release: NGOs renew push for nano rules.

ECOS (December 5, 2016). “Position paper – Reset governance: Nanomaterials as a case study on negligence.


ECOS et al. (December 5, 2016). “Reset governance: Nanomaterials as a case study on negligence.(pdf)