Civil society concerns and demands regarding the EC “nanomaterial” definition

The document is an open letter from a coalition of civil society organisations to the European Commission criticizing the revision process of the "nanomaterial" definition. The authors argue that the 2021 online consultation was rushed and lacked clarity, potentially leading to a definition that excludes substances covered by the 2011 recommendation. They highlight risks such as the under-registration of nanomaterials in REACH and the presence of unauthorised nanomaterials in consumer products. The signatories demand that the Commission justify modifications with real-world examples, conduct transparent public Q&A sessions, and align the definition with the latest scientific evidence, citing EFSA guidance on particle size thresholds.

• The authors contend that the May-June 2021 online consultation was flawed due to short notice and limited response time, which they claim "favoured the participation of industry stakeholders over others".
• There is a concern that proposed changes to the definition would exclude substances previously covered by the 2011 recommendation, which would be "extremely counterproductive" given the EU's Zero Pollution ambition and the goal of a toxic-free environment.
• The letter notes significant compliance issues with existing frameworks, specifically the "continuing under-registration of nanomaterials within REACH" and the widespread use of "unauthorised nanomaterials across consumer products".
• The signatories argue that the revised definition should be based on current scientific evidence, referencing a June 2021 EFSA guidance that focuses on materials where more than 10% of particles have at least one external dimension smaller than 500 nm.

APA

Center for International Environmental Law (2022). Civil society concerns and demands regarding the EC “nanomaterial” definition. https://www.ciel.org/wp-content/uploads/2022/02/2022_02_08_CIEL_Open-letter_definition-nanomaterial.pdf

Chicago

Center for International Environmental Law. Civil society concerns and demands regarding the EC “nanomaterial” definition. 2022. https://www.ciel.org/wp-content/uploads/2022/02/2022_02_08_CIEL_Open-letter_definition-nanomaterial.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Civil society concerns and demands regarding the EC “nanomaterial” definition |date=8 February 2022 |url=https://www.ciel.org/wp-content/uploads/2022/02/2022_02_08_CIEL_Open-letter_definition-nanomaterial.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2022civil, author = {{Center for International Environmental Law}}, title = {{Civil society concerns and demands regarding the EC “nanomaterial” definition}}, publisher = {Center for International Environmental Law}, year = {2022}, month = feb, url = {https://www.ciel.org/wp-content/uploads/2022/02/2022_02_08_CIEL_Open-letter_definition-nanomaterial.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }