StakeholdersZesponse to the Communication on the Second Regulatory Review on Nanomaterials

The document argues that the European Commission's Second Regulatory Review on Nanomaterials is inconsistent with its own scientific analysis and fails to protect human health and the environment. The signatories claim that the Commission ignores evidence that nanomaterials have distinct toxicological properties compared to larger particles and that the proposed amendments to REACH are insufficient to close information loopholes. They specifically criticize the shift of the burden of proof to employers and workers and the lack of reliable data generation, calling for a strict application of the precautionary principle and the 'no data no market' principle.

• The signatories argue that the European Commission's Second Regulatory Review is inconsistent with its own Staff Working Paper (SWP), which acknowledges that nanomaterials' physical and chemical properties can change with size and that toxicity may be driven by size and shape rather than chemical elements.
• Scientific evidence cited in the document suggests that nano-scale particles may be more toxic than larger particles of the same composition due to greater surface area per mass, with specific examples including the carcinogenicity of carbon black and titanium dioxide (TiO2) in experimental animals.

APA

Center for International Environmental Law (2012). StakeholdersZesponse to the Communication on the Second Regulatory Review on Nanomaterials. https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf

Chicago

Center for International Environmental Law. StakeholdersZesponse to the Communication on the Second Regulatory Review on Nanomaterials. 2012. https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=StakeholdersZesponse to the Communication on the Second Regulatory Review on Nanomaterials |date=23 October 2012 |url=https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2012stakeholderszesponse, author = {{Center for International Environmental Law}}, title = {{StakeholdersZesponse to the Communication on the Second Regulatory Review on Nanomaterials}}, publisher = {Center for International Environmental Law}, year = {2012}, month = oct, url = {https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }