Stakeholders’ response to the Communication from the Commission to the European Parliament, the Council and the European Econom
Summary
A joint statement from environmental, worker, and consumer organisations expressing disappointment and concern regarding the European Commission's Second Regulatory Review on Nanomaterials published on 3 October 2012. The signatories argue that the Commission's approach is inconsistent with its own analysis, ignores scientific evidence of nanomaterial toxicity, and fails to implement a precautionary approach to protect human health and the environment.
Key insights
- The signatories claim the European Commission's Second Regulatory Review on Nanomaterials contradicts its own Staff Working Paper (SWP). While the SWP acknowledges that nanomaterial properties and toxicity can change based on size and shape, and that REACH does not provide adequate information to assess risks, the Commission's final approach only proposes limited amendments to REACH annexes.
- The document asserts that nanomaterials can exhibit different (eco)toxicity properties than larger particles of the same chemical composition. It cites evidence that carbon black and titanium dioxide (TiO2) have shown carcinogenicity in experimental animals, and that carbon black nanoparticles can induce genotoxicity and sustained inflammation in mouse lung and liver.
- The signatories criticize the Commission for failing to ensure citizens' right to know about the hazards and uses of nanomaterials. They argue that the proposed solution—creating a web platform for existing information sources—is insufficient because existing databases and voluntary reporting schemes have been unreliable or have failed completely.
- The statement challenges the European Commission's estimate of 300,000 to 400,000 direct jobs associated with nanotechnologies in the EU, noting that the original source does not disclose its methodological approach or account for structural job market changes.
- The authors argue that the Commission is shifting the burden of risk assessment to employers and workers, despite the fact that Safety Data Sheets often lack nano-specific information and it may be unknown if nanomaterials are even present in products.
Cite the original document
- APA
- Center for International Environmental Law (n.d.). Stakeholders’ response to the Communication from the Commission to the European Parliament, the Council and the European Econom. https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf
- Chicago
- Center for International Environmental Law. Stakeholders’ response to the Communication from the Commission to the European Parliament, the Council and the European Econom. n.d. https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf.
- Wikipedia
- {{cite press release |author=Center for International Environmental Law |title=Stakeholders’ response to the Communication from the Commission to the European Parliament, the Council and the European Econom |url=https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{centerforinternationalenvironmentallawndstakeholders, author = {{Center for International Environmental Law}}, title = {{Stakeholders’ response to the Communication from the Commission to the European Parliament, the Council and the European Econom}}, publisher = {Center for International Environmental Law}, url = {https://www.ciel.org/Publications/Nano_EC_23Oct2012.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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