Reply form for the public consultation on Proposal for a Commission definition of the term "nanomaterial"

The document outlines the positions of a broad coalition of environmental and health NGOs on the European Commission's proposed definition of nanomaterials. While welcoming the initiative to establish a regulatory framework, the signatories argue for a broader size range (0.3 to 300 nm) than the proposed 1-100 nm to ensure that potentially hazardous materials are not excluded from scrutiny. They specifically support basing size distribution on particle numbers and the inclusion of aggregates, agglomerates, and materials smaller than 1 nm, such as fullerenes.

• The signatory NGOs support the European Commission's draft recommendation as it provides a necessary foundation for regulatory activities to keep pace with market developments and ensure the safe development of products.
• The coalition advocates for expanding the defined size range of nanomaterials to between 0.3 and 300 nm, rather than the proposed 1-100 nm, because some particles up to several hundred nanometers exhibit novel properties critical for risk assessment.
• The NGOs endorse specific technical aspects of the proposal, including the use of particle numbers for size distribution instead of mass concentration, the inclusion of aggregates and agglomerates, and the potential inclusion of materials smaller than 1 nm, such as fullerenes.
• The signatories warn that a narrow definition could allow harmful substances to avoid regulatory scrutiny and limit the flexibility of legislators to address future generations of nanomaterials.

APA

Center for International Environmental Law (2010). Reply form for the public consultation on Proposal for a Commission definition of the term "nanomaterial". https://www.ciel.org/wp-content/uploads/2015/04/Nanomaterials_ReplyForm_Nov10.pdf

Chicago

Center for International Environmental Law. Reply form for the public consultation on Proposal for a Commission definition of the term "nanomaterial". 2010. https://www.ciel.org/wp-content/uploads/2015/04/Nanomaterials_ReplyForm_Nov10.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Reply form for the public consultation on Proposal for a Commission definition of the term "nanomaterial" |date=19 November 2010 |url=https://www.ciel.org/wp-content/uploads/2015/04/Nanomaterials_ReplyForm_Nov10.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2010reply, author = {{Center for International Environmental Law}}, title = {{Reply form for the public consultation on Proposal for a Commission definition of the term "nanomaterial"}}, publisher = {Center for International Environmental Law}, year = {2010}, month = nov, url = {https://www.ciel.org/wp-content/uploads/2015/04/Nanomaterials_ReplyForm_Nov10.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }