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

This document is a reply form submitted by the Center for International Environmental Law (CIEL) and the European Environmental Bureau (EEB), on behalf of a coalition of international and European NGOs, to a public consultation on the European Commission's proposed definition of 'nanomaterial'.

• The signatory NGOs support the European Commission's draft recommendation for a nanomaterial definition, stating that a broad, overarching definition is necessary to allow regulatory activities to keep pace with market developments and ensure the responsible development of products.
• The coalition specifically supports several provisions of the draft, including the call for regular reviews of the definition, the inclusion of aggregates and agglomerates, the potential inclusion of materials smaller than 1nm (such as fullerenes), and the recommendation to base size distribution on particle numbers instead of mass concentration.
• The NGOs advocate for a larger size range of 0.3 to 300 nm to define nanomaterials, rather than the proposed 1-100nm range. This recommendation is based on evidence that particles up to several hundred nanometers can exhibit novel properties critical for risk assessment and the acknowledgment that science cannot establish a definitive upper size limit for nano-properties.
• The signatories request a sensitivity analysis immediately following the adoption of the definition to ensure the chosen size range captures materials of concern while excluding those without nano scale-related issues. They also support a 1% threshold for particle number size distribution to include materials in the larger size range that may have nano-specific hazardous properties.
• The coalition warns that narrowing the definition of nanomaterials could allow harmful substances to avoid scrutiny and limit the flexibility of legislators to regulate future generations of nanomaterials or substances not currently engineered to nano-sizes.

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} }