Position Paper Reset Governance: Nanomaterials as a case study on negligence

This position paper, authored by civil society organisations, criticises the European Commission's governance of nanomaterials, describing it as a "laissez-faire approach" that prioritises industry interests over human health and environmental safety. The signatories demand a comprehensive framework regulation to harmonise the regulation of nanomaterials across the EU, incorporating a lifecycle approach and the "no data, no market" principle.

• Civil society organisations argue that the European Commission has failed to establish a clear regulatory framework for nanomaterials, leading to a situation where risk assessment is impossible because hazard profiles and exposure scenarios cannot yet be characterised.
• The signatories demand the creation of a harmonised nanomaterials framework regulation that would apply to all nanomaterials with an annual production volume of at least 100g. This legislation should include mandatory information requirements on risk management, hazard, exposure, and characterisation, and should introduce pre-market information requirements for future products.
• The paper calls for the strict enforcement of the "no data, no market" principle from REACH, asserting that manufactured nanomaterials should not be released into the environment until adequate safety data is available and products with significant data gaps should be removed from the market.
• The document proposes several specific governance measures, including a full producer responsibility lifecycle approach, mandatory neutral labelling for products requiring ingredient lists, and the requirement that all research projects involving nanomaterials include publicly available environmental, health, and safety (EHS) research.
• The signatories request that the definition of nanomaterials be based on the 2011 Commission recommendation but with a reduced number size distribution threshold of 10%, which could be further adjusted based on scientific data.

APA

Center for International Environmental Law (n.d.). Position Paper Reset Governance: Nanomaterials as a case study on negligence. https://www.ciel.org/wp-content/uploads/2016/12/NGO-position-paper_Dec2016_Reset-Governance_Nanomaterials.pdf

Chicago

Center for International Environmental Law. Position Paper Reset Governance: Nanomaterials as a case study on negligence. n.d. https://www.ciel.org/wp-content/uploads/2016/12/NGO-position-paper_Dec2016_Reset-Governance_Nanomaterials.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Position Paper Reset Governance: Nanomaterials as a case study on negligence |url=https://www.ciel.org/wp-content/uploads/2016/12/NGO-position-paper_Dec2016_Reset-Governance_Nanomaterials.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallawndposition, author = {{Center for International Environmental Law}}, title = {{Position Paper Reset Governance: Nanomaterials as a case study on negligence}}, publisher = {Center for International Environmental Law}, url = {https://www.ciel.org/wp-content/uploads/2016/12/NGO-position-paper_Dec2016_Reset-Governance_Nanomaterials.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }