ECOS welcomes the publication of the European Commission’s official proposal for REACH Annex revisions to address nanomaterials. Nonetheless, ECOS wants to signal the unacceptably late publication of this revision. Work began in 2011, when another option for adequate regulation of nanomaterials also included the creation of a nano-specific legislation to supplement REACH’s horizontal addressing of chemicals. At that time, the European Commission proposed that the quickest, and therefore most appropriate, option for establishing chemicals legislation that explicitly addressed nanomaterials was by revising REACH Annexes. Given numerous delays to the development of the proposed revisions, the specific nano requirements for nanomaterials will not be available for the last REACH registration deadline of 2018 and substances in the nanoform will therefore continue to reach the market without ECHA having adequate data to assess their safety.
Our political and technical response to the Public Consultation is available here.