The NIA provided comments on the 24th of March 2017 to the Swedish Chemicals Agency (KEMI) on their consultation to require reporting of nanomaterials in products to the Swedish Product Register.
NIA is of the view that the information requirements and administrative burden of the proposal is not proportional to the objective to provide an overview of nanomaterials in products on the Swedish market. The claimed objective to provide a basis for future regulatory proposals and to use the gathered information as a basis for monitoring of industries can be achieved with information provided on a higher level, e.g. via the ECHA Observatory on Nanomaterials which is under construction. There is no need to require additional burdens for industries applying nanomaterials compared to conventional use of chemical substances in products. The proposal hamper innovation, competitiveness, requires heavy administrative burden and is of limited value as it lacks proportionality.
