The NIA has submitted comments to the European Commission’s consultation on potential new REACH restrictions for substances classified as carcinogenic, mutagenic, or reprotoxic (CMR), including certain multi-walled carbon nanotubes (MWCNTs).
While supporting the existing harmonised CLP classification for defined fibre-like MWCNTs, the NIA emphasised that REACH restrictions are risk management tools and must therefore reflect realistic exposure scenarios. Inhalation risk for fibrous materials depends on geometric properties as well as on whether fibres are respirable, airborne, and capable of reaching the deep lung.
Drawing on analyses from the German Competent Authority (BAuA) and established fibre toxicology principles, the NIA recommended that any restriction focus on “critical fibres” most relevant for inhalation exposure. Specifically, it proposed using an exposure-relevant fibre length range (≥ 5 µm and < 100 µm) when defining Annex XVII restrictions.
This targeted approach would protect human health while ensuring that regulatory measures remain proportionate, science-based, and practically enforceable.
