On 16 October, NIA (Nanotechnology Industries Association) and CEFIC (European Chemical Industry Council) organised a joint workshop to discuss the legal term ‘nanoform’ included in the modified and adopted REACH Annexes. Industry experts, ECHA (European Chemicals Agency) and the European Commission presented and discuss the position and presentation of nanoforms within REACH dossiers. The aim of the meeting was to gain a greater understanding of how industry can interpret and implement the new concept of “nanoform” and “sets of nanoform” in preparing their registration dossiers under the REACH Regulation.
Regulatory and European Agency positions and actions
ECHA presented preliminary thoughts on how applicants can implement the terms in Annex VI of the REACH regulation. The legal text should be applied from 1 January 2020 and thereby provide regulatory requirement affecting those that manufacture or important nanoforms or sets of nanoforms on the EU market in relevant tonnages as specified in the legal text.
The JRC (Joint Research Centre of the European Commission) presented its work on preparing guidance for the current (2011) nanomaterial definition. A first JRC guidance is expected to be published shortly and will focus on concept and terms and a second guidance, for publication in 2019, will focus on measurements.
Industry case studies representing nanoforms
The meeting presented five industry case studies prepared from NIA and CEFIC Members. Participants discussed queries and clarifications regarding nanoforms within REACH Annexes, with extensive analysis of how sets of similar nanoforms might be presented.
The meeting was a strong platform to advance the implementation of the modified REACH Annexes and the guidance development process of ECHA, to which industry, CEFIC and NIA will provide their active input. NIA has recently nominated several experts to participate in the ECHA Guidance development.
