Brussels, [15.09.2025] – The Nanotechnology Industries Association (NIA) has submitted its response to the European Commission's consultation on the revised Safe and Sustainable by Design (SSbD) framework, expressing strong support for its ambitious goals while advocating for improvements to enhance practicality and accessibility, particularly for SMEs and emerging technologies.
Positive Framework Elements
NIA welcomes the framework's new tiered entry approach (simplified, intermediate, full), which provides much-needed flexibility for innovators at different stages of technology development. The association also recognizes the value of the new scoping analysis, while emphasizing the need for clearer templates, sector-specific examples, and streamlined decision rules to guide companies efficiently through the process.
Safety and Environmental Assessment Recommendations
Regarding safety assessment, NIA supports the integration of hazard and exposure considerations but recommends enhanced clarity on progression between assessment levels and stronger attention to process-related safety, including workplace emissions and scale-up risks. While welcoming the inclusion of environmental benchmarks, NIA cautions that these may not always apply to niche or early-stage innovations, calling for greater flexibility and sector-specific tailoring.
Addressing SME Challenges
For socio-economic assessments, NIA highlights significant challenges faced by SMEs in accessing necessary data and expertise. The association advocates for simplified approaches, proxy indicators, and shared databases to prevent disproportionate burdens and ensure broader applicability across the innovation ecosystem.
"NIA strongly supports the Commission's ambition to drive safer and more sustainable innovation," said [Sean Kelly, interim Director General]. "However, the framework must remain practical, proportionate, and enabling for companies of all sizes—especially SMEs—to ensure it fosters innovation rather than creating unnecessary barriers."
The Commission will incorporate stakeholder feedback to refine the SSbD framework, with a revised Recommendation expected by the end of 2025.
