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Austrian Academy of Sciences Publishes NanoTrust Dossier on Nano Registries

The Institute of Technology Assessment of the Austrian Academy of Sciences has published a NanoTrust Dossier entitled “Nano-registries:  Country-specific Solutions for Nano-regulation.”  While the European Union (EU) has declined to create an EU-wide nano-registry, several EU Member States have adopted their own nano-registries.  Belgium and France created stand-alone nano-registries, but Norway and Sweden added a “tick box” for nano to their product registries.  Denmark established a stand-alone registry and added a “tick box” for nano to its product registry.  According to the Dossier, Belgium, Denmark, France, Norway, and Sweden all use the European Commission’s (EC) Recommendation on the definition of nanomaterial (2011/696/EU).  The NanoTrust Dossier provides an overview of the registries that includes a helpful summary of who must register and the registration threshold and the information required to be reported.  The Dossier concludes that “it is necessary to close the information gaps on nanomaterials in the EU through a harmonised regulatory framework.”  The Dossier notes that Belgium, France, Sweden, and Denmark communicate closely “to maintain a certain consensus concerning the national registry projects of nanomaterials with a view to allow for future possible harmonisation.”  According to the Dossier, registrants do not know if they have to register a given substance, mixture, or product because they either lack information about the ingredients or knowledge about how to complete the registration process.  The Dossier states that national registries pose a challenge for industry and free trade across borders within the EU, and small and medium enterprises are particularly affected by the financial burden of a time-consuming registration process.  The Dossier suggests that a holistic framework, such as the one proposed in the 2017 article “React now regarding nanomaterial regulation,” “can help gather data on nanomaterials within the European Union, promising increased transparency and benefits for workers, the environment and consumers.”

©2020 Bergeson & Campbell, P.C.National Law Review, Volume IX, Number 193


About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

Carla Hutton, Bergeson Campbell PC, global regulatory attorney, public health activists lawyer, metals industry legal counsel, Toxic Substances Control Act law
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client initiatives. These tasks have proven invaluable to many clients, keeping them aware and abreast of developing issues so that they can respond in kind and prepare for the future of their business.

Ms. Hutton brings a wealth of experience and judgment to her work in federal, state, and international chemical regulatory and legislative issues, including green chemistry, nanotechnology, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), Proposition 65, and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.