November 18, 2018

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French NGO Claims Many Manufacturers Fail to Comply with Nano Labeling Requirement

UFC-Que Choisir, a French non-governmental organization (NGO), announced on January 23, 2018, that it filed complaints against nine manufacturers of food and cosmetic products for failure to comply with the requirement to report the presence of nanomaterials on the product label.  UFC-Que Choisir states that its analysis covered 20 consumer products (seven food products, nine cosmetics, and four drugs) and targeted titanium dioxide, silicon dioxide, iron oxide, zinc oxide, and carbon black.  The NGO tested the products for the presence of nanomaterials and then checked the product packaging for reference to nanomaterials.  According to UFC-Que Choisir, all the food and cosmetic products contained nanoparticles, but most labels failed to reflect their presence.  In addition to the complaints filed, UFC-Que Choisir requests that the Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes (DGCCRF) and the Ministry of Economy publish a list of food and cosmetic products containing nanomaterials that fail to meet the labeling requirement, prosecute manufacturers that violate the labeling requirement, and continue to monitor compliance.

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

Owner of Bergeson & Campbell, P.C. (B&C®), 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...

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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.

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