April 18, 2021

Volume XI, Number 108

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April 16, 2021

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VdMi Publishes Comparative Compilation of Nano Definitions and Their Consequences

The Verband der Mineralfarbenindustrie e. V. (VdMi), which represents German manufacturers of inorganic, organic, and metallic pigments, fillers, carbon black, ceramic and glass colors, food colorants, artists’ and school paints, masterbatches, and products for applied photocatalysis, has published a “Comparative Compilation of relevant nano definitions in different regulations and their corresponding consequences.”  The compilation notes that pigments and fillers often fall under the legislative definitions of nanomaterials “because they show their best properties with correspondingly small particle sizes — without being intentionally a nanomaterial.”  VdMi states that the variety of product-specific regulations “often results in different consequences for the same product, depending on the application.”  For example, according to VdMi, “no uniform definition for a nanomaterial has been found within [European Union (EU)] legislation to date.”  For consumers, these discrepancies “are incomprehensible and weaken the trust in a comprehensive risk assessment and appropriate risk management.”  For industry, “it is often difficult to understand the various requirements, especially in the field of downstream users close to end customers.”

VdMi intends the compilation “to provide an initial overview of the nano-definitions implemented in the various EU regulations and their differences, as well as — according to our interpretation — the resulting consequences for the products concerned.”  The compilation does not include national regulations, such as nano registration registers.  VdMi notes that the compilation “does not claim to be complete and will be updated and expanded as necessary.  The legal basis for all matters is always the corresponding legal text.”  The compilation is available in German and English.

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©2021 Bergeson & Campbell, P.C.National Law Review, Volume XI, Number 57
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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

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...

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Carla Hutto, Bergeson Campbell PC environmental law regulatory analyst,Toxic Substances Control Act law attorney
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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...

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