A European nano-registry as a reliable database for quantitative risk assessment of nanomaterials? A comparison of national approaches

Despite the fact that nanomaterials have been in use for decades and chemicals legislation is largely harmonised within the EU, quantitative and safety-relevant information on nanomaterials is still scarce. In particular, information about production volumes, their unique physicochemical properties (size, specific surface area, etc.) and nanomaterial exposure, which may lead to adverse effects on human health and the environment, is still lacking. While the latest amendments of the REACH Annexes have led to certain improvements, a harmonised EU-wide nano-registry would provide additional quantitative data for risk assessment but is not foreseeable for the near future. Since the European Commission, the European Parliament and some member states take contrasting approaches to the regulation of nanomaterials, France, Belgium, Denmark, Sweden and Norway (as a country of the European Economic Area), launched national mandatory reporting systems to collect quantitative information, thus fostering early risk assessment of nanomaterials. In this study, we compare national registries - based on a literature review and expert interviews - and show differences between the regulations under the respective national laws and REACH regulation. These include, for instance, thresholds for notification and level of detail on the specification of the nanomaterial, mixture and/or product, the definition of exceptions for the requirement to register and the timing of registration. As this heterogenous regulatory framework hinders comparability and potentially creates trade barriers, we argue that a harmonised EU-wide nano-registry would substantially improve the current situation by promoting the safe and sustainable handling of nanomaterials, increasing transparency and trust, and consequently nurturing innovation. Such an EU-wide nano-registry should both cover nanomaterials as substances or mixtures, such as in REACH registration, and the semi-/finished products they will be used in, since the exposure, and thus the hazardous potential of released nanomaterials during their life cycle, depends largely on the scope of application.