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June 16, 2020

EUON Nanopinion Addresses Pigments, “the Oldest Nanomaterials in Human History”

Lynn L. Bergeson Carla N. Hutton

The European Union (EU) Observatory for Nanomaterials (EUON) posted a Nanopinion on June 12, 2020, entitled “Pigments:  The oldest nanomaterials in human history facing modern day challenges.”  Dr. Heike Liewald, Managing Director, Eurocolour e.V., and Giuliana Beck, Advisor, German association of producers of pigments and fillers, describe how the introduction of nano-specific requirements in statutes has significantly increased the regulatory burden.  The authors state that while many pigments have been produced in the same way over several decades without any safety concerns, the nano-specific requirements introduced more recently have increased the reporting and safety obligations, even though the product itself or information on its safety has not changed at all.  The authors review the various nano-specific requirements, noting that the lack of harmonization among statutes means that the same pigment may be a nanomaterial under one regulation but not another.  According to the authors, there is a divergence between the amended Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Annexes and the REACH guidance documents, leading to more confusion instead of more clarity.  The authors state that the objective of the industry is to avoid unjustified restrictions or use bans, and they recommend that downstream legislation take into account whether pigments and fillers are tightly bound to a matrix or paste preventing direct contact with single nanoparticles.