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April 22, 2023

France Extends Due Date for R-Nano Declarations to May 31, 2023

Lynn L. Bergeson Carla N. Hutton

In France, under Decree No. 2012-232, companies that manufacture, import, and/or distribute a “substance with nanoparticle status” in an amount of at least 100 grams per year must submit an annual report with substance identity, quantity, and use information. According to the R-Nano website, managed by the French Agency for Food, Environmental and Occupational Health and Safety (ANSES), the declaration form has evolved since 2022 to require the completion of certain fields in accordance with the regulations. Substances must also be characterized according to the analytical methods listed in the form. The website states that for the 2023 reporting year, “it is important to provide the required characterization methods for your substances.” The website includes the following messages:

  • Message to Distributors: According to ANSES, data import will only be possible with declarations created from 2022. Therefore, to ensure that distributors can declare before the end of the fiscal year, ANSES encourages them to contact their suppliers to obtain an updated declaration number that corresponds to the supplier’s last declaration, and that contains all the data required by the regulations; and
  • Message to Importers and Manufacturers: ANSES invites importers and manufacturers to submit their declarations “as soon as possible” to allow their customers to make their declarations within the regulatory deadline. For substances distributed prior to 2022 that contribute to an activity requiring a declaration by their customers, ANSES asks that suppliers provide an updated declaration number to their customers when requested, even if they do not have any declared activity. ANSES notes that in all the cases, the supplier must transmit the declaration number as soon as possible to all French entities receiving a substance concerned by the R-nano declaration.

An extension of the closing date of the declaration, to May 31, 2023, is granted to all the actors