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September 16, 2014

Guideline Published for the Danish Inventory of Nanoproducts

Lynn L. Bergeson

In August 2014, the Danish Environmental Protection Agency published the Guideline for the Danish Inventory of Nanoproducts, which is intended to explain how manufacturers and importers of products for consumers should use the new Inventory. The Guideline describes who has a duty to report; which products must be reported; and how to collect information and perform the actual reporting to the Inventory. The Guideline uses questions to determine whether a product must be reported, including the following:

2.         Is your product covered by other regulations?

If you are a manufacturer or importer of only one or more of the following products (mixtures or articles), you are not obliged to report these (see section 3), and you do not have to do anything further:

2.1. Foodstuffs and food contact materials

2.2. Animal feed

2.3. Medicinal products

2.4. Medical devices

2.5. Cosmetics

2.6. Pesticides

2.7. Waste.

For manufacturers and importers that are not exempt, the Guideline includes a flow chart to help determine whether their products are nanoproducts that need to be reported to the Inventory. Manufacturers and importers of products for consumers that must be reported must report by August 30, 2015, for the period beginning June 20, 2014, and ending June 20, 2015.