Discussion about labelling and reporting schemes for nanomaterials in consumer products in the EU
JRC experts provide an overview on how EU legislation addresses nanomaterials, and recapitulate issues relevant for the on-going discussion on transparency and requests for more information regarding the use of nanomaterials in consumer products
Specific physical and chemical properties of nanomaterials can make them attractive to a wide variety of applications such as water-repellent clothing, self-cleaning paints and more efficient electronics. On the other hand, such properties may also give reasons for concern regarding their safety for human health and the environment. The European Parliament together with several EU countries have called for more transparency, traceability and information for consumers regarding the use and possible exposure to nanomaterials, by the introduction of registers for products which contain nanomaterials or make use of nanotechnology, and/or by labelling of such products.
To address this topic, JRC experts have published a report which discusses labelling and reporting schemes for nanomaterials in consumer products in the EU. Currently the EU legislation requires nanomaterials to be reported in the list of ingredients, with "nano" added in brackets after the substance name, for food, cosmetics and biocides. Importantly, this labelling should be understood as risk-independent, as the nanomaterial presence does not automatically imply a risk. In addition, voluntary "nanoclaims" indicating the presence or absence of nanomaterials are sometimes added by manufacturers on different types of consumer products, mainly for marketing reasons.
Whereas labelling of products provides information to the consumer at the time of purchase, a product register may give a better overview of the overall application of nanomaterials and potential exposure of humans and the environment. Mandatory reporting to the European Commission is already required for cosmetic products containing nanomaterials. Some EU Member States (France, Belgium and Denmark) have already in place or are introducing mandatory reporting schemes for a wider range of consumer products. Several EU Member States, including Austria, Croatia, the Czech Republic, Denmark, France, Germany, Italy, Luxembourg, the Netherlands, Spain and Sweden would prefer a harmonised central EU nanomaterials register. The authors of the report emphasise that only mandatory reporting/labelling of products containing nanomaterials can assure accurate and comprehensive information. Harmonised procedures are needed to avoid trade barriers and unfair commercial practices.
Finally, a claim of the presence (or absence) of nanomaterials in products should be verifiable ; the report gives an overview of experimental methods available for this purpose, explaining that routine application of detection methods in complex products, such as in cosmetics or food, still needs considerable development.