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Challenges of Regulation and Risk Assessment of Nanomaterials

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<strong>Nanomaterials</strong> in REACH registrations <strong>and</strong> C&L notifications<br />

Quinn B. 1<br />

1 European Chemicals Agency (ECHA), Annankatu 18, P.O. Box 400, 00121 Helsinki Finl<strong>and</strong><br />

ECHA is assisting the European Commission prepare the REACH <strong>and</strong> CLP aspects mentioned in the<br />

2nd Commission communication on the Regulatory aspects <strong>of</strong> nanomaterials. This will involve the<br />

compilation <strong>of</strong> information on nanomaterial types <strong>and</strong> uses, including safety aspects, which has been<br />

reported by the chemical companies either in their registration dossiers submitted under the REACH<br />

<strong>Regulation</strong> or in notifications to the Classification <strong>and</strong> Labelling Inventory submitted under the CLP<br />

<strong>Regulation</strong>.<br />

Since 1 June 2008, ECHA has received more than 26,000 REACH registrations for approximately 4700<br />

distinct substances (7 March 2011) <strong>and</strong> more than 3.2 million CLP notifications for approximately<br />

109,000 distinct substances (1 April 2011). The tiered REACH registration deadlines for existing (or<br />

phase-in) chemicals mean that the registrations received by the 1 December 2010 deadline refer to<br />

those that are manufactured or imported per legal entity at > 1000 tons per year <strong>and</strong> those that are<br />

CMR or have a classification R50/53 that are manufactured per legal entity at greater than 1 <strong>and</strong> 100<br />

tons/year respectively. New substances manufactured or imported after REACH came into force 1<br />

June 2007 are required to be registered when their tonnage exceeds 1 ton/year. The requirement to<br />

make a CLP notification by the 3 January 2011 deadline refers to substances placed on the market at<br />

> 1 ton per year <strong>and</strong> substances classified as hazardous under CLP <strong>and</strong> present in a mixture above the<br />

concentration limits specified in Annex I to CLP or in Directive 1999/45/EC which results in the<br />

classification <strong>of</strong> the mixture as hazardous irrespective <strong>of</strong> tonnage. ECHA therefore has a very large<br />

repository <strong>of</strong> REACH registration <strong>and</strong> CLP notification dossiers that will provide information on what<br />

nanomaterials have been registered or notified <strong>and</strong> are therefore on the market.<br />

ECHA will screen these received registration <strong>and</strong> notification dossiers for those that refer to<br />

nanomaterials <strong>and</strong> compile an inventory <strong>of</strong> nanomaterials based on the information included in<br />

registration dossiers <strong>and</strong> the C&L notifications. For each substance on the inventory, the criteria used<br />

for its inclusion will be given.<br />

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