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EveNanos - The R-Nano register

The R-Nano register

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The R-Nano register

By AVICENN Team – Last Modified June 2022

France, the first country to introduce compulsory declaration of nanomaterials

“Listing nanoparticles from nanotechnology and the production channels” was in 2006 the first recommendation of the Committee for Prevention and Precaution (CPP, attached to the Ministry of Ecology)1Committee for Prevention and Precaution (CPP), Ministry of Ecology, Nanotechnologies, nanoparticles: what dangers? what risks?May 2006.

A year and a half later, the Grenelle de l'environnement pledged to implement a mandatory declaration of the presence of nanoparticles in consumer products from 2008.2Commitment No. 159 of the Grenelle de l'Environnement, November 2007: “the presence of nanoparticles in consumer products will be required to be declared from 2008; systematic cost/benefit assessment before the marketing of products containing nanoparticles or nanomaterials, from 2008; ensure the information and protection of employees on the basis of the AFSSET study”, p.23/35 (as well as the requirement for a systematic cost/benefit assessment before the marketing of products containing nanoparticles or nanomaterials, from the same year).

We still had to wait five more years, but since January 1, 2013 finally came into force mandatory declaration, on the portal, "substances in nanoparticle state" manufactured, imported or placed on the market in France.

This declaration is the result of a long process which gave rise to public consultation and the creation of a multi-actor working group dedicated to the system which continues to meet once or several times a year, led by the Ministry of Ecology. It was institutionalized by the Grenelle 1 law of 2009 and specified in the Grenelle 2 law of 2010 and in decrees No. 2012-232 et n ° 2012-233 of February 2012, supplemented by the of August 2012.

Despite this delay and the deviations from the initial project carried by the Grenelle, France is the first country to have adopted such a system, creating a ripple effect in other European countries.

Who must complete this declaration?

The declaration concerns companies and public and private research laboratories having an activity involving a minimum quantity of 100 grams of a “substance in nanoparticle state”3“substance in the nanoparticle state”: substance intentionally manufactured on a nanometric scale containing unbound particles or in the form of an aggregate or in the form of an agglomerate, of which 50% of the particles, in the size distribution in number, present one or more external dimensions between 1 nm and 100 nm. (This minimum proportion may be reduced in specific cases when this is justified for reasons relating to the protection of the environment, public health, safety or competitiveness. By way of derogation from this definition, fullerenes, graphene flakes and single-walled carbon nanotubes with one or more external dimensions less than 1 nm are to be considered as substances in the nanoparticle state)..

Each year, these companies and laboratories must declare the quantities and uses of nanomaterials that they produce, distribute or import via the site.
The deadline for declaration provided for by the texts is May 1, but the filing deadline was extended by two months for all filers in 20134 In 2013, the Ministry of Ecology, considering the diversity of the actors covered by the declaration obligation, and at the request of several sectors of activity, decided to grant 2 additional months to make the declaration for this first year. declaration; thus, exceptionally, new declarations could be initiated and submitted until June 30, 2013. Cf. Emerging risks: the declaration of substances with nanoparticle status comes into force on January 1, 2013, updated May 7, 2013, then, every year since, it has been postponed for a month, until May 31 therefore (first for distributors to professional users only, then again for all players).

The declarations, as well as the data they contain, are managed by the National Agency for Food, Environmental and Occupational Health Safety (ANSES).

A list of questions and answers (FAQ) is online on the website of the Ministry of Ecology in order to facilitate the understanding of the system by the companies concerned by the declaration or likely to be.

For what purposes was this declaration put in place?

The system, in its current version, has the stated objectives5View decree n ° 2012-232 signed on February 17 and published in the Official Journal on February 19, 2012 from:

  • “better know these substances and their uses”,
  • "have traceability of the channels of use, better knowledge of the market and the volumes marketed"
  • “collect available information on their toxicological and ecotoxicological properties”.

These lenses are no longer exactly those that gave birth to this device6see our paragraph below 'Ambitions revised downwards in relation to the commitment of the Grenelle de l'Environnement'.

A review of the first years since its establishment

Results of the first years: the R-Nano register

All public reports can be downloaded from the website page of the Ministry of Ecological Transition dedicated to nanomaterials.

The results from 2014 to 2017, year by year
  • In 2013, the first year of deployment of the declaration obligation, 3400 declarations were completed, via more than 930 declaring accounts, including more than 90 made by foreign suppliers; in total 670 French entities had participated. At the end of November 2013, an initial assessment had been made public, reporting 500 tonnes of "substances in nanoparticle state" placed on the French market in 000. In total, 2012 substances had been identified after groupings... but none statement on nanosilver! As for carbon nanotubes, they did not appear either, some having been declared and merged into the “carbon” category in the public balance sheet.
  • In mid-November 2014, the 2014 report was made public. 400 tonnes of “nano substances” had been declared as produced or imported into France in 000 – ie 2013 tonnes less than the previous year, despite a tripling of the number of declarations. This time, nanosilver and carbon nanotubes figured well in the balance sheet, but in much lower proportions (respectively less than 100 kg and less than 000 tons) than those supposedly present on the territory.
  • At the end of February 2016, the 2015 report was published: 416 tonnes were imported or produced in 000, with approximately 2014 categories of nano substances and a relatively stable number of declarants.
  • In early November 2016, the 2016 report was published: more than 475 tonnes were imported or produced in France in 000, more than 2015 declarations were submitted and 14 French entities made at least one declaration.
  • At the end of December 2017, the 2017 Report was in turn published. just under 9 tonnes imported or produced in France in 700, a slight decrease compared to the previous year (but a 27% increase in the quantity produced in France)
Reports from 2018 to today
  • It was more than a year late, in December 2019, that the 2015 Assessment was published, with a drop in total tonnage, less than 390 tonnes nanomaterials imported or produced in France in 2017.
  • Le 2019 review, which should have been released in November 2019, was released in June 2020, with a total tonnage relatively stable, which is close to 400 000 tons.

We are still awaiting the publication of the 2020 balance sheets and the 2021 balance sheet...

What are the criticisms leveled at the device?

A “financial and bureaucratic burden” for declarants, when initially setting up the declaration

For declarants, the initial implementation of the declaration represented a significant workload in the first year. But with a good organization and anticipation, and thanks to progress on the r-nano tool, the reporting becomes less cumbersome once it is anchored in business practice, since it mainly involves updating the data every year.

Principles Difficulties in the Declaration

The main difficulties are generally related to:

  • to the problems of definition et characterization of nanomaterials that make it difficult for some companies to:
    – the fact of knowing whether or not companies must complete the declaration
    – providing certain information (particularly concerning the physico-chemical characteristics nanomaterials)
  • to theinadequacy of the system in relation to the reality of supply chains, with notably :
    – confusion around subcontractors
    – technical problems importing data from suppliers located outside France: “A company can import a chemical mixture from Germany that has a premix compounded in Russia with nanomaterials made in Vietnam. The chain to be reassembled is complex », illustrated Sonia Benacquista, in charge of the nano file within the Union of Chemical Industries (UIC)7See more clearly in the world of “nanos”, South West, Jan 11, 2014 in 2014.
    - A more intermediaries than expected but a single deadline for completing the declaration regardless of the category of declarants: the last link in the declaration chain formed by distributors to professional users is in fact dependent on the declaration number provided by their suppliers upstream of the chain (producers, importers or processors themselves sometimes dependent on the declaration number that their own suppliers must transmit to them).


> A staggering over time of the declaration deadline according to the position of the declarants in the supply chain is strongly desired by the distributors who are today in difficulty if they do not obtain the number from the of their supplier(s) only belatedly – ​​and this, even though until the establishment of the declaration obligation in 2013 they were unaware, for many of them, that the products they bought and distributed contained nanomaterials. The deadline for reporting 2014 on 2013 data has been postponed, for distributors to professional users only, to May 31, 2014. Same for the other years.

Ambitions revised downwards compared to the commitment of the Grenelle de l'Environnement

The first years of setting up the system produced results far removed from the expectations of the partners of the Grenelle de l'environnement in 20078Commitment No. 159 of the Grenelle de l'Environnement, November 2007: “the presence of nanoparticles in consumer products will be required to be declared from 2008; systematic cost/benefit assessment before the marketing of products containing nanoparticles or nanomaterials, from 2008; ensure the information and protection of employees on the basis of the AFSSET study”.

As things currently stand, neither consumers nor health authorities are able to identify objects that contain nanomaterials or any associated risks.

a) Public information, left out to preserve industrial and commercial secrecy?

Despite the progress made possible by the creation of this R-nano register, the general public cannot currently identify the products in which nanomaterials are integrated by manufacturers and to which they are exposed.

The objective of informing the public and consumers required by the legislator in 20099There is progress compared to the Nano3 database which had remained confidential: this non-exhaustive inventory of products containing manufactured nanomaterials present on the French market had been carried out by Afsset between November 2008 and May 2009, in the referral framework Nanomaterials – assessment of the risks associated with nanomaterials for the general population and for the environment (Afsset report published in March 2010). It covered products available on the French market as well as those made in France or in neighboring countries. It has not been made public: in February 2011, the VivAgora association publicly deplored that the data in this database is not accessible to everyone (in a VivAgora's contribution to the public consultation concerning the implementing decree relating to the annual declaration of substances with nanoparticle status placed on the market, dated February 24, 2011, which is no longer available online). is currently full minima because it comes up against respect for commercial and industrial secrecy10Art. R. 523-18 of decree n ° 2012-232 signed on February 17, 2012 and published in the Official Journal on February 19, 2012. or military11See thedecree of January 24, 2013 defining the conditions for the presentation and examination of requests for derogation relating to the making available to the public of the annual declaration of substances with nanoparticle status, taken pursuant to article R. 523-20 of the code of the 'environment. The industrial federations have in fact obtained from the Ministry of Ecology that the quantities of nanomaterials be, for example, aggregated at the national level in the public assessments12Frequently Asked Questions on the declaration of substances with nanoparticle status, Ministry of Ecology, V2, March 2013. These do not contain either the names of the manufacturers, importers or distributors and even less of the brands concerned; and do not provide any information on the properties of the declared nano substances (which are not even necessarily declared: the “properties” field is indeed optional!).

Result: the first assessments have so far proved to be very difficult to read and almost unusable!

The device does not go up to thelabeling of nanomaterials declared: once integrated into products, these nanomaterials therefore “disappear” from the view of the consumer.

Only a few rare organizations can have knowledge of only part of the information contained in the register: theMSNA, Public Health France,INRS,INERIS, organizations responsible for toxicovigilance and, since 2017 only, regional waste observatories13Since 2013 (decree n° 2012-233 of February 17, 2012):
– the National Agency for the Safety of Medicines and Health Products (MSNA, which replaced on May 1, 2012 the French Agency for the Safety of Medicines and Health Products (Afssaps) from which it took over the missions, rights and obligations)
– the National Institute for Health Surveillance (InVS)
– the National Institute for Research and Security (INRS)
– the National Institute for the Industrial Environment and Risks (INERIS)
– organizations responsible for toxicovigilance (in other words poison control centres).
And since 2017, regional waste observatories have been added, "for the exercise of their missions and within the limits of the information corresponding to their area of ​​expertise" (decree n ° 2017-765 signed in extremis by the Minister of the Environment Ségolène Royal on May 4, 2017).

Anyone wishing to have information has no other solution than to fall back on the inventories of nano-products which, far from being exhaustive, are developed from industrial claims or hypotheses on the composition of the products, without possible verification, for lack of financial, human and / or technical means.

Many actors plead in favor of increased transparency. It would indeed be conceivable to go further in terms of transparency, as is done for example in the area of ​​pharmaceutical products (drug directory), phytosanitary products (e-phy database) or polluting emissions (the IREP register).

b) Nothing on the protection of employees and the environment

The system does not provide anything to encourage companies and laboratories to respect the protection of the environment and people likely to be exposed to declared nanomaterials (consumers or workers in particular).

Concerning the workers: the declaration completed by the companies or laboratories does not include no indication either of their overall workforce or of the number of workers exposed to declared nanomaterials. Nevertheless, thanks to the registration system and the transmission by the suppliers of the declaration number to their customers, many professional players have been informed by their supplier(s) of the presence of nanomaterials in the products they bought and were in turn able to inform their customers. In the end, more players discover thanks to this declaration that they were handling products containing "nano substances": through this awareness, we can hope that a certain number of them have started to (or will be able to ) implement measures to limit occupational exposure to these substances: is this the case? We are interested in your testimonials (redaction(at)

In the current state of the system, central purchasing bodies and distributors who supply "nano substances" to the general public in addition to professionals have not been subject to the declaration obligation (see question 7 of the FAQ of the R-Nano site in its March 2014 version). DIY stores that sell to individuals and professionals, for example, do not have to complete a declaration.

French authorities reported in August 2014 that “if we also made the last professional user subject to the declaration obligation, which is not currently the case, it would then be possible to have more precise information on the uses, thus contributing to achieve the objective of traceability as well as better consumer information”14Note from the French authorities and answers to questions asked by the European Commission as part of its consultation on transparency measures concerning nanomaterials on the European market, August 2014.

Today, “end” professional users are in fact not subject to declaration: hairdressers, beauticians, mechanics, farmers, house painters, masons, etc. therefore handle products containing "nano substances" often without being informed: theobligation to specify the presence of nanomaterials in the safety data sheets (MSDS) only entered into force in 2021 and is still very little implemented. Environmental and health declaration sheets (FDES) for materials are not covered by this obligation.

The health authorities are not currently in a position to identify all the professions concerned.

Questioned by AVICENN in February 2016, Gérald Hayotte, "Nanos" project manager with the CFDT Confederation, deplores the fact that the “Assessment of the mandatory declaration (R-Nano) still does not make it possible to know how many employees are directly or indirectly exposed to nanoparticles, on our territory. As things stand, it is difficult, if not impossible, to support a precautionary approach or decline preventive actions! ».

c) No limit to the commercialization of nanomaterials

It is not planned, in the current state of the system, to “Cost/benefit balance before the marketing of products containing nanoparticles or nanomaterials” as committed by the partners of the Grenelle de l'environnement in 200715Commitment No. 159 of the Grenelle de l'Environnement, November 2007: “the presence of nanoparticles in consumer products will be required to be declared from 2008; systematic cost/benefit assessment before the marketing of products containing nanoparticles or nanomaterials, from 2008; ensure the information and protection of employees on the basis of the AFSSET study”, p.23/35. The declaration that companies and laboratories must complete relates to nanomaterials manufactured, imported or placed on the market in the past year: it is not part of a registration process prior to marketing authorization, for example. Nanomaterials therefore continue to be marketed without more supervision than before, without consumer or environmental protection.

A "strainer effect"

Many nanomaterials escape declaration. There is a strong "strainer effect" which comes in particular from the very restrictive definition of "substances in nanoparticle state" adopted by the legislator:

  • R-Nano does NOT (or does not necessarily) incorporate nanomaterials intended to remain in the products in which they are incorporated16Le decree n ° 2012-232 signed on February 17, 2012 and published in the Official Journal on February 19, 2012 defines substances in the nanoparticle state as "substances intentionally incorporated into a mixture without being bound to it" (ie "from which they are likely to be extracted or released under normal or reasonably foreseeable conditions of use") (this remains a point to be clarified); however, nanosilver in textiles can for example detach from textiles during washing and carbon nanotubes, although contained in a matrix, can be released into the environment under the influence of sunlight and moderate humidity or abrasion.
  • R-Nano also does NOT include the many nanomaterials which are integrated abroad into the many finished products then imported into France.
Other technical considerations…

Result: for example, substances composed of 45% of particles smaller than 95 nm and 55% of particles larger than 105 nm will therefore not be subject to the reporting obligation.

New or old nano substances?

80% of the substances that were declared in 2013 on the website were already on the market before 1981 without it being possible to know whether they were already in the nano state previously, however manufacturers have confirmed that the most common nanomaterials and those used as pigments or dyes have already been on the market for many years20Study to Assess the Impact of Possible Legislation to Increase Transparency on Nanomaterials on the Market – Evaluation Report, BiPro and RPA, June 2014.

This figure as well as the tiny quantity of declared nanosilver raise the question of the distinction between "new" nanomaterials and more "old" nanomaterials (all things considered), difficult to make today: we are in the dark to quantify the new nanomaterials used for new uses (especially nano-coatings anti-UV or antibacterial or anti-stain or waterproof for example, relatively recent).

Penalties too low?

The fine provided for in the event of non-compliance with the legal obligation, in the amount of 3000 euros, with a daily penalty of 300 euros, is considered to be not very dissuasive.21See Risk Analysis of Nanomaterials: Exposing Nanotechnology's Naked Emperor, Miller G and Wickson F, Review of Policy Research, 32(4): 485, July 2015 (p. 500).

To compare, Belgium, for its part, has planned penalties ranging from imprisonment for eight days to three years and/or a fine of €160 to €4 !

What controls?

In addition, the public authorities have long been powerless to monitor the implementation of the law:

  • At the scientific and technical levels, detect nanomaterials in products is complex (all the more so when they are not declared and their nature and characteristics are unknown physico-chemical) and requires expensive instruments;
  • Until 2022*, there is no there was no deployment of a specific device to control the proper application of the law : the control bodies traditionally used in the context of chemical product controls were not equipped to do so, leading some to consider that the declaration was therefore "just putting pressure on industrialists to declare information with which environmental defense associations will not be able to do much"22"No serious analysis, just putting pressure on industrialists", Interview with Alain Lombard, Engineering Techniques, March 21, 2013.

* At the end of December 2021, a circulation of the Ministry of Ecological Transition announced inspections in 2022 to verify compliance with the reporting obligations for nanomaterials in the French r-nano register (and in REACH). The establishments targeted will be companies likely to manufacture substances in nanoparticle form. The list of establishments concerned will be established by the DGPR on the basis of the data to which it has access, within the limit of ten per region. As part of this action, samples of certain pure substances may be taken and analyzed by the Joint Laboratory Service (SCL) in order to detect the presence of nanoparticle forms of the substance.

How to envisage an improvement of a device still too limited?

What prospects? What data exploitation?

Public assessments leave many players unsatisfied, due to the very general and hard to use nature of the data disclosed.

According to the Ministry of Ecology23Nanomaterials, Ministry of Ecology website > Risk prevention > Management of chemical products > Nanomaterials, page consulted on 18/11/14 :

  • In 2014, declared data relating to carbon nanotubes and nano-titanium dioxide were communicated to InVS as part of the project Epinano for monitoring cohorts of workers exposed to nanomaterials.
  • In 2014, INERIS also had to use certain data from the R-nano database as part of its support programs for the Ministry of Ecology, in particular for the assessment of accidental risks (flammability, explosiveness).
  • In 2015, theANSES relied on a working group to determine and list the uses that can be made of the data collected as part of the Agency's assessment work. This group met 6 to 8 times without succeeding in establishing lists of priority substances.

Another question: does ANSES have sufficient resources to analyze the information collected?

What improvements should be made to the device?

The challenge is therefore to remedy the weaknesses of this highly commendable system in order to consolidate it, because, in the opinion of a growing number of associations and scientific experts24See for example When enough is enough, J. Hansen & A. Baun, Nature Nanotechnology, 7, 409-411, 2012, It is urgent to take action.

A revision of instituting mandatory reporting had been planned for 2015 to clarify certain points of the text. But it was suspended from the decision that the European Commission had to take following the consultation in 2014 concerning the establishment of a possible EU-wide nano register. Since the Commission has not decided to set up a European register similar to R-Nano, different national registers (French, Belgian, Danish, Swedish, etc.) coexist, with non-optimized interoperability.

The improvement proposals put forward by AVICENN for several years

Since 2013, AVICENN has issued concrete recommendations aimed in particular at improving access to the register, as well as the nature and quality of the data collected via R-nano25See 20 proposals compiled in June 2019 by AVICENN as part of the prefiguration of the 4th national health-environment plan (PNSE4).

a) Expand the register to include nanomaterials that currently escape notification
  • Ensure that the system includes the obligation to declare nanomaterials which may be released outside of "normal conditions of use", in order to include products containing nanomaterials which may be released as a result of wear, abrasion or washing of products but which are not currently registered in R-nano.
  • Integrate into the R-Nano device the nanomaterials that are integrated into finished products made abroad before arriving in France (because they escape the register today!)
  • Extend the reporting obligation to mixtures and not only to nano substances, as is the case in the belgian system and in the danish device ?
b) Improve the identification of end uses of declared nanomaterials and products containing these nanomaterials

In the r-nano tool, there is no way to quantify, for a given use, the weight of the nano substances concerned, which constitutes a very damaging limit for traceability and risk assessment.

  • Since 2016, it has been mandatory to provide information, in addition to the "sector of use" (SU) which was until then the only descriptor required today, the other descriptors used by ECHA: "chemical product" (PC), "process" (PROC), "article" (AC), "release into the environment" (ERC): this is a step forward which has made it possible to refine knowledge of the uses of declared nanomaterials, but there are all the same there is a need to adopt another typology that is more relevant and more “meaningful” for the general public.
  • It should also be mandatory to request the NACE and/or NAF code of the customers of the last declaring professional distributors
  • Linking the quantities to the uses would allow a quantification of nanomaterials by type of use, because in the current state of the system, even the administration cannot determine, for a given type of nanomaterial, what quantity is used for such use!
  • In the long term, if we advance in parallel on the site of labeling, one can imagine that a mention [nano] will be obligatorily affixed in front of the name of the substance concerned in the list of ingredients and that a QR-code could also be added to the label of the products and refer to a section to be created on the R-nano site containing more precise information on the nanosubstance in question and its risks to health and the environment; Without waiting for the creation of a hypothetical European register, a national register of products containing nanomaterials could eventually be set up by pooling information with the Belgium and Denmark who have taken similar initiatives.
c) Enable use of the registry for monitoring and prevention purposes
  • Enable the location of sites where declared nanomaterials are handled
  • Mandatory request the number of workers potentially exposed to declared nanomaterials and enter in the EpiNano cohort workers exposed to carbon nanotubes, nano-titanium dioxide, silica nanoparticles and carbon black
  • Oblige the last declarants to communicate to the professional users to whom they supply the "nano substances", in addition to the declaration number (cf. Stopped of August 6, 2012, Art. 3, II), information on the reasons for the R-Nano device and the risks associated with these substances.
d) Extend the right of access to data to other actors involved in risk assessment or management

Prevention workers and in particular occupational health services (the CARSATs but also the DREETS (former DIRECCTES that have become Regional Directorates for the Economy, Employment, Labor and Solidarity) which lead regional occupational health policy in companies, the DETSPPs at departmental level which house the labor inspectorate), do not have regulatory access to R-nano data : they cannot therefore use it to identify risk sites or exposed workers.

It is becoming essential to extend it to other public actors or those carrying out public service missions, so that they can identify and protect exposed workers and sites. More broadly, researchers and environmental protection or public health professionals should be able to obtain extractions from the R-nano register, which would benefit everyone by pooling vigilance efforts. The issue of emerging risks is an occupational health concern in many regions which have included it in their regional occupational health plans (PRST). However, without visibility on the companies concerned, information actions are not possible or at least made difficult.

e) Pool information in the agricultural field
f) Set up a declaration control system

It took nearly ten years for a control system to be put in place to ensure compliance with the reporting obligation by companies.

The metrology problems and the slowness of standardization groups in terms of nanomaterial measurement methodologies, which come up against major obstacles, do not explain everything.

Not only do manufacturers know that technical capacity is lacking today, but there is also little political will to monitor compliance with the law.

The OECD recalled at the end of 2015 that the identification and quantification of flows of manufactured nanomaterials are priority issues to be addressed as soon as possible.26See Nanomaterials in waste streams, OECD, November 2015. A whole lot of work remains to be done to refine the improvements to be made to the R-nano register. In addition to the previous points, however, progress should be made on the following aspects:

  • what additional data to collect? less? other ?
  • how best to use them? (In 2015, theMSNA hadn't grabbed the data from the R-nano register yet!)
  • how to better use the R-nano register to issue recommendations and targeted prevention or monitoring actions?
  • how can the register allow better traceability and identification of exposed workers – not only during the production/handling phase of nanomaterials, but also downstream of the production chain (professional users at the end of the chain: masons, mechanics , hairdressers, farmers, bakers, pastry chefs, hospital staff, etc.)?

Once reconfigured, the "R-Nano 2.0 register" should also allow manufacturers and distributors to recall marketed products in the event of a health or environmental problem.

From a technical point of view, scientists are asking to add, among the parameters to be entered in R-Nano, the solubility of the nanoparticulate substance (as recommended by the ISO and the OECD) – see also the recommendations established as part of the project aimed at setting up a Universal Nanoscale Materials Description System (UDS).

Even if the instruments and methods for detecting, measuring, monitoring and controlling nanomaterials still need to be improved, it is already technically possible to take and store samples for analysis when these instruments and methods are developed.27See Nanomaterials: A review of definitions, applications and health effects. How to implement safe development, Eric Gaffet, Physical Reports, Volume 12, Number 7, Pages 648-658, September 2011 .

The idea is to be able to correlate the volumes of nanomaterials released with any problems that could be observed in the short, medium and long term. By setting up various cartographic and experimental tools, it would be possible to build a collective and operational vigilance associating the suppliers of nanomaterials and the purchasing centers of the large distributors of consumer products, in order to record the flows of products containing nanomaterials. sold (starting with nanosilver), to map the places of distribution and potential release then to carry out an observation over time and in the field, for example on a catchment area with the participation of water managers.

In December 2020, the publication of an assessment of r-nano by ANSES

At the end of 2020, ANSES published a enlightening diagnosis and strong recommendations to improve the r-nano registry, in which AVICENN finds itself completely. It remains to be seen if, how and when ANSES's recommendations will be implemented.

In May 2021, the improvement of r-nano registered in the PNSE 4

The ball is now in the court of the Ministry of Ecological Transition, which must pilot, as part of the PNSE4, actions aimed at "improve the quality of the data declared in the R-Nano register and optimize access to the register data by scientific or expert bodies as well as the publication of the data".

ANSES has set up a working group on "the consolidation and use of data declared on substances with nanoparticle status" which began its work in March 2022.28A call for applications was launched between September and November 2021.

In 2022, the HCSP in turn insists on the improvements to be made to the r-nano device

The High Council for Public Health (HCSP), in its assessment of PNSE 1, 2 and 3 published in 2022, also considers29See Overall assessment of National Health-Environment Plans (2004-2019), HCSP, March 2022 which “the r-nano register must be improved because it is poorly filled out by manufacturers and difficult to use because access is too restrictive. Its openness must be wider and, in particular, to researchers working on the relationship between exposure and health effects in epidemiological studies." page (in French).

The HCSP is also in favor of an increase in resources dedicated to r-nano: “ ANSES has a single person to manage the R-Nano register, respond to requests from declarants, support them and produce the annual report, which is notoriously insufficient to steer and lead the action”.

Other more or less similar mechanisms in several European countries

The R-Nano register set up in France since 2013 is spreading: several other Member States have set up more or less similar devices.

The establishment ofa European register products containing nanomaterials marketed in Europe has so far always been rejected by the European Commission.

Yet even Chinese scientists advocate mandatory registration of nanomaterials30See Regulation of engineered nanomaterials: current challenges, insights and future directions, Environmental Science and Pollution Research, 1-18, 2017: “Compulsory reporting schemes (registration and labelling) for commercial products containing ENMs should be adopted”.

A question, a remark ? This sheet produced by AVICENN is intended to be supplemented and updated. Please feel free to contribute.

The next nano appointments

Unnoticed and ungoverned: How nanomaterials are slipping through the cracks (ECOS, Brussels and online)
Brussels and online
  • Hybrid event (face-to-face and online)
  • Organizers: Environmental Coalition on Standards (ECOS), Friends of the Earth Germany (FEDERATION)
  • Speakers: representatives of the European Commission, civil society and research  
  • Website :…
NanoSafe conference 2023 (CEA, Grenoble)
  • 8th International Conference on Health Issues for a Responsible Approach to Nanomaterials
  • June 5-9, 2023
  • Organizer: Commissariat for Atomic Energy and Alternative Energies (CEA)
  • Website :…  
How the world deals with Materials on the Nanoscale – Responsible Use and Challenges (OECD-BMUV, Berlin)
  • International conference from June 22 to 23, 2023
  • Organizers: OECD, German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV)
  • Website :…

This listing was originally created in February 2019

Notes & references

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