Notice of work on nanos at European level  

ECHA puts the turbo on nanos : it has just published three calls for tenders with a view to carrying out work on nanos and their risks. 

A review of knowledge on phytos and nano-additive fertilizers 

The European Chemicals Agency (ECHA) has published a first invitation to tender to make a point of knowledge on nanomaterials in phytosanitary products and fertilizers. Potential service providers have until March 1, 2023 to express their interest, then until March 17, 2023 (date to be confirmed by ECHA) to elaborate on their proposal.

A subject proposed by AVICENN and other European NGOs

This subject of study had been proposed by AVICENN and co-signed by CIEL, Clientearth, EEB and HEAL in July 2022, as part of a call for topics organized by the European Observatory for Nanomaterials (EUON). The commissioned study must: 

• collect, analyze and organize theinformation on nano-additive pesticides and fertilizers intended for agriculture. 
• draw general conclusions about the potential risks associated with them and the challenges of testing these products. 
• evaluate and discuss theadequacy of tools and regulatory framework to ensure the identification and safety of these substances and products.

There is indeed a worrying lack of knowledge regarding the use of nanos in the agricultural sector and the risks associated with it. Agriculture is the sector of use that comes first in the French register r-nano (in number of declarations; for the volume, the information does not exist) and is the subject of numerous nano research and development efforts. However, these nanos are currently not subject to any obligation tolabeling [nano] et very few studies explore the potential limits of these substances, the health risks for agricultural workers, the risks of environmental contamination, as well as the health risks for end consumers. To be continued… ! 

A review of knowledge on the release of nanos by products that contain them

A second call for tenders is planned by ECHA for the realization of a study on the release of nanomaterials from articles and products containing them and on the potential toxicity of the released nanoparticles. The study commissioned by ECHA aims to examine and collect data on: 

• la way and forms in which these nanos are released, 
• their to become after release and the (eco)toxicological issues that are associated with it. 

The deadline to express an interest is March 6, 2023. 

Understand and assess the propensity of nanos to detach from the products and supports on which they are supposed to be attached (during use or during the alteration of these products throughout their life cycle), remains a major challenge in nano risk assessment. At present it is difficult – see impossible – to have a precise idea of ​​the level of exposure nanos from consumers of products that contain them. 

Project Rename in France and Belgium on the release of nanos by masks is a step in this direction, financed by the French authorities. This type of project should be multiplied. to study the release of nanos by all other products (food, packaging, cosmetics, textiles, paints, etc.). This especially since there are regulatory issues at stake : titanium dioxide nanoparticles grafted onto mica plates, in cosmetic products, are thus about to be excluded from the definition of the term nanomaterials in the future Cosmetics Regulation (and therefore the [nano] labeling obligation) on the grounds that they would be “attached” to the mica plates… without there being any proof of this today.

Literature reviews but no new data…

Unfortunately, these two studies will mainly consist of carrying out literature reviews based on existing public information, and not to undertake further researchs, yet essential to fill the lack of data and knowledge vis-à-vis nano applications and the risks associated with them. 

When will real dedicated funding be available? for this type of research in order to answer societal questions and concerns on the subject?

A third call for tenders (already launched) on nano risk assessment in REACH

As part of the upcoming revision of the REACH regulation, another call for tenders was also launched by ECHA to carry out work on the risk assessment of nanomaterials based on their grouping according to toxicological criteria. 

REACH remains indeed a device still very inefficient for the supervision of nanos marketed in Europe. The main objective of the study commissioned by ECHA is therefore to come up with a set of grouping criteria with a view to a potential revision of the methods of registration and evaluation of nanos in REACH.  

The challenge is big : nanomaterials are particularly difficult to group (compared to other conventional chemical substances) because more parameters need to be taken into account to demonstrate structural similarity between two nanomaterials, and even though their physico-chemical properties evolve throughout the life cycle. 

To be continued then…