Notice of work on nanos at European level

ECHA is putting the turbo on nanos: it has just published three calls for tenders in order to have work done on nanos and their risks.

A review of knowledge on nano-additivated plant protection products and fertilizers

The European Chemicals Agency (ECHA) has published a first call for tenders to conduct a state of knowledge on nanomaterials in plant protection products and fertilizers. Potential providers have until March 1, 2023 to express their interest, and then until March 17, 2023(date to be confirmed by ECHA) to detail their proposal.

A topic proposed by AVICENN and other European NGO

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

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

There is indeed a worrying lack of knowledge about the use of nanos in the agricultural sector and the associated risks. Agriculture is the sector of use that comes first in the French r-nano register (in terms of number of declarations; for the volume, the information does not exist) and is the subject of many nano research and development efforts. However, these nanos are currently not subject to anylabelling obligation [nano] and 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 risks for the health of final consumers. To be continued… !

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

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

• the way and the forms in which these nanos are released,
• their fate after release and the associated (eco)toxicological issues.

The deadline for expressions of interest is March 6, 2023.

Understanding and assessing the propensity of nanos to detach from the products and substrates to which they are supposed to be attached (during use or when these products are altered throughout their life cycle), remains a major challenge in nanos risk assessment. At present, it is difficult – if not impossible – to have a precise idea of the level of exposure to nanos of consumers of products that contain them.

The Renaame project in France and Belgium on the release of nanos by masks is a step in this direction, funded 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 nanoparticles of titanium dioxide grafted on mica plates in cosmetic products are thus about to be excluded from the definition of nanomaterials in the future Cosmetics Regulation (and therefore the obligation of labelling [nano]) on the grounds that they would be “attached” to the mica plates… without any proof today.

Literature reviews but no new data…

Unfortunately, these two studies will mainly consist of literature reviews based on existing public information, and not to undertake additional researchs, which are essential to fill the gap in data and knowledge regarding nanos applications and their associated risks.

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

A third call for tender (already launched) on nanos risk assessment in REACH

In the context of the upcoming revision of the REACH regulation, another call for tender has also been launched by ECHA to carry out work on the risk assessment of nanomaterials based on their grouping according to toxicological criteria.

REACH is still a very inefficient system very ineffective 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 for a potential revision of the registration and evaluation of nanos in REACH.

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

To be continued…