A study recently publishes by the German Federal Environment Agency (UBA) has concluded that ‘the creation of [a] horizontal European register of products containing nanomaterials, which is buil[t] on present substance- and product-related regulations, is preferable to a separate register’. The findings, presented in Assessment of Impacts of a European Register of Products containing Nanomaterials, indicate that a register making use of existing regulatory obligations would result in ‘significantly lower costs’.
Savings for substances in the European register that are already registered under the REACH Regulation are expected to be between 90-95%, 80% in cosmetics, 95% for food (by making use of the EC’s Novel Food Regulation), and 40% for cleaning and disinfectant products (by make partial use of the EC’ Biocidal Products Register). The study also indicates that ‘the extent of notification between the various sectors differs considerably, with coatings and inks, rubber, paper, health care and cosmetics likely being subject to the most notification requests.
The study was also said to provide ‘important insights into factors that have a high impact on the cost-benefit ratio of a register’. It was found that implementation costs ‘are 4 to 5 times higher than the recurring costs’, as a company would need to adapt its business procedures, undergo administrative changes and train staff in order to comply. UBA also found that ‘the costs for substances are an order of magnitude lower compared to the costs of mixtures and articles’.
A sector specific assessment that would ‘allow statements about the relative price effect on specific product groups’ was not available due to a lack of data. In fact, a lack of input on the calculations of costs is acknowledged by the authors, who admit that they were forced to calculate many of the costs ‘based on assumptions’. Nevertheless UBA decided to publish the study ‘as a basis for further reflection and discussion on the impact assessment’.
Follow this link to read the full report by UBA.