The Nanotechnology Industries Association (NIA) has submitted detailed comments to the public consultation on the Proposal for European Commission definition of the term 'nanomaterial'. In its comments on the recommended definition, the association strongly urges the European Commission to conduct an impact assessment for the recommended definition before a final definition of the term 'nanomaterial' is set.
In general the NIA welcomes the initiative of the European Commission in developing a definition of term 'nanomaterial', which is overarching and broadly applicable as a reference term for any communication performed and policy action taken by EU stakeholders, including EU Member States and EU agencies. It also urges the Commission to also explicitly invite other stakeholders (e.g. NGOs, consumer groups, etc.) to use the recommended definition.
The NIA disagrees, however, with the recommended threshold of '1% of their number size distribution' because this threshold is neither based on current scientific knowledge, nor on technical capability, and is therefore not implementable.
Registered NIA Members can download the respective comments submitted by the CEN/TC 352. Member and non-members can follow this link to download the full NIA Comments.