The four trade association CEFIC (European Chemical Industry Council), NIA (Nanotechnology Industries Association), Eurometaux (European Association of Metals), and IMA (Industrial Minerals Association) – Europe submitted joint comments on two documents, presented by the European Commission to the 1^st Meeting of the newly-established REACH Competent Authorities subgroup on Nanomaterials (CASG Nano) (held on the 1^st and 2^nd July 2008).

The creation of the CASG Nano had been agreed during the 3^rd REACH Competent Authorities meeting (held on the 27^th and 28^th March 2008), in order to analyse how REACH applies to nanomaterials.

1. Concern: Discussion paper on how Nanomaterials are covered by REACH (Agenda Point 6.2) (CASG Nano/03/2008)
2. Concern: Supply of Information (Agenda Point 8.2) (CASG Nano/05/2008)

The four abovementioned trade association submitted detailed comments to both documents:

• CEFIC's, NIA's, Eurometaux', and IMA's Comment on CASG Nano/03/2008 (i.e. Discussion paper on how Nanomaterials are covered by REACH) provides, amongst more detailed comments, general support ‘of the assessment given in the Commission’s document and specifically appreciates that the Commission’s position has been clarified on the following issues:
  -        that the Commission concluded that substances at nanoscale are sufficiently covered by REACH and therefore its provisions apply; 
  -        that REACH deals with substances, in whatever size, shape or physical state and 
  -        that the provisions of REACH are underpinned by the precautionary principle.’

• CEFIC’s, NIA’s, Eurometaux’, and IMA’s Comments on CASG Nano/05/2008 (i.e. Supply of Information) outlines the industries’ opinion on a proposal for initiating a voluntary reporting scheme was tabled with the intention of gathering data, and more detailed information about the applications, volumes produced and used, of nanomaterials, presented during the 1^st CASG Nano Meeting (1^st – 2^nd July 2008).