5 March 2021
The Verband der Mineralfarbenindustrie e. V. (VdMi), which represents German manufacturers of inorganic, organic, and metallic pigments, fillers, carbon black, ceramic and glass colors, food colorants, artists’ and school paints, masterbatches, and products for applied photocatalysis, has published a “Comparative Compilation of relevant nano definitions in different regulations and their corresponding consequences.” The compilation notes that pigments and fillers often fall under the legislative definitions of nanomaterials “because they show their best properties with correspondingly small particle sizes — without being intentionally a nanomaterial.” VdMi states that the variety of product-specific regulations “often results in different consequences for the same product, depending on the application.” For example, according to VdMi, “no uniform definition for a nanomaterial has been found within [European Union (EU)] legislation to date.” For consumers, these discrepancies “are incomprehensible and weaken the trust in a comprehensive risk assessment and appropriate risk management.” For industry, “it is often difficult to understand the various requirements, especially in the field of downstream users close to end customers.”
VdMi intends the compilation “to provide an initial overview of the nano-definitions implemented in the various EU regulations and their differences, as well as — according to our interpretation — the resulting consequences for the products concerned.” The compilation does not include national regulations, such as nano registration registers. VdMi notes that the compilation “does not claim to be complete and will be updated and expanded as necessary. The legal basis for all matters is always the corresponding legal text.” The compilation is available in German and English.