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Home > Nanotechnology Columns > Bergeson & Campbell, P.C. > ECHA Interviews KEMI Regarding Nano Reporting Requirement

Lynn L. Bergeson
Managing Director
Bergeson & Campbell, P.C.

Abstract:
The May 2018 ECHA Newsletter includes an interview with Robert Johansson, Head of the Swedish Chemicals Agency's (KEMI) Chemical Statistics and Registries Unit.

May 24th, 2018

ECHA Interviews KEMI Regarding Nano Reporting Requirement

The May 2018 ECHA Newsletter includes an interview with Robert Johansson, Head of the Swedish Chemicals Agency's (KEMI) Chemical Statistics and Registries Unit. See https://newsletter.echa.europa.eu/home/-/newsletter/entry/swedish-national-products-registry-more-information-on-nanomaterials?_cldee=Y2h1dHRvbkBsYXdiYy5jb20%3d&recipientid=lead-5f1702cfc0e0e71180fa005056952b31-a1e26103bcf84c8b8c352d8582379d0f&esid=77847081-9759-e811-80fe-005056952b31&urlid=21 As reported in our December 7, 2017, blog item, KEMI has established a mandatory reporting scheme to obtain information on the quantities and types of nanomaterials used in Sweden, with the first reports due in February 2019. See https://nanotech.lawbc.com/2017/12/sweden-announces-product-registration-requirement-for-nanomaterials/ According to Johansson, "[t]his information can then provide a basis for making changes to legislation or taking other measures regarding nanomaterials, in areas such as healthcare, the environment or workplace safety." The article provides the following list of actors required to notify if their products contain nanomaterials:

- Professional manufacturers or importers of chemical products and biotechnical organisms;
- Those who, in their own name, package, repackage, or change the names of chemical products or biotechnical organisms for further distribution;
- Those who make mixtures of chemical products and biotechnical organisms for further distribution;
- Manufacturers or importers of notifiable chemical pesticides; and
- Third parties that report the products on behalf of the manufacturers or importers.

According to the article, Kemi expects to receive between 900 and 2,600 notifications. The current reporting requirements include exemptions for nanomaterials that occur naturally or are accidentally produced, as well as nanomaterials used as pigments. Johansson notes that these figures are somewhat uncertain and are based in part on a study made at the European Union (EU) level. The article offers tips for other countries planning to establish a national registry. Johansson suggested that when setting up a national registry, it should "be planned together with different stakeholders, taking into account their views and needs during the entire process."

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