The executive director of the European Chemicals Agency (ECHA) has indicated that chemical manufacturers in the European Union that make nanoscale versions and larger forms of the same chemical or companies that export to EU countries should combine the volume of both types of chemicals to determine their registration deadline under REACH.
Although the volume should be combined for registration purposes, manufacturers should address questions about the safe use of nanoscale versions and larger forms separately as they comply with a provision of REACH that requires them to prepare Chemical Safety Assessments and Chemical Safety Reports if the total tonnage is 10 metric tons or more. That means, according to ECHA, that manufacturers should evaluate how the nanoscale form of the chemical can safely be used throughout its life cycle and separately discuss how the larger form of the same chemical can be used safely throughout its life cycle. Those analyses will generate additional information about nanomaterials to help ensure they are made, used and disposed of safely. (Source: FMA, FEMA)