All products imported into the EU will be required to report use of nanomaterials starting 1 January 2020. This is not optional. To comply with the reporting, you will be will need to get this information from your suppliers of parts that use nanomaterials.

Your first thought, “Well that doesn’t apply to us, so we don’t need to do anything.” STOP. You are not thinking this through. Nanoparticles may have been used in many of your parts and subassemblies for years. Nanoparticles can contribute to stronger, lighter, cleaner, resistant, durable, and “smarter” surfaces and systems.

For example, in automotive parts nanoparticles have been used fillers in tires to improve adhesion to the road. I purchased a set of “Ecopia” tires that improved gas mileage more than 8 years ago. The stiffness of the car body can be improved by use of nanoparticle-strengthened steels. Nanometer thick antireflection layers of silicon dioxide or other materials can be applied to displays or indicator panels to make them scratch resistant and self-cleaning. They can be added to paints for improved crack and weather resistant. Employees, customers or users may come into contact with nanoparticle aerosols from mechanical processing of parts or components. Therefore, exposure to nanoparticles may happen after the initial manufacturing process. Nanoparticles exhibit increased diffusivity with decreasing size which translates into potentially increased dwell times in the air. In the presence of larger microparticles, as with the wide size distribution in aerosols such as smoke, the highly diffusive character of nanoparticles may lead to faster agglomeration or impaction on the larger particles. Furthermore, many particles, including metallic particles, are highly pyrophoric and there is a considerable risk of dust explosions.

It is likely that one or more of the parts of your product use a nanomaterial. The original manufacturer of the nanomaterial is required to get it authorized in the EU (if imported) and you need to report any use to your customers and recyclers.

See the link for the news release from ECHA which discusses registration and downstream user obligations.

  • What are the uses of nanoparticles in consumer products?

As always, this article is not a complete thesis on this topic. If you suspect that you need more information, than you should be responsible and find it.