Just eight companies submitted information under the first reporting deadline of Denmark’s nanoregister.
According to a report by the country's EPA, this could be because Danish legislation is regarded as unimportant by suppliers outside the country. Many suppliers are in regions such as Asia and do not easily understand English and these firms are unwilling to pass on information they regard as confidential.
The project was conducted to assess the administrative burdens and costs of companies reporting to the register of mixtures and articles containing nanomaterials.
Another objective was to conduct and present the results so that they can feed into the European Commission’s impact assessment of a possible EU nanomaterial registry. The method used for measurements was compatible with that recommended by the Commission’s impact assessment guidelines.
Business organisations told the EPA that reporting could be improved if there were an EU-wide reporting requirement instead. Experience with REACH shows that suppliers in Asia will gradually adapt to legislation if it is implemented at EU level. However, it is unlikely that the Commission will propose such a step.
According to the report, industry said that rather than persist with the register the EPA could make “targeted analyses of supply chains in industries through strategic cooperation with selected industries or business”. These should be chosen on the basis of risk, “focusing on significant exposure and/or usage of particularly hazardous nanomaterials to avoid a situation that may create a general mistrust in nanoproducts/nanotechnologies”.
One way of mapping the use of nanomaterials, industry said would be to "start at the producers ... and then follow the products down the value chain.”
Denmark's law requires producers and importers of products containing nanomaterials to register them when they are intended for sale to the public, and where the nanomaterials are released. The first deadline was 30 August 2015. It covered the period 20 June 2014 to 20 June 2015.
An added problem is that e-trading of products is not covered by the reporting obligation.
To minimise the burden on business, the law exempts a number of products. These include:
- products on which the nanomaterial is used as a printing ink, directly on the product or on the product label;
- textiles where the nanomaterial is used as ink or for dyeing;
- paints, wood preservatives, glue and filler containing nanopigments; and
- rubber or rubber parts that contain the nanomaterials carbon black or silicon dioxide.
Abolishing these exemptions could lead to “very significant administrative burdens”, says the report, especially for the first three. In these the pigment content often contains nanomaterials, and could result in a very high number of reportable articles. Those businesses and trade bodies interviewed pointed out that the agency had already mapped pigments and questioned whether additional reporting in these areas would add any value.
The Nanotechnology Industries Association (NIA) said the report "estimated administrative burdens on businesses to be as high as 62.3m Danish Krone in 2015, however only 350,000 of this was incurred by companies reporting to the registry. The remaining costs were incurred by companies who had to assess their reporting obligations."