Nanomaterials and Public Disclosure: Are European Nano Product Registries the Answer?

Vol. 29 No. 1

Ms. Bergeson is managing partner of Bergeson & Campbell, P.C. (B&C®), a Washington, D.C., law firm focusing on conventional, nanoscale, and biobased industrial, agricultural, and specialty chemical product regulation and approval matters; environmental health and safety law; chemical product litigation; and associated business counseling and litigation issues. Ms. Mihova is a managing partner at EPPA SA., a Brussels-based specialized management consultancy.

Nano product registries in Europe are the newest twist to satiating the public’s relentless “right to know.” Nominally intended to prevent hazards, facilitate monitoring, and promote consumer choice, nano product registries also risk stigmatizing nano products, diverting limited government and private resources, and potentially creating commercial barriers to a promising technology. We discuss below the efforts of multiple European countries that are presently at varying stages of establishing product registries to keep track of nanomaterials and the products that contain them. After outlining the stated purposes of these registries and explaining how they operate, we explore whether they are achieving their stated goals or inadvertently inviting unintended consequences.

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