EUON, a European Commission (EC) funded observatory set up in 2016 and managed by the European Chemicals Agency (ECHA), conducted a consumer study among 5,000 citizens across five EU countries – Austria, Bulgaria, Finland, France and Poland – to measure and analyse how people perceived nanomaterials and their potential risks to human health and the environment.
Findings showed that whilst overall awareness on the nature, characteristics and properties of nanomaterials remained low, there was an “increased awareness of the risks and benefits of products containing nanomaterials” compared to earlier surveys. And this rising awareness, EUON said, was “expected to continue increasing in the future”.
What is a nanomaterial?
According to the European Commission definition of a nanomaterial, adopted in 2011, it is:
A natural, incidental or manufactured material containing particles, in an unbound state or as an aggregate or as an agglomerate and where, for 50 % or more of the particles in the number size distribution, one or more external dimensions is in the size range 1 nm - 100 nm.
In specific cases and where warranted by concerns for the environment, health, safety or competitiveness the number size distribution threshold of 50 % may be replaced by a threshold between 1 and 50 %.
By derogation from the above, fullerenes, graphene flakes and single wall carbon nanotubes with one or more external dimensions below 1 nm should be considered as nanomaterials.
Labelling and consumer communication
Importantly, the study indicated that EU citizens “demand better labelling of everyday products containing nanomaterials”, EUON said.
Findings revealed 87% of respondents wanted to know if a product they were buying contained nanomaterials, communicated either on a label or on-pack. This was especially important for consumers when buying food and food-related products and cosmetics.
But EUON said to understand exact labelling expectations among consumers, the study would need to be expanded to all 27 EU countries with additional questions – a move it recommended and that, if implemented, would “support authorities and regulators to improve the information and communication on nanomaterials”.
“[The study] outlines a need for further research to determine the most appropriate type of labelling for products containing nanomaterials and whether existing labelling requirements would need to be adapted.”
Future focus had to be about ensuring consumers “better understand how nanomaterials and nanotechnology are used in different products”, EUON said.
“…The key recommendation of the study is to increase European citizens’ awareness of nanomaterials, including their benefits and risks, to ensure the public can make informed choices. This is to be achieved through sharing of information and communicating the benefits and safety aspects of nanomaterials.”
EU law on nanomaterials and cosmetic labelling
All cosmetics placed on the EU market are regulated by the Cosmetics Regulation (EC) No. 1223/2009 which contained a safety framework and central notification system whereby all colourants, preservatives and UV filters, including those that were nanomaterials, had to be explicitly authorised. Authorisation of such substances only happened after the Scientific Committee on Consumer Safety (SCCS) had reviewed the related toxicological data.
All nanomaterials in cosmetics had to be labelled with the word ‘nano’ in brackets after the name of the ingredient on the ingredients list. When registering a product via the Cosmetic Products Notification Portal (CPNP), manufacturers, importers or appointed third parties also had to identify the nanomaterial and specify the likely route through which a person may be exposed to it.
Dr. Emma Meredith, director-general of the UK Cosmetic, Toiletry and Perfumery Association (CTPA), said the current labelling legislation was “sufficient”.
“Labelling on cosmetic products is covered by robust requirements of the EU Cosmetic Products Regulation. Providing additional scientific information on pack about nanomaterials might not be the best way to help consumers in making purchasing decisions,” Meredith told CosmeticsDesign-Europe.
John Chave, director-general of Cosmetics Europe, agreed: "From our side, we would like stress that the industry already identifies via appropriate labelling if a nanomaterial is present in the product and which nanomaterial it is. Therefore, we do not believe that increased labelling would be more transparent or more conducive to consumer safety."
Meredith added that the CTPA, and likely other industry associations and companies, would be happy to provide additional information about nanomaterials on their websites “to help explain their uses and safety”. This was something the CTPA had, in fact, already done on its consumer website ‘The Facts About’, she said.
Risk perception of nanomaterials
Findings from the EUON study related to the risk perception of nanomaterials showed concerns were lower than safety concerns related to the likes of asbestos, the accumulation of plastic waste, global warming, use of pesticides and GMOs. Just one-quarter of respondents were worried about the possible impact of nanomaterials on their life and the same number had no distinct opinion.
“The results confirm that concerns often correlate with a lack of awareness of nanomaterials. People who know more about nanomaterials tend to be less concerned about the safety of using them in everyday products.”
However, EUON said the level of concern increased when talking about direct exposure to nanomaterials. “The concerns are mainly associated with yet-to-be-discovered impacts and properties of nanomaterials, as well as limited means to avoid exposure. In this regard, dermal exposure is perceived as most likely. However, the respondents also tend to think that negative impacts can be avoided or prevented by proper use and treatment of nanomaterials.”
Last month, the Scientific Committee on Consumer Safety (SCCS) published its preliminary opinion on the safety of nanomaterials in cosmetics and following the closure of its comment period at the beginning of this month, the Committee was now finalising this opinion.
In its preliminary opinion, the SCCS identified certain aspects of nanomaterials that constituted a “basis for concern over safety to consumers’ health when used in cosmetics products”. These included the physicochemical aspects relating to very small dimensions of nanomaterials; exposure aspects relating to the frequency and amounts used; and concerns arising from the type of application and novel active or functional properties the nanomaterials were being used for. As part of the opinion, the SCCS tabulated the EC catalogue of nanomaterials issued in 2019 “in an order or priority according to risk potential”. The UV filter Methylene bis-benzotriazolyl tetramethylbutylphenol was ranked top of the concerns list, followed by Colloidal silver and Silver – both used for various other functions.