According to the new regulation: “Downstream users should [send] this information up the supply chain to ensure that the use is adequately covered by the registration dossier of the manufacturer or importer, or alternatively cover the specific use in their own chemical safety report.” Detailed assessments to ensure compliance will need to be provided in submissions to the regulator: “Particle size, shape and surface properties of a nanoform may influence its toxicological or ecotoxicological profile, exposure as well as behavior in the environment,” notes the law. The law was approved as secondary legislation by the European Commission without a formal vote by the European Parliament and EU Council of Ministers, although it has been discussed by specialist committees with national government representatives.Given its January 2020 implementation date, should the United Kingdom exit the European Union as planned under the draft withdrawal deal due to be discussed by the House of Commons in early January, British compliance with this regulation would be subject to final EU-UK relations negotiations, which can only take place after ‘Brexit’ on March 29, 2019.
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