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Home > Nanotechnology Columns > Bergeson & Campbell, P.C. > ECHA Posts New Set of Q&As for Downstream Users of Nanoforms

Lynn L. Bergeson
Managing Director
Bergeson & Campbell, P.C.

Abstract:
The European Chemicals Agency (ECHA) has posted a new set of questions and answers (Q&A) for downstream users of nanoforms.

October 8th, 2021

ECHA Posts New Set of Q&As for Downstream Users of Nanoforms

The European Chemicals Agency (ECHA) has posted a new set of questions and answers (Q&A) for downstream users of nanoforms. See https://echa.europa.eu/support/qas-support/browse/-/qa/70Qx/view/scope/REACH/Nanoforms+of+substances The new Q&As, posted under Section I, include:

- What are my obligations as a downstream user purchasing, modifying or creating nanoforms?

- How do I know when I have created a new nanoform from a supplied substance?

- How do I know whether the nanoform I have created is covered by my supplier if I received [a safety data sheet (SDS)] with an exposure scenario attached?

- How do I know whether the nanoform I have created is covered by my supplier if: i) I did not receive an SDS or ii) I received an SDS but it does not contain exposure scenarios?

- How to check if my use and the conditions of use are covered by the exposure scenario received?

- What do I need to do if my nanoform/uses are not covered by my supplier?

- What should the downstream user chemical safety report contain?

- How do I report to ECHA that I have performed a downstream user chemical safety report (or I am relying on an exemption)?

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