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Belgium’s Nanomaterials Register Now Available

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Source: Bergeson & Campbell, P.C.

This week, Belgium’s Federal Public Service for Health, Food Chain Safety and Environment created an online portal for companies to register nanomaterials they put on the market.  Nanosubstances must be registered before January 1, 2016.  Mixtures containing such substances must be registered before January 1, 2017.  Belgium has posted several documents to help companies determine whether they must register:

  • Who has to register?  The answer is given in a schematic way, with a decision tree for substances and a decision tree for mixtures.  According to the document, the main difference between the decision trees follows from the exemption made in Article 1.8 of the Royal Decree:  “The provisions of this Decree shall not apply to . . . pigments, when placed on the market in a mixture, an article or a complex object.”  The following products are exempt from registration:  biocide; medicinal products for human or veterinary use; products intended to come into contact with foodstuff; animal feed; and technological aid or other products that may be used for processing ingredients of agricultural origin.
  • When do I have to register?  Existing substances produced in nanoparticular state that are already on the market before January 1, 2016, must be registered before January 1, 2016.  Existing mixtures containing substances produced in nanoparticular state that are already on the market before January 1, 2017, must be registered before January 1, 2017.  New substances produced in nanoparticular state after January 1, 2016, and mixtures containing such substances after January 1, 2017, must be registered before being placed on the market.
  • Which type of account?  Creating an account gives users access to the registration tool and allows the submission of one or more registrations.
  • Which type of registration?  A foreign supplier can submit only one type of registration, namely the inverse (of the limited) registration.  A registrant or a representative can submit different types of registrations, depending on whether the registration concerns a substance or a mixture; a first registration or an annual update; a registration using a previous registration number; or a product that is used exclusively within the framework of scientific research and development or within the framework of product and process-oriented research and development.
  • Registration — which info?  This document aims to guide users through the registration process and to provide an overview of the information that will be asked during this process.

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