What's Up with Nanomaterials and Do We Still Care about Conflict Minerals?

April 27, 2018

For nanomaterials, the European REACH Committee has voted to amend their annexes to explicitly address nanoforms of substances.  Think tiny, tiny zinc oxide within your sunscreens.  The underlying problem is that chemical these are the same formulas, but the exposures and hazards may be different due to the small sized.  Specific requirements will be created to address these gaps for materials and substances registered under REACH if they are placed on the market as nanomaterials.  Draft regulation is currently being subjected to a 3 month evaluation by the EU Parliament and Council before Commission adoption.

 

 

As for Conflict Minerals, also known as 3TG, or Tin, Tantalum, Tungsten and Gold (you knew that) or Sn, Ta, W, and Au for you chemical types – the U.S. Dodd Frank disclosure requirements still hold, for now.  However, EU again has a new law that is similar but in some ways easier to meet and in others almost impossible.  The EU law is applicable to importers of metals and minerals rather than the entire supply chain; with voluntary actions for durables.  But, it doesn’t define the conflict areas – meaning one company might say only Country X is in-scope while another might have Country X, Y, and Z.  And ever since CBS got a news crew into the Democratic Republic of Congo and filled children mining cobalt; many forward facing electronics and other companies are considering adding cobalt to their yearly survey of smelters going through to the very bottom of the supply chain.  This new business process for 3TG may not be ready to expand to new areas and new minerals, but the future comes whether or not we’re ready for it.  If B Cubed can help you sort this out, please feel free to contact me. 

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