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How to manage risk before REACH implementation?
In France, from 2007 to 2017 which is the implementation period of REACH ("Registration, Evaluation and Authorization of Chemicals"), integration into the regulations can be done in two different ways for a compound occurring simultaneously in a "classic" form and in a "nano" form. Either we consider these two forms as a single substance (already on the market) or as two separate substances.
The proof of substance safety used to depend on the manufacturer only for substances placed on the market after 1981: that is, less than 10 % of substances marketed.
The particularity of nanomaterials in terms of size effects and persistence in the environment suggest that they should be taken into account specifically in the context of future regulations.