RIVM on Advanced Materials, October 2024

General

The past few decades of managing the uncertain risks for human and environment associated with nanomaterials have provided crucial insights for ensuring the safe and sustainable development of advanced materials. Building on these insights, three EU European Union (European Union ) Horizon2020-funded projects have outlined key actions to enhance the risk and sustainability governance of advanced materials. Nonetheless, whether the current EU initiatives on advanced material innovation adequately consider these lessons is questionable.

The European Commission’s ambition for safe and sustainable advanced materials

The European Commission (EC) considers advanced materials crucial in facilitating the green and digital transition towards a circular economy. At the same time, sustainability and protection of human health and the environment have been placed high on the EC’s agenda. It is, therefore, critical to establish robust governance measures that address safety and sustainability from the initial design phase of these materials. This should ensure their safe, sustainable, and responsible use throughout their life cycle. Existing governance measures for conventional chemicals often do not adequately address advanced materials’ specific and unique properties.

Shaping a safe and sustainable future for advanced materials

In a recent article, three EU Horizon2020 NMBP-13 funded projects, Gov4Nano, NANORIGO and RiskGONE, provide their vast experience with governing the uncertain risks of nanotechnology. They use this to emphasise the importance of establishing a European approach for risk and sustainability governance of advanced materials as soon as possible to avoid a setback in innovation. The approach should aim to manage uncertainty about the safety and sustainability of advanced materials. This requires intense collaboration between regulators, industry, SMEs, and the public regarding potential risks and impacts of advanced materials.

Key actions based on lessons learned from nanotechnology

Based on their experience, the three NMBP-13 projects highly recommend coordinating safe and sustainable research efforts for advanced materials. This includes managing data according to the Findable, Accessible, Interoperable, and Reusable (FAIR) principles to enhance and speed up the generation of regulatory-relevant knowledge. This knowledge is crucial to identifying whether current regulatory standardised and harmonised test methods are adequate for assessing advanced materials. At the same time, there is an urgent need for responsible innovation beyond regulatory compliance. This can be promoted through the Safe and Sustainable Innovation Approach. The projects further recommend consolidating all efforts and networks related to the risk and sustainability governance of advanced materials in a single, easy-to-use digital portal.

The EU needs a governance structure to manage the risk and sustainability of advanced materials properly

Given the anticipated complexity and tremendous efforts required, the researchers identified the need to establish an organisational structure. This should be dedicated to aligning the fast technological developments in advanced materials with proper risk and sustainability governance. Active involvement of multiple stakeholders in a trusted ecosystem ensures a coordinated effort toward the safe and sustainable development, production, and use of advanced materials. The existing infrastructures and network of experts involved in the governance of nanomaterials would form a solid foundation for such an organisational structure.

Reflections by RIVM

The paper outlines valuable lessons learned from governing the uncertain risks of nanotechnology. Unfortunately, these lessons are not visibly reflected in the EC’s plans to stimulate the development of advanced materials. The recently published EU Communication on Advanced Materials for Industrial Leadership lists fourteen actions to establish “a dynamic, secure and inclusive materials ecosystem in Europe that ensures leadership in research and fast-tracks innovations to market”. The Communication explicitly mentions that sustainability and protection of human health and the environment must be ensured. Nevertheless, no dedicated actions for addressing safety and sustainability were formulated.

For example, the call for members of the new Technology Council on Advanced Materials does not specifically request competence and experience in safety or sustainability. Furthermore, the call to coordinate ongoing projects in advanced materials to ensure synergies fails to mention projects focused on safety and sustainability. Without a specific focus on these aspects, the safety and sustainability of advanced materials are by no means secured. This poses a significant risk to the responsible application of advanced materials in the long run.

The article rightly outlines that European projects on nanotechnology have already demonstrated that input from regulators and risk assessors on safety and sustainability is not a barrier to developing new materials. In contrast, the collaboration between innovators, risk assessors, and innovators has given rise to the Safe and Sustainable Innovation Approach. This approach combines the Safe-and-Sustainable-by-Design and the Regulatory Preparedness concepts. These responsible innovation concepts have been widely embraced because of their potential to enhance efficiency in the path to market safe and sustainable materials.

Collectively, the current implementation of the actions in the Communication on Advanced Materials for Industrial Leadership urgently requires adaptation to include tangible actions on human and environmental health. Only then, safety and sustainability of advanced materials can be effectively addressed to ensure marketing safe and sustainable materials.