The European Commission (EC) is preparing an Advanced Materials Act to strengthen EU (European Union) competitiveness and accelerate the safe, sustainable development and uptake of advanced materials. Feedback from a public Call for Evidence indicates that stakeholders broadly support the initiative, highlighting the need for stakeholder collaboration, regulatory alignment, harmonised test methods, and the early integration of safety and sustainability into innovation. RIVM stresses that current regulations and test methods may not adequately assess advanced materials, calling for a robust risk governance system embedded in the EU innovation ecosystem.

Call for evidence: Development of the Advanced Materials Act

The European Commission (EC) has recently completed a public Call for Evidence as part of its initiative to create an Advanced Materials Act. The Act is a response to the increasing importance and demand for advanced materials, including nanomaterials. It is designed to establish a comprehensive framework that will facilitate the development and market introduction of innovative advanced materials across various sectors. With this Act, the EC aims to enhance the competitiveness of EU industry and stimulate the twin green and digital transitions. The proposal for the Act is planned to be published in the fourth quarter in 2026.

What are advanced materials?

According to the Organisation for Economic Co-operation and Development (OECD), advanced materials are materials that are rationally designed to have (i) new or enhanced properties, and/or (ii) targeted or enhanced structural features with the objective to achieve specific or improved functional performance. The EC envisions these materials to provide innovative solutions for a more efficient, sustainable and competitive industry, playing a key role in achieving the EU objectives of strengthening competitiveness and achieving climate neutrality by 2050, as outlined in the Clean Industrial Deal.

Examples of advanced materials highlighted by the EC include bio-based materials with enhanced insulation and circularity, recyclable carbon-reinforced plastics for wind turbine blades or aerospace applications, sodium-ion batteries designed to minimise reliance on critical raw materials such as lithium, and bio-based coatings replacing harmful substances, such as per- and polyfluoroalkyl substances (PFAS).

Addressing key challenges

The Advanced Materials Act aims to tackle four primary challenges identified by the EC:

1. Enhance EU research and innovation (R&I) capacities, particularly for startups and scaleups, while incentivising the industry to adopt advanced materials that support sustainability and performance improvements.
2. Secure supply chains, improve economic resilience (e.g. by reducing reliance on critical raw materials) and minimise environmental impacts (e.g. through strategic production initiatives).
3. Promote the reuse, remanufacture, repurposing and recycling of advanced materials by supporting established technologies that foster a circular economy (e.g. disassembly, dismantling, sorting), alongside providing industry incentives.
4. Reduce regulatory barriers and administrative burdens associated with research, production, uptake and use of advanced materials.

Stakeholder feedback

The EC received a total of 192 responses to the Call for Evidence from various stakeholders, including approximately 25% from academia and nearly 50% from businesses and their associations. Feedback originated from a diverse range of EU Member States, as well as responses from international stakeholders.

AFBEELDING

In general, the vast majority of the different stakeholders expressed support for the initiative, emphasising the necessity for better alignment of the existing, fragmented regulatory frameworks within the EU. There was broad consensus on the importance of integrating safety, health, and environmental considerations from the design stage, along with principles of life-cycle thinking, circularity, and recyclability.

Different stakeholders highlighted specific concerns: research institutes and public authorities stressed the need for interdisciplinary collaboration between academia, industry, and government to enhance the transfer of knowledge into industrial practice. They advocated safe-and-sustainable-by-design approaches and the need for appropriate, harmonised test methods to assess safety. Public authorities also referred to existing safety  legislation to ensure protection of human health and the environment, although adaptations are likely needed to make it fully applicable to advanced materials. In contrast, businesses pointed out challenges such as long time-to-market pointing to regulatory burdens, and inadequate research ecosystems as important reasons. They stressed the need for appropriate standards and risk-based approaches to shorten the time-to-market process. 

Although none of the stakeholder groups explicitly provided a clear definition of advanced materials, there was general agreement with the EC’s description. Companies and business associations particularly emphasized innovative functionalities, while novel production processes were also frequently mentioned. Public authorities noted the challenges of establishing a legally binding definition, particularly due to the ambiguity surrounding the term ‘advanced’. Although a legal definition of advanced materials may not be needed, public authorities highlighted that an unambiguous description of (groups of) advanced materials is needed to clarify regulatory requirements for industry and allow enforcement of legislation.

What are the next steps?

The EC will use all the collected evidence as the basis for the European Advanced Materials Act. It expects to present the proposal of this Act in the final months of 2026. Following this, representatives of the EU Member States will get the opportunity to scrutinise the proposal.

Reflection by RIVM

RIVM was one of the public authorities that provided feedback on the Call for Evidence. According to RIVM, safety is insufficiently addressed in the Call for Evidence, and current regulations and test methods may not adequately assess advanced materials safety and sustainability of advanced materials to protect human health and the environment. This situation leads to uncertainties that will hinder the scaling up of innovations.
In line with the broad agreement among various stakeholders, RIVM highlights that integrating safety and sustainability in innovation will enhance efficiency of bringing innovative safe and sustainable products to market. However, additional efforts are required to address any potential uncertainties in the applicability of regulatory requirements and test methods. Therefore, RIVM highlighted the need for a future proof legal description.

In addition, RIVM sees a robust risk governance system, integrated into the EU innovation ecosystem, as crucial for the safe, sustainable, and circular advanced materials innovation. This system should include coordinated test methods development, the integration of safety and sustainability into innovation processes, and early identification and anticipation of regulatory needs. Finally, RIVM points at the need for integrating regulatory knowledge into education to support innovators in their efforts towards safe-and-sustainable designs.