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The European legislation has responded to the wide use of nanomaterials in our daily life and defined the term “nanoform” in the Annexes to the REACH (Registration, Evaluation, Authorization of Chemicals) Regulation. Now specific information of the nanomaterials is required from the companies when registering the appropriate materials in a dossier.
In the context of REACH eleven physicochemical properties were considered as relevant, of which the following six are essential for registration of nanoforms (priority properties): chemical composition, crystallinity, particle size, particle shape, chemical nature of the surface (“surface chemistry”), and specific surface area (SSA). A key role is the reliable, reproduceable and traceable character of the data of these priority properties.
In this context, we want to discuss which ‘analytical’ information is exactly required to fulfill these conditions. Time-of-Flight Secondary Ion Mass Spectrometry (ToF-SIMS) and X-ray Photoelectron Spectroscopy (XPS) were chosen as the most popular surface analytical methods. Both methods allow a detailed understanding of the surface chemistry with an information depth below ten nanometers. As a rather bulk method for the analysis of nanoforms, Electron Probe Microanalysis (EPMA) in the version with energy dispersive X-ray spectroscopy (EDS) is considered for the quick identification of the main chemical elements present in the sample. Furthermore, Scanning Electron Microscopy (SEM) results are discussed which provide results on particle size and shape. Thus, four of the six priority properties can be obtained with these methods.
Identifying nanomaterials (NMs) according to European Union Legislation is challenging, as there is an enormous variety of materials, with different physico-chemical properties. The NanoDefiner Framework and its Decision Support Flow Scheme (DSFS) allow choosing the optimal method to measure the particle size distribution by matching the material properties and the performance of the particular measurement techniques. The DSFS leads to a reliable and economic decision whether a material is an NM or not based on scientific criteria and respecting regulatory requirements. The DSFS starts beyond regulatory requirements by identifying non-NMs by a proxy Approach based on their volume-specific surface area. In a second step, it identifies NMs. The DSFS is tested on real-world materials and is implemented in an e-tool. The DSFS is compared with a decision flowchart of the European Commission’s (EC) Joint Research Centre (JRC), which rigorously follows the explicit criteria of the EC NM definition with the focus on identifying NMs, and non-NMs are identified by exclusion. The two approaches build on the same scientific basis and measurement methods, but start from opposite ends: the JRC Flowchart starts by identifying NMs, whereas the NanoDefiner Framework first identifies non-NMs.