In a joint effort, the Confederation of the Food and Drink Industries in the EU (CIAA) and the Nanotechnology Industries Association (NIA) developed and provided comments on 1 December 2008 to the ‘Draft Opinion of the Scientific Committee on the Potential Risks Arising from Nanoscience and Nanotechnologies on Food and Feed Safety and the Environment’, published for public consultation by the European Food and Safety Authority (EFSA) on the 17th October 2008.
The combined feedback include the following general statements:
- We, the NIA and CIAA, agree with the general core of the EFSA Opinion, although it takes a very generic perspective, and would of course need to be specific to each application on a case-by-case basis.
- While the European Commission requested ‘an initial scientific opinion on the risks arising from nanoscience and nanotechnologies on food and feed safety and the environment’, the EFSA Opinion focuses on ‘engineered nanomaterials (ENMs)’ only (see EFSA Opinion, line 188). The NIA welcomes this focus, and urges EFSA to ensure that this focus and appropriate terminology is maintained throughout the opinion.
- All potential nano-applications should not be regarded as the same. What type of differentiation is EFSA recommending? Appropriate reflections are missing from the draft Opinion.
- The paper is a literature review. It cannot, however, serve as instructions for the preparation of risk assessment dossiers, in the event of submission of applications.
- We note the conclusion that the current usage levels of ENM in food and feed are not known. There is a misconception that the potential applications are already in use. This, however, appears to contradict the statement under 4.2.1, where it is said that “In conclusion, significant consumer and animal exposure to ENM ingredients in food and feed is currently not likely within EU, though there may be exposure to nanoscale fractions within other materials. However, products are available via the Internet; this contribution to consumer exposure is not quantified”.
- We also welcome the conclusion that claims made concerning materials available in nanoform may not be true and cannot be routinely verified with the available analytical methods (lines 271-274).
- We note that the terminology "nanotechnologies" and "nanomaterials" are used interchangeably, while the Opinion addresses ENMs, only. The terminology should be consistent and appropriate throughout.