Nano Product Register

Brief description: Here you can find guidance for reporting information to the nanoproduct register.

Are all articles and mixtures containing nanomaterials covered by the legislation?

No, they're not. Paragraph 3 of the Statutory Order lists a wide range of product categories which are not subject to the reporting obligation, regardless of whether they contain nanomaterials. For example, these are: foodstuffs and food contact materials, waste, cosmetics, medical equipment, medical devices, animal feed, etc.

Is my information contained in the submission confidential?

If this is justified, the reporter may choose to request that certain information contained in the submission be regarded as business secrets, cf. paragraph 8 (1) of the Statutory Order. However, certain information is normally considered confidential without the reporter having to request it. These include, for example: Detailed information on the full composition of a mixture, the exact quantity marketed, etc., cf. paragraph 8(2).

Is it enough to make a single submission/reporting?

Submissions/reporting shall be made once a year and shall cover articles and mixtures manufactured or imported during the period 20 June of the previous year to 20 June of the year reported. Reporting must be made by 30 August at the latest.

What if I cannot provide the relevant information for my products?

If you cannot provide the relevant information, some of these may be omitted if it is documented in connection with the submission, that it is not possible, or is associated with disproportionate costs of obtaining the information, cf. paragraph 5(5).

If you need more informations on how to report to the register

The Danish Environmental Protection Agency has made a Guidance Document on Registration to the Danish Nano Product Register. You can find it here: https://www2.mst.dk/Udgiv/publications/2014/08/978-87-93178-89-2.pdf

As a manufacturer or importer of mixtures and articles containing nanomaterials, that are intended for sale for private use, you may have an obligation to report your products to the Nano Product Register. It is a condition either that the nanomaterial is released under normal or with reasonably foreseeable use of the mixture or article, or that substances in soluble form that are classified as CMR substances or as hazardous to the environment are released from the nanomaterial.

Reports are to be made digitally via virk.dk.

Reported mixtures and articles are assigned a report number that is communicated digitally to the reporting party.

You can also find an unofficial english translation of the order her: Order on a register of mixtures and articles that contain nanomaterials

The text is to be regarded as an unofficial translation based on the latest official statutory order. Only the Danish document has legal validity.