A shift in how the EU defines nanomaterials could quietly redraw the regulatory map for cosmetics, reclassifying ingredients that industry has long treated as settled.
Some titanium dioxide and silica products currently listed as nanomaterials could lose that designation, while carbon black may gain it depending on particle characterization results.
Fragmented national implementations are already creating a compliance patchwork across EU member states, years before the regulation is finalized.
The revision timeline runs to 2029, but mid-2026 evaluation results will be the first major signal of where regulators are heading.
NIA Regulatory Director Publishes Analysis on EU Nanomaterial Definition Changes
NIA Staff
2 min read
Summary
The Nanotechnology Industries Association's Director of Regulatory Affairs, Dr Blanca Suarez-Merino, has published a comprehensive analysis of evolving EU nanomaterial definitions and their impact on the cosmetics sector. The article appears in H&PC Today journal's October 2025 issue.
Dr Suarez-Merino examines how the European Commission's updated 2022 recommendation for defining nanomaterials could significantly affect cosmetics regulation if adopted by the Cosmetics Products Regulation. The analysis highlights critical differences between current cosmetics-specific definitions and the broader EU framework.
Key regulatory implications
The current EU Cosmetics Regulation defines nanomaterials as "insoluble or biopersistent and intentionally manufactured" materials with dimensions between 1-100 nm. However, the 2022 EU recommendation encompasses all naturally occurring, incidental, and manufactured nanomaterials, applying stricter classification criteria.
