Nanotechnologies and Food - Science and Technology Committee Contents

CHAPTER 8: List of Recommendations and Conclusions

Nanotechnologies in the food sector


8.1.  We recommend that, as part of their commitment to gain a better understanding of the needs of United Kingdom industry sectors likely to use nanotechnologies, the Government should pay specific attention to identifying the needs of the food industry and make provision for meeting those needs in their 2010 national strategy (paragraph 3.36).

8.2.  We recommend that Government should take steps to ensure the establishment of research collaborations between industry, academia and other relevant bodies at the pre-competitive stage in order to promote the translation of basic research into commercially viable applications of nanotechnologies in the food sector (paragraph 3.37). (Recommendation 2)

8.3.  We recommend that the Technology Strategy Board reviews the state of the commercialisation of nanotechnologies in the food sector. As part of this review it should suggest mechanisms for improving the effectiveness of current knowledge transfer systems (paragraph 3.38). (Recommendation 3)

8.4.  We recommend that the Technology Strategy Board includes consideration of the role that nanotechnologies may play in helping the food industry meet societal challenges, such as obesity and waste, in its strategies for promoting nanoscale technologies and biosciences, and that the Technology Strategy Board proposes ways of supporting the development and commercialisation of these technologies (paragraph 3.49). (Recommendation 4)

Health and Safety


8.5.  We recommend that the Research Councils should establish more pro-active forms of funding to encourage the submission of research bids to address the severe shortfalls in research required for risk assessment of nanomaterials as set out in the EMERGNANO report, and ensure that submissions are reviewed by a committee with appropriate expertise in this field (paragraph 4.43). (Recommendation 5)

8.6.  We recommend that, as part of any strategy to address the research shortfalls identified in the EMERGNANO report, the Government should ensure that specific research is focused on the gut and the other knowledge gaps we have identified above (paragraphs 4.18-4.27) with relevance to the risk assessment of nanomaterials in food or food contact materials (paragraph 4.44). (Recommendation 6)

8.7.  We recommend that the Government ensure that a breakdown of annual public spending on nanotechnology-related environmental, health and safety research within the United Kingdom is compiled and available when the five-year review of its progress against the 2004 Royal Society and Royal Academy of Engineering report is carried out (paragraph 4.48). (Recommendation 7)

8.8.  We endorse the recommendation contained in the 2008 report of the Royal Commission on Environmental Pollution that more attention should be paid to toxicology training. We welcome, therefore, the Government's commitment to tackling the shortage of trained toxicologists and ecotoxicologists and also their commissioning of an evaluation of the United Kingdom skills base for toxicologists and ecotoxicologists. However, the policies to address the shortfall promised for this year have not yet been launched. We look for urgent progress on this issue and ask that the Government update the Committee on its activity in this area (paragraph 4.52). (Recommendation 8)

8.9.  We recommend that the Government work more closely with other EU Member States on research related to the health and safety risks of nanomaterials to ensure that knowledge gaps are quickly filled without duplication of effort, while continuing to support coordinated research in this area at an international level through appropriate international organisations including the International Organization for Standardization and Organisation for Economic Cooperation and Development (paragraph 4.60). (Recommendation 9)

8.10.  We recommend that the Food Standards Agency develop, in collaboration with the food industry, a confidential database of information about nanomaterials being researched within the food sector to inform the development of appropriate risk assessment procedures, and to aid in the prioritisation of appropriate research. Industry participation in this database should be mandatory, given the failure of similar voluntary schemes in the United Kingdom and elsewhere (paragraph 4.72). (Recommendation 10)

Regulatory Coverage


8.11.  Given the uncertainty about the potential risks of nanomaterials, it is essential that any nanomaterial used in a food product (with the exceptions set out in paragraph 5.32) should to be subject to a formal risk assessment process through the European Food Safety Authority. We recommend, therefore, that the Government should work within the European Union to promote the amendment of current legislation to ensure that all nanomaterials used in food products, additives or supplements fall within the scope of current legislation. We recommend in particular that the legislation should, for the avoidance of uncertainty, include workable definitions of nanomaterials and related concepts (paragraph 5.19). (Recommendation 11)

8.12.  We recommend that the Government should work towards ensuring that any regulatory definition of nanomaterials proposed at a European level, in particular in the Novel Foods Regulation, should not include a size limit of 100nm but instead refer to 'the nanoscale' to ensure that all materials with a dimension under 1000nm are considered. A change in functionality, meaning how a substance interacts with the body, should be the factor that distinguishes a nanomaterial from its larger form within the nanoscale (paragraph 5.24). (Recommendation 12)

8.13.  We recommend that Government should work within the European Union to clarify the phrase "properties that are characteristic to the nanoscale" through the inclusion in the Novel Foods Regulation of a more detailed list of what these properties comprise. This list should be regularly reviewed, as the understanding of nanomaterials develops, to ensure it provides comprehensive and up-to-date coverage of relevant properties (paragraph 5.26). (Recommendation 13)

8.14.  We recommend that, for regulatory purposes, any definition of 'nanomaterials' should exclude those created from natural food substances, except for nanomaterials that have been deliberately chosen or engineered to take advantage of their nanoscale properties. The fact that they have been chosen for their novel properties indicates that they may pose novel risks (paragraph 5.32). (Recommendation 14)


8.15.  We recommend that the Government ensure that implementation guidelines for legislation state clearly what proportion of a bulk material has to be at the nanoscale for regulatory oversight to be triggered (paragraph 5.33). (Recommendation 15)


8.16.  Given the pace at which novel technologies develop we recommend that, in addition to its on-going monitoring of the state of the science, the Food Standards Agency should formally review the suitability of legislation every three years to ensure that regulatory oversight and risk assessment keeps pace with the development of these technologies (paragraph 5.34). (Recommendation 16)


8.17.  We welcome the Government's decision, in response to the Royal Commission on Environmental Pollution's report, to recognise that functionality, as well as size, should be the focus of required revisions to REACH (paragraph 5.36). (Recommendation 17)

8.18.  We commend the Government's commitment to address the issue of the one-tonne threshold for considering the potential toxic effects of substances under the REACH Regulations. We ask the Government to update the Committee on the progress they have made towards meeting this urgent need (paragraph 5.37). (Recommendation 18)


8.19.  We recommend that the Government, in collaboration with relevant stakeholders, support the development of voluntary codes of conduct for nanotechnologies in order to assist the continuing development of effective legislation for this rapidly emerging technology. The Government should work to ensure that voluntary codes are of a high standard, are subject to effective monitoring processes and are transparent (paragraph 5.42). (Recommendation 19)

Regulatory Enforcement


8.20.  We endorse the case-by-case approach taken by the European Food Safety Authority in assessing the safety of products. It allows the responsible development of low-risk products where safety data are available and is, in effect, a selective moratorium on products where safety data are not available. It provides consumers with the greatest security and ensures that unless a product can be fully safety assessed, on its own merits, it will not be allowed on to the market (paragraph 6.12). (Recommendation 20)

8.21.  We welcome the participation of the Food Standards Agency in a European Union project which will investigate methods for detecting and measuring nanomaterials in the food. Ensuring that this research results in practical tests that can be used by enforcement agents will be an important step in securing the safety of food imports (paragraph 6.15). (Recommendation 21)

8.22.  We welcome the assurance from the Government that the Food Standards Agency will ensure that enforcement authorities are made aware of the issues surrounding the use of nanomaterials in imported food (paragraph 6.17). (Recommendation 22)

8.23.  We recommend that the Government should ensure that research into methods of measuring nanomaterials in food results in the development of practical tests for enforcement authorities to use on imported food, and develop a plan to inform and educate enforcement authorities once such tests have been developed (paragraph 6.17). (Recommendation 23)


8.24.  We recommend that the Government work with the European Food Safety Authority as it develops guidance on the implementation of the Novel Foods Regulation and other relevant legislation. We urge the Government to state what steps they will take to ensure industry and academia are involved in the development of this guidance (paragraph 6.21). (Recommendation 24)

8.25.  We recommend that the Government continue to push for continued international dialogue and information exchange on appropriate approaches to regulating the applications of nanotechnologies in the food sector, and seeks to ensure that all relevant international organisations are aware of the emerging implications of the development of nanotechnologies (paragraph 6.29). (Recommendation 25)

8.26.  We recommend therefore that the Food Standards Agency create and maintain an accessible list of publicly-available food and food packaging products containing nanomaterials that have been approved by the European Food Safety Authority (paragraph 6.37). (Recommendation 26)

Effective Communication


8.27.  We recommend that the Government commission a survey of public attitudes towards the use of nanotechnologies in the food sector, with the aim of informing debate on the subject. This work should be carried out regularly to keep pace with evolving public opinion (paragraph 7.10). (Recommendation 27)


8.28.  We welcome the Government's decision to commission a website designed to give the public a balanced source of information on nanotechnologies, and commend the decision to include a section specifically covering issues related to the use of nanotechnologies in the food sector (paragraph 7.14). (Recommendation 28)

8.29.  We recommend that the Government wok with the food industry to secure more openness and transparency about their research and development and their future plans for the application of nanotechnologies in the food sector (paragraph 7.19). (Recommendation 29)

8.30.  Consumers can expect to have access to information about the food they eat. But blanket labelling of nanomaterials on packages is not, in our view, the right approach to providing information about the application of nanotechnologies. We believe the primary mechanism should be a public register of foods containing nanomaterials, as we have recommended in Chapter 6 above. We urge also that the Government, along with consumer groups, should consider other means through which this information can be made available and accessible to consumers (paragraph 7.24). (Recommendation 30)


8.31.  We agree with the Royal Commission on Environmental Pollution that the Nanotechnologies Stakeholder Forum provides a useful model on which to base a public engagement group to discuss the issues surrounding the use of nanotechnologies in the food sector (paragraph 7.29). (Recommendation 31)

8.32.  We recommend that the Government should establish an open discussion group, along the lines of the DEFRA-sponsored Nanotechnology Stakeholder Forum, to discuss issues surrounding the application of nanotechnologies in the food sector. This group should contain representatives from Government, academia and industry, as well as from representatives groups from the public such as consumer groups and non-governmental organisations. Meetings should take place on a regular basis as nanotechnology applications are developed and enter the United Kingdom food market. The Government should ensure that concerns of, and suggestions made by, the group are published and taken into account in policy decision-making processes. The Government should report on how these concerns are being met at regular intervals (paragraph 7.31). (Recommendation 32)

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