Switzerland’s food retailers association, IG DHS, has released a Code of Conduct for food and packaging suppliers with regards to nanotechnology usage in their products. The Code is fallout from earlier criticism, and is aimed at avoiding similar public backlash, over the use of genetically modified food in Switzerland.
The two-page Code of Conduct states that "The lack of specific legal rulings for nanomaterials and the uncertainty associated with the assessment of their possible risks mean that the precautionary principle needs to be applied in order to protect the health of consumers and the environment from possible harmful effects. On the other hand, the numerous potential advantages and benefits offered by nanotechnologies need to be exploited in the best possible way. This document adopts the working definition cited in the basic report of the Swiss Action Plan on Synthetic Nanomaterials, according to which nanotechnology is concerned with structures between 1 and 100 nm that offer added functionality and are manufactured or manipulated in a targeted manner."
Specific obligations under the Code impact procurement, product safety, and manufacturers and suppliers. The largest impact of the Code appears to be the requirement placed on manufacturers and suppliers to submit detailed information on nanomaterials used in their products. The Code requires the following minimum information from manufactures and suppliers:
- Benefit or added value of the "nano-product" compared to the conventional product
- Evidence of the nanospecific effects and/or modes of action
- Technical specifications (physical-chemical data, e.g. size, structure, etc.)
- Risk potential for humans, animals and the environment (toxicology, ecotoxicology, degradability, disposal, etc.)
While the requirements placed on suppliers seem to be detailed data submissions, the Code is contingent upon implementation by the signing IG DHS members (the Code states, "The members of IG DHS are responsible for requesting information about nanotechnologies from their manufacturers and suppliers."). In addition, the use of the phrase "working definition" for nanotechnology, leading me to think its a rather soft use of the term. While credit should be given for IG DHS’s concern for protecting its customer, this document does not seem to have much teeth behind it. Perhaps this is seen as a first step only, and with all new programs, first steps are generally revised over time. We’ll just have to keep an eye on how the Code is implemented and revised.