The European Union is to make the labelling of nanomaterials in cosmetics mandatory according to Chemistry World.

The cosmetic regulation states that all ingredients present in the product in the form of nanomaterials should be clearly indicated in the list of ingredients, by inserting the word ‘nano’ in brackets after the ingredient listing. The ruling defines nanomaterial as ‘an insoluble or biopersistant and intentionally manufactured material with one or more external dimensions, or an internal structure, on the scale from 1 to 100 nm’.

As always, the devil is in the details and the detail in question is the definition. While one of the advantages of nanotechnology is that it allows you to control very tightly the size range of the particles that you are creating, top down technologies such as milling and grinding tend to produce particles with a wide range of different sizes, and while the mean size may be above 100nm, that does not mean that there will not be any sub 100 nm particles present. I suppose the definition of ‘intentionally manufactured’ is also open to question.

I have seen a number of ads recently for ‘chemical free’ cosmetics – which once again depends on whether you class tea tree oil and water as chemicals or not, and nanoparticle free cosmetics are a similar oxymoron. Depending on the production method used, the mean particle size could have to be as large as gravel in order to be even 99% nanoparticle free.

Germany has adopted the EU proposals with the caveat that

the general mention on labels of nano-scale materials in cosmetic products using the term “nano” might be misunderstood by consumers as a warning.’

While labelling may assuage some of the regulatory concerns, will the average consumer would be any more concerned with labelling the nanoparticle containing ingredients than they are with currently permissible constituents. Grabbing a bottle at random from my wife’s dresser I find a long list of ingredients such as Methyl Glucech-20, PEG-12 Dimethicone, and Polyquaternium-4, and I can’t really see that putting Hydroxyethyl cellulose dimethyl diallylammonium chloride copolymer (nano), or (C₈H₁₆N)_x^.xCl^.(C₂H₆O₂)_x (nano) would make much difference compared with the power of the cosmetic company’s marketing machine.

And that’s before I get into another debate with a polymer chemist about whether or not polymers are nanotech!