On Nov 13^Th2012 the Center for International Environmental Law (CIEL), ClientEarth  and Friends of the Earth Germany (BUND) released their proposal for a European Union legislation to address the risks of nanomaterials. The NGO Proposal comes in reaction to a recent Communication of the EU Commission on the regulation on nanomaterials, which proposed only minor amendments to REACH annexes.

The proposal uses the 2011 definition of nanomaterials recommended by the European Commission, and presents the outline of a new stand-alone piece of legislation. The proposed legislation would set common principles for the regulation of nanomaterials and complement existing regulations to make them "nano fit", particularly REACH, as the cornerstone of EU chemical regulations.

To address this situation, the three NGOs propose a "nano patch" for REACH. It includes an obligation for all nanomaterials to be considered distinct from their counterparts above the nanoscale and suggests substantially lower volume thresholds for registration of substances at the nanoscale. The concept paper also proposes an EU-wide registry for all nanomaterials and products on the market.