The development of science-based categorization strategies for regulatory purposes is not a simple task. It requires understanding the needs and capacity of a wide variety of stakeholders and should consider the potential risks and unintended consequences. For an evolving science area, such as nanotechnologies, the overall uncertainties of designing an effective categorization scheme can be significant. Future nanomaterials may be far more complex and may integrate far different functionalities than modern nanomaterials. There is much that has been learned from our experience with legacy nanomaterials and particulate substances in general. Most of the modern nanomaterials are not new nor dramatically different from parent or existing chemical substances, however there are some nuances. Applying these learnings to define reasonable science-based categories that consider how different emerging nanomaterials might be from existing known substances (while integrating sound concepts as they develop) would be a pragmatic and flexible path forward. However, there are many barriers down this road including a need for improvement and updates to chemical classification systems to improve hazard and risk communications, while promoting transparency and consistency.
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