"Whether or not and how to regulate the manufacture and commercialization of nanomaterials is subject to heated debate internationally. Several governments have opted to implement voluntary environmental programs (VEPs), arguing that this is the only viable proportional option for the time being. However, it remains to be seen whether voluntary measures will be enough to generate up-to-date and relevant health and safety information to ensure protection of health, safety, and the environment. In this article we analyze past experiences with implemented VEPs in the U.S. and apply the lessons learned on nanomaterials. We also discuss the implementation of these lessons in currently implemented and proposed VEPs on nanomaterials. We find that key elements of any VEP should be incentives to participate for various stakeholders; agency guidance and technical assistance; signed commitments and periodical reporting; quality of information; and transparency both in design, reporting and evaluation. Many of these elements have not been fully addressed in VEPs on nanomaterials. We provide recommendations on how to include these elements in government agency policies on nanomaterials and recommend that any VEPs be made mandatory after no more than three years, to ensure that there is a "regulatory stick" motivating voluntary participation, while affording first-moving companies early benefits and a level regulatory playing field."

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