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Possible talc classification: implications for the paint industry
Nowadays, it’s almost impossible to imagine many paints and varnishes without talc. However, this functional filler is under scrutiny: in the ongoing CLH procedure, there is a risk of a Europe-wide harmonised classification as ‘presumed to be carcinogenic’ and ‘harmful to the lungs following repeated exposure’. Associations such as Eurotalc, CEPE and VdL are seeking a re-evaluation. Aline Rommert, Product Safety Officer at the German paints and printing inks association VdL, discusses the status of the proceedings and the potential consequences for the industry. The interview was conducted by Kirsten Wrede.
Why is the impending reclassification of talc so significant for the paints and coatings industry?
Aline Rommert: Talc is a very important raw material in our sector. It is used as a functional filler in many paints and coatings and improves properties such as matting, scratch resistance, sandability or the workability of the products. At the same time, it has been established in many applications for decades. A stricter classification would therefore affect a large number of formulations and would present many companies with considerable technical and economic challenges.
The RAC (Risk Assessment Committee of the European Chemicals Agency) has recommended a significantly stricter classification. How do you view this tightening of the rules?
Rommert: From the industry’s perspective, this tightening is noteworthy because it goes significantly beyond the original proposal by the Dutch authority RIVM. Whilst a classification as Carc. 2 was initially under discussion, the RAC now recommends Carc. 1B.
We naturally take scientific assessments very seriously. At the same time, there is considerable debate as to whether the available data actually justify such a far-reaching classification. Eurotalc has submitted additional scientific analyses on this matter and concludes that the available epidemiological data do not support the proposed classification. We therefore believe that a fresh scientific review would be appropriate
What, specifically, do you hope to achieve from a renewed RAC assessment?
Rommert: We would like to see all available data assessed comprehensively and the decision based on as robust a scientific foundation as possible. A second RAC opinion could help to clarify outstanding issues and, where appropriate, lead to a more nuanced classification. In our view, it is crucial that scientific evidence, actual exposure conditions and the practical implications for industrial applications are all given equal consideration.
What response are you hoping for at national level?
Rommert: With our joint letter to the German Federal Ministry for Economic Affairs and the Federal Institute for Occupational Safety and Health (BAuA), we aim to draw attention at an early stage to the industrial policy and economic consequences of a strict classification.
We hope that the German authorities will actively raise these issues in the European discussion process and advocate for a scientifically sound and proportionate assessment. This is not about calling health protection into question, but about taking all scientific and economic implications into account appropriately.
The European Commission is now adopting a more open stance. How do you determine that?
Rommert: From our point of view, it is positive that additional scientific information and possible further assessment steps are being discussed at all. This shows that the process is not yet considered concluded. Of course, it remains to be seen how the Commission will ultimately decide. But the willingness to listen to new arguments and to examine the implications more closely is, in principle, a good sign.
How easy would it be to replace talc?
Rommert: Based on the studies carried out so far, finding a substitute would be extremely challenging. CEPE has established in an analysis that a direct 1:1 substitution is practically impossible. Instead, extensive reformulation would often be required.
This is because talc fulfils several functions simultaneously. Other substances can replace individual properties, but they often fail to achieve the same overall performance. Added to this are considerable costs for development, raw material qualification, product testing and market launch.
How realistic is differentiated regulation still?
Rommert: There may well still be some scope for a differentiated approach. On the one hand, discussions within the European bodies are still ongoing; on the other hand, additional scientific data have been submitted and are currently being evaluated. Furthermore, the socio-economic study by CEPE will provide additional insights into the implications of a possible classification. The European Commission does, in principle, have the option of initiating a fresh RAC assessment.
What advice would you give to manufacturers wishing to prepare?
Rommert: Companies should monitor regulatory developments very closely and analyse how they might be affected at an early stage. This includes, in particular, identifying formulations in which talc is used, as well as assessing possible alternatives. At the same time, it would still be too early to switch to alternatives across the board. It would make more sense to prepare for various scenarios: that is, to examine possible substitutes, evaluate their own formulations and keep a close eye on further regulatory developments.
