Potential reclassification of talc: Checklist provides guidance

1. Monitor the process – Closely follow the CLH process and discussions in EU bodies. The process has not yet been concluded; additional scientific data are currently being assessed. Relevant industry associations are monitoring the process, collecting information and preparing guidance.
2. Analyse potential impact – Assess at an early stage how strongly your company could be affected by a stricter classification.
3. Map formulations – Identify and list all products in which talc is used as a functional filler, for example to achieve matting, scratch resistance or sandability.
4. Assess alternatives – Evaluate potential substitute materials. A direct one-to-one substitution is generally not feasible, as talc performs several functions simultaneously; extensive reformulation is usually required.
5. Prepare scenarios – Consider several possible courses of action in parallel: Scenario A: No reclassification or a differentiated reclassification → formulations remain largely unchanged. Scenario B: Stricter classification → reformulation using alternative raw materials and the corresponding conversion process are required. Scenario C: Transitional solution → stricter regulatory requirements while talc use continues.
6. Calculate costs – Factor in the costs of development, raw material qualification, product testing and market introduction that could arise from reformulation.
7. Involve customers and raw material suppliers – Inform customers early about possible formulation or labelling changes and involve them in the coordination process. Engage with raw material suppliers, including on their assessment of the process and on potential substitutes.

Read an in-depth interview with Aline Rommer from the German paint and printing inks assocation (VdL) on the possible reclassification of talc and the implications for the coatings industry here.

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