Titanium dioxide: “Not the right approach
By Didier Leroy, Technical Director at CEPE
CEPE is not happy that the legislator used CLP to address their concerns. It is not about the chemical titanium dioxide but about dust. For the first time chemically inert dust particles have been considered in scope of CLP. CLP should communicate relevant hazards, and titanium dioxide does not fulfill this criterion. We do not think this is the right approach as it will lead to misunderstandings, and, ultimately, CLP itself will be negatively impacted.
The practical implications for our industry are that liquid mixtures are not in scope of the classification but will all have to be relabeled with the EUH211 sentence. Powder coatings, however, may be in scope if they fulfill the Note 10 criteria. Powder blend mixtures are also in scope. More generally, the impact for our industry as a whole is the misunderstanding that this classification will entail.
Reputation will suffer
It is expected that our industry will suffer from using a ‘carcinogenic substance’. It is about perception and reputation. We will have to explain that lung overload of dust is an unrealistic condition for consumers and professional users and therefore there is no real hazard nor risk. Nothing will change for industrial workers who are already protected from dust exposure through the worker protection legislation and occupational exposure controls in all Member States.
The classification does not bring any benefit for the society but will have negative consequences not only on CLP but also on downstream legislations as many derogations will be required and the issue of waste has not yet been properly addressed. This classification has set a precedent for other poorly soluble particles. It has also set a precedent for the way substances are treated under the EU harmonised classification process.
The current status of titanium dioxide will also be discussed at the European Coatings Regulatory Forum on 27 and 28 November in Brussels. David Lockley of Venator / Titanium Dioxide Manufacturers Association gives updates and talks about the consequences for the coatings industry. The conference will also address other regulatory challenges such as poison information centres, Brexit and much more.
Titanium dioxide will be the focus of the EC TiO2 Forum on 28 and 29 January in Berlin. The conference will look at the pigment from a technical point of view, but will deal with alternatives and innovations in the field of TiO2.