EU REACH Committee Delays Titanium Dioxide Hazard Classification

On Feb. 14, the European Union’s REACH Committee further delayed a decision on a proposed hazard classification for titanium dioxide (TiO2) as a Category 2 (Animal) carcinogen by inhalation. This delay marks the first time efforts to advance regulations under REACH — the EU’s Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals — have been held up by member states. EU officials will be meeting in early March to consider options.

If official action does not emerge at that time, then the issue will likely be left to a new European Commission (EC) that will convene in the fall.

ACA and several other industry groups have expressed significant procedural, scientific, and trade concerns arising from the European Chemicals Agency’s (ECHA) effort, concerns which should be evaluated and considered pending final decision by the EC. ACA, along with the European Council of the Paint, Printing Ink and Artist Colours Industry (CEPE), British Coatings Federation (BCF), French Federation of Paint, Ink, Color, Adhesives and Wood Preservation Industries (FIPEC), and German Paint Association (VdL); in concert with the EU-based Titanium Dioxide Manufacturers Association (TDMA); and other members of the International Paint and Printing Ink Council (IPPIC), have repeatedly expressed concern about the underlying EU hazard classification framework. Of major concern is the Classification, Labeling and Packaging Regulation or CLP, which ACA and IPPIC believe is not the right mechanism to address TiO2.

Industry also emphasized the focused nature of any potential hazard (poorly soluble, low toxicity, occupational dust exposure) and a host of consequences associated with formulated products, where no exposure or risk is evident.

ACA will remain engaged on behalf of the membership through the remaining deliberations, providing updates as new information is received.


ECHA has a program to develop harmonized hazard classifications for chemicals and the products containing them that are offered for sale and use in the EU. ECHA’s Risk Assessment Committee adopted an initial opinion on a proposed harmonized classification, which has been under consideration by member states. Established under REACH, the hazard criteria used was set up under the CLP regulation, which seeks to align with UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Should the proposed classification (as a Category 2 [Animal] Carcinogen) be finalized under the CLP, onerous new labeling requirements will be required for TiO2, leading to market unease, with implications for product quality, performance and waste management.

ACA Efforts to Address TiO2 Issues

ACA has filed numerous comments during the EU’s process, including the initial and more recent ECHA initiated public consultation. ACA has also taken its concerns directly to the WTO and through the U.S. Department of Commerce’s International Trade Administration (ITA). Working with CEPE and other IPPIC- allied paint industry associations, ACA has organized the submission of industry comments from around the globe. In addition, ACA has been monitoring efforts advanced by the coatings industry associations in Europe to influence national delegations to secure formal consideration of key industry positions.

ACA has repeatedly cited the many other national chemicals management schemes that acknowledge the lack of exposure and pursuant health risk for substances (like TiO2) embedded in polymers. Paints, coatings, inks and other polymers have a long history of safe use, as do the organic and organo-metallic pigments and dyes that have been used in these and other applications.

Contact ACA’s Steve Sides for more information.

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