The Case of Titanium Dioxide - Commission puts the cards on the table

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In preparation for the consultation meeting on 18 September 2019, the European Commission has sent its draft final proposal for the classification of titanium dioxide as a hazardous substance to the EU Member States. The scope of the new proposal includes far more solid mixtures with titanium dioxide than before, with significant downstream legal consequences like e.g. a ban for paint boxes. Meanwhile, there is a growing call for a comprehensive impact assessment.

The Commission proposal to classify titanium dioxide as a "substance with a suspected carcinogenic effect in humans through inhalation” (Category 2) in Annex VI CLP Regulation covers two different categories:

(1.) ‘Titanium dioxide in powder form containing 1% or more of particles with aerodynamic diameter ≤ 10 μm;’ and

(2.) ‘Mixtures in powder form containing 1% or more of titanium dioxide which is in the form of or incorporated in particles with aerodynamic diameter ≤ 10 μm.’ [underlined = new text in “Note 10”].

The last point has undergone various small but significant changes during the process. In contrast to the previous version it is now clear that not only



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