The German manufacturers of paints, varnishes and printing inks criticise the EU Commission's latest proposal to classify titanium dioxide as unjustified and call for an assessment of the social and economic consequences in order to avoid unwanted effects.

At a meeting of experts on 18 September 2019, the European Commission will seek final clarity on the Member States' position on its proposal to classify titanium dioxide as a hazardous substance. Prior to this, the German paint industry has raised serious concerns. From the point of view of the companies, the proposal, which has been revised several times, still lacks any scientific basis. In addition, manufacturers warn of the unintended consequences of classification and require a prior impact assessment.
Titanium dioxide is the white pigment with the highest opacity and is therefore widely used in many industrial value chains, for example in the manufacture of paints, varnishes, building products, plastics and paper. There are no equivalent alternatives. The Commission's recently announced proposal significantly extends the scope of the directive: According to it, mixtures in which titanium dioxide is firmly bound in a matrix, e.g. industrial applications such as powder coatings, but also many plasters, dry mortars, grouts and fillers etc., should also be classified as hazardous substances.
"The proposed classification would have the consequence that many of these products would have to warn on their packing of a possible cancer danger, although according to estimate of all experts the current limit values ensure a safe handling , criticizes Dr. Martin Engelmann, managing director of the federation of the German lacquer and printing ink industry registered association. (VdL), the German Association of the Paint and Printing Ink Industry. Moreover, several EU regulations would explicitly exclude the use of (potentially) carcinogenic substances in certain products, for example for toys such as decorative paint boxes and coloured street chalk. "We do not have the impression that the Commission is aware of the implications of its new proposal. It is therefore essential to have an assessment of the economic, social and environmental consequences, as is actually envisaged for measures with such significant consequences," said Mr Engelmann. Together with 297 companies and associations, the VdL has signed an appeal to the Commission to this effect.

The Commission's proposal is based on a recommendation of a committee of the European Chemicals Agency ECHA of 2017, according to which titanium dioxide should be classified as "a substance suspected of causing cancer in humans by inhalation". The German Chemical Industry Association (VCI) had criticised this recommendation as incomprehensible and warned of great uncertainty among consumers. The criticism is particularly sparked by a study more than 20 years old, on which the recommendation is based and in which rats had to inhale powdery titanium dioxide over a very long period of time. Experts from authorities and industry had criticised that the reaction observed was not specific to titanium dioxide, but characteristic of a large number of dusts. In addition, there was no evidence in this or other studies that there was a danger to humans. On the contrary, comprehensive epidemiological studies show no link between exposure to titanium dioxide dust in the workplace and a risk of cancer. According to the German statutory accident insurance, there is not a single case of a recognised occupational disease due to titanium dioxide in Germany.
In the meantime, work is continuing on the European harmonisation of dust limits at the workplace. Germany had advocated such harmonisation of occupational health and safety regulations as an alternative to classification. Although almost all EU member states have introduced limit values for dust emissions at the workplace, these vary to some extent. For example, a German paint manufacturer has to comply with four times stricter dust limits than its French competitor. In an internal market that aims to ensure a level playing field for market participants, this is not acceptable in the medium term, according to the VdL. The industry is therefore urging a hurry. Due to the complexity and the considerable economic impact, however, the first steps towards harmonising occupational health and safety standards are not expected until 2020 at the earliest.


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