Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

SSAB welcomes the proposed carcinogen category 1B GCL 0.1% for cobalt metal as the majority of the iron ores mined within the European Union contain approximately up to 0.03 % cobalt metal by weight after reduction in the iron ore melting process, thus meaning all steel based upon those iron ores would have contained cobalt in excess of the RAC proposed SCL 0.01%.

The Cobalt, except for very specific alloys, is a component that enters steel in an inadvertent mode, both in virgin raw materials, and in recycled origin, making it extremely difficult to separate the nickel due to its chemical affinity. In stainless steel content up to 0.3 % by weight of cobalt metal is frequent and next to it remains after the recycling process in the electric furnaces.

Filed in Spanish · English published by the European Commission

Colorcon strongly recommends that the adoption of the 14th ATP of the CLP continue as scheduled without TiO2 while the open regulatory and legal questions are clarified to allow full consideration of alternative regulatory options for all PSLTs. Colorcon manufactures coatings and printing inks for the pharmaceutical, food supplement and food industries.

Donauchem Polska Sp. z o.o. is part of Donau Chemie international group, founded 170 years ago.The headquarters of the group is located in Austria, where there are also three factories producing a wide range of quality chemical products. Apart from Austria and Poland, Donau Chemie's scope of activities includes Germany, Italy, Hungary, Slovak Republic, Czech Republic, the USA and the Philippines.

The Sherwin-Williams Company is multinational paint and coatings manufacturer with significant operations located throughout the European Union. Titanium Dioxide (TiO2) is a key ingredient in our paints that helps to impart the signature bright white color found in our interior and exterior base paints.

The Confederation of Danish Industry (DI) welcomes the opportunity to provide comments to public consultation on the draft ATP to the CLP, as part of its Better Regulation approach. DI representsmore than 10,000 private enterprises within manufacturing, trade and services covering most sub-sectors.

Cefic, the European Council of the Chemical Industry, welcomes the Commission Better Regulation Consultation on the 14th Adaptation to technical progress of the CLP Regulation. We believe this is an important measure to ensure transparency and look forward for future opportunities to participate in regulatory consultations.

Croda Europe Limited welcomes the opportunity to contribute to the public consultation on the CLP Proposal for Titanium Dioxide as Carcinogen 2 (by inhalation) under the Better Regulation initiative. The Risk Assessment Committee (RAC) has concluded that titanium dioxide should be classified as a Category 2 Carcinogen when inhaled.

EUROFER Feedback with regards to: “Ref. Ares(2019)141469 - 10/01/2019 The European Steel Association (EUROFER) is pleased to submit the following comments on the ‘Hazardous chemicals — new rules on classification, labelling and packaging’, in particular with regards to Cobalt Harmonised Classification and Labelling (CLH).

Our company is a leading player within the field of process chemicals for leather and other substrates for the automotive (and other transportation), amongst others. We mainly use TiO2 for the production of pigment dispersions used in the leather finishing and all kind of other flexible materials.

The BAV – German Waste Wood Association (BAV - Bundesverband der Altholz-aufbereiter und -verwerter e.V.) is the leading trade association of the waste wood industry in Germany. Our aim is to make waste wood usable as secondary raw material or secondary fuel.

AQUAFIL GROUP: Founded in 1965, Aquafil is one of the main producers of nylon Polymers and Fibers in Europe. The Group employs more than 2.800 people and has 16 manufacturing operations in 8 different countries (Italy, Germany, Scotland, Slovenia, Croatia, United States, Thailand and China).

Hispanamer S.A. is a company specialised in the manufacture of industrial paints of all kinds. Its experience in this field is over 95 years of age, through the development of its built up to a high standard of quality.

Filed in Spanish · English published by the European Commission

Titanium dioxide has been used in industry for decades and there has been no evidence so far of any negative health effects for users. This is not least because when using the dust exposure at the workplace and not the material properties of the titanium dioxide play the decisive role. This is borne out by the fact that effective dust levels are already in place in most Member States.

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The European Recycling Industries’ Confederation – EuRIC AISBL – is an umbrella organization for the recycling industries in Europe. Through its Member Recycling Federations from 20 EU and EFTA countries, EuRIC represents over 5,500 companies, both large companies and SMEs, involved in the recycling and trade of various resource streams; EuRIC welcomes the public consultation on the draft 10th ATP regulation, and…

Sherritt International Corporation is a metals producer with sales of high-quality nickel and cobalt into Europe. Our nickel and cobalt products allow Europe to move ahead with important measures such as increasing transportation fleet electrification, development of long-lasting infrastructure, and building a long-lasting European circular economy including both durable goods and high rates of material recycle.

Ugitech is a major producer of stainless steel long products in the EU and worldwide. The proposed classification of cobalt, when applied to stainless steels as mixtures, will affect the classification of almost all stainless steel due to the small amounts of residual cobalt contained in stainless steels. At the level actually proposed in the legislation, cobalt cannot be avoided nor removed from stainless steels.

As a leading supplier of coatings to the wallcoverings industry, we appreciate this opportunity to contribute to the public consultation on the proposed classification of titanium dioxide as carcinogen category 2 by inhalation (H351). The committee for risk assessment of the agency (RAC) recognise that the proposed classification is related to a dust effect.

the manufacturer of paintings LANDCOLOR SA located at Ajalvir (Madrid, Spain) would like to indicate its support for the contributions submitted by ASFAPI and UNECE as regards the proposal for a harmonised classification for TiO2 as carcinogenic category 1B. we fully agree with the comments that I received from ASFAIP. we hope that we will take this into account when taking the final decision. thank you, and welcome

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VDFFI, the German Refractories Association, welcomes the opportunity to provide comments to this public consultation under the Better Regulation initiative on the classification and labeling of Titanium dioxide (TiO2). The proposed classification and labeling is not the most appropriate regulatory tool to address the potential effects of TiO2.

NORD COMPOSITES company takes the opportunity to respond to the public consultation under the “Better Regulation” initiative and wishes to demonstrate its disagreement about the new classification proposal of titanium dioxide. If danger and proposed classification are based only on particles size, in that case, most of the powder products are concerned by dust effect.

CEPE welcome this public consultation under the Better Regulation initiative. CEPE represents the paint, printing ink and artists’ colours manufacturers in Europe. Our industry is the main user (60% of total volume) of the essential pigment titanium dioxide.

European Aluminium, representing the aluminium industry in Europe, does not support the proposed classification of TiO2 as a carcinogen by inhalation. At this time, the criteria applied to mixtures containing TiO2 require further development and there are still several important issues and implications that need to be considered further, both at technical and legislative level.

The TSR Group, headquartered in Germany, is a European leader in the recycling of metals and established partners for international business, small and medium-sized enterprises, micro enterprises and local authorities.

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Regulatory Compliance Services Ltd as technical support for Reliance Industries Limited, India, welcomes this public consultation under the Better Regulation initiative. It is listed in the European transparency register. Man-made fibres - as well synthetic as cellulosic - are organic fibers and the most important textile basic materials in the areas of apparel, home furnishing and industrial uses (e.g.

The European Mortar Industry Association (EMO) represents the European manufacturers of dry mixed and ready to use (wet) mortars. Our industry uses TiO2 as a pigment predominantly in plasters, renders and smoothing mortars for internal and external uses.

This is further feed-back from the Cobalt Institute, providing a non-exhaustive and high-level overview of the applications of cobalt and their contribution to society, and to some key European environmental/industrial policies.

From my perspective, a classification is not appropriate. The concern relates to titanium dioxide in POWDER form which ONLY may occur at the workplace but NOT in the finished product. Most member states have already introduced limits, Spain between them.

Södra Skogsägarna ek. för. Södra Cell statement regarding DTPA classification under the CLP Regulation We support the information provided by the consortium of DTPA suppliers, Dow et al. stating that there is most likely a lack of human relevance of the effects seen in rats at the estimated exposure. We would also like to point out the following practical impacts of the classification.

The Cobalt Institute (CI) and the Cobalt REACH Consortium (CoRC) represent the manufacturers, producers, users, traders and recyclers of cobalt in the EU (including for REACH matters) and globally, promoting the sustainable and responsible production and use of cobalt in all its forms.

The The Association of Turkish Paint Industry Supports its EU-based Trade Association Members Position The Association of Turkish Paint Industry (BOSAD) is a member of the International Paint and Printing Ink Council, Inc. (IPPIC), a global non-governmental organization whose membership is comprised of national and regional trade associations representing the paint and printing ink industry around the world.

ADVANSA GmbH is a medium sized producer of polyester staple fibre. For our industry titanium dioxide is the essential pigment and is used as one of the most important delustering agent additives in polyester fibre production. Different amounts of TiO2 are used to gain various characteristics on synthetic fibres in industrial applications.

Dormer Pramet develop, manufacture and supply a full range of metal cutting tools containing cobalt to customers globally. To our understanding, more work is required before the decision on classification of cobalt can be taken. Large amount of epidemiological data* from hardmetal industry has been published. It is important that the data is fully evaluated before concluding on cobalt classification.

Jernkontoret questions the inclusion of cobalt in this ATP as more clarification is required regarding all routes of exposure, mutagenicity, the carcinogenic potency methodology and consideration of bioavailbility for the classification of matrix materials like alloys. Jernkontoret is the Swedish Steel Producers Association.

SAR, Société d'Applications Routières, is one of the European leaders of the road markings market. In the road markings industry, 95% of the products are white stripes, thin or thick coatings using only titanium dioxide (rutile) as a pigment. It is by far the most efficient to provide opacity, day-time visibility (luminance or "whiteness") but also night-time visibility.

A classification of titanium dioxide as carcinogen via inhalation will have major consequences for users and manufacturers of paint. Our authorities are limited by the framework set by the CLP-regulation and the procedures that dictates but this is a case that do not fit the normal procedure.

The International Carbon Black Association (ICBA) represents leading carbon black manufacturers. Carbon black, like titanium dioxide (TiO2), is considered an inert, poorly soluble particle (PSP). As such, we are monitoring the proposed classification of TiO2 as a carcinogen category 2 with concern for the wide-reaching precedent it would set.

The European Portable Battery Association (EPBA) is the authoritative voice of the portable power industry. The association supports the common interests of its members regarding portable batteries and battery chargers with European institutions and other leading international bodies to provide consumers with complete power solutions which are sustainable across their life-cycle.

Submission of Gregory Brochard Technical Director, ALLIOS, FRANCE. ALLIOS is a French paint manufacturer and distributor for more than 180 years. The company manufactures in Europe, coatings based on TiO2, for Interior decoration, facade treatment, metal protection, wood, floor, roof coating, sports flooring, historical monuments, mineral coatings, lime paints ...).

ISOMAT is a producer of building chemicals and mortars with a multinational perspective. it is currently one of the most important industries of building materials in South-East Europe, with 3 production plants in Greece, Romania and Serbia, 7 subsidiaries in Germany, Russia, Turkey, Bulgaria, Romania, Serbia and Slovenia, and export sales in more than 50 countries in the world.

The vision and mission of our company states that we avoid working with substances which are carcinogenic, mutagenic or toxic for reproduction. For us this is very important because we want to avoid that our employees are exposed to this kind of substances and because we are located in a residential area we also want to minimize the stockage of dangerous and especially carcinogenic substances.

The Finnish Forest Industries Federation welcomes the public consultation initiated by the European Commission. The Finnish Forest Industries Federation, representing the pulp and paper industry in Finland, has followed with concern the process for harmonised classification and labelling of DTPA and titanium dioxide (TiO2).

Sappi is a leading global provider of sustainable woodfibre products and solutions. We produce annually 1.1 million tonnes of totally chlorine free woodfibre pulp (TCF) in 4 EU countries. In line with our objective to minimize the use of hazardous chemicals, we have been exploring viable alternatives to DTPA for a long time, without remarkable success.

A Poli-Farbe Vegyipari Kft (Magyarország) örömmel veszi a lehetőséget, hogy kifejezheti álláspontját / aggodalmait /véleményét a 14. ATP tervezetben szereplő titándioxid besorolási javaslattal kapcsolatban. Számunkra a titándioxid nélkülözhetetlen alapanyag, amely a festékek és bevonatok fedési képességét és fehérségét adja.

Referring to new information provided by DTPA manufacturers (dossier submitters), SCA urges the European Commission and the Member States to postpone the final decision on the harmonized classification of DTPA until RAC has had a chance to review this new information and until there is additional clarity on the key concepts of the CLP involved in the classification of DTPA and chelating agents in general.

As stated in the UNECE report of January 2019, if the risk of titanium dioxide is not due to its chemical composition but rather to the risk of inhaling dust/particles as such, it already exists in Spain and I understand in all the Member States, the maximum exposure values set by the National Institute for Safety and Hygiene at Work (INSHT) set at 10 mg/m³ the appropriate VLA for both titanium dioxide and inhalable…

Filed in Spanish · English published by the European Commission

Selena Labs in the name of producer of chemical construction products ( Selena Group) which use TiO2 in their products would like to provide below comments regarding proposed classification of TiO2 as Canc. Cat.2. TiO2 is strategic raw material for our industry, used in a wide range of our formulas e.g. paints, adhesives or sealants.

IVP-coatings represents Belgian paint and printing ink manufacturers. We welcome the possibility to give feedback and were able to keep track of various holding points in this process, therefore we like to use this opportunity to express the deep concern of our members about the impact of a possible classification as carcinogen as category 2 of an essential ingredient in almost all of the paints on the market.

The Association of Andean Technicians in the Republic of America (Star, http://starandinapaint.com/), a member of the Latin American Federation of Associations of Technicians and Manufacturers in Pintures and Ribbons (LATINPIN, http://www.latinpin.com/), is an agent of Colombian technicians and professionals in the paint industry, which is motivated by the FSCT (Federation of Societies for Societies for Coatings…

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Tata Steel Europe (TSE) uses cobalt to produce cobalt-nickel plated steels, which are used in the production of alkaline batteries. These cobalt-nickel plated steels are produced from cold rolled steel that is initially plated with nickel, then with cobalt. The plated steel is annealed to alloy the iron, steel and nickel and cobalt to form a layer with optimum surface conductivity.

FEPA, the Federation of European Producers of abrasives welcomes the opportunity to provide comments to this public consultation under the Better Regulation initiative on the classification of Titanium dioxide (TiO2). FEPA represents over 200 companies (140 headquarters) gathering 90% of European abrasives producers.

Höganäs is a global manufacturer of metal powders. Impurities of cobalt are present in the raw materials for our production, both in the base materials as steel scrap and iron ore, and also in alloying elements as nickel. In contrast to many other impurities, there are no commercially available technologies for the removal of cobalt from steel.

FPM Fachverband Pulvermetallurgie e.V. (Federation of Powder Metallurgy in Germany, FMP) representing the economic interests of the producers of sintered parts, metal powders and hardmetals in the German-speaking countries, would like to take this opportunity to express serious concerns regarding the proposal for classification and labelling of cobalt metal.

Submission of Gregory Brochard Technical Director, ALLIOS, FRANCE. ALLIOS is a French paint manufacturer and distributor for more than 180 years. The company manufactures in Europe, coatings based on TiO2, for Interior decoration, facade treatment, metal protection, wood, floor, roof coating, sports flooring, historical monuments, mineral coatings, lime paints ...).

Stora Enso refers to the new information provided by the dossier submitters (BASF, Dow and Nouryon) and urges the European Commission and the Member States to postpone the final decision on the harmonised classification until RAC has had a chance to review it and until there is additional clarity on the key concepts of the CLP involved in the classification of DTPA and chelating agents in general.

PLASTIKA KRITIS SA is one of the major European masterbatch manufacturers with long presence in global markets. Our production sites are located in Greece, Turkey, Romania, Russia and Poland. Our comments are listed below: 1. Titanium Dioxide is the most widely used white color pigment in the plastics industry.

The Colombian Association of Technicians in coatings — ACTR, member of LATINPIN and currently trained by professionals in Colombia with more than 30 years of experience in the paints and coatings sector, adds to all the voices you disagree that you want to rank and label substances and mixtures that contain Titanium dioxide in its composition as carcinogenic category 2.

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Inter-service consultation on amendment to Annex VI of the EU’s Classification and Labelling (CLP) Regulation for its adaptation to technical progress (ATP) – including titanium dioxide (TiO2) Lomon Billions is the world’s 4th largest producer of high-performance TiO2 pigments globally with a strong and expanding European presence. Lomon Billions welcomes the opportunity to provide the following comments.

Metsä Group is a forerunner in sustainable bioeconomy utilising renewable wood from sustainably managed northern forests. Metsä Group focuses on wood supply and forest services, wood products, pulp, fresh fibre paperboards and tissue and cooking papers. The Group operates in nearly 30 countries. Metsä Group supports the comments made by the Lead registrants that DTPA does not deserve the proposed Cat.

The Federal Association of the German Waste Management, Water and Raw Materials Management Association (Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft e.V.) is grateful for the opportunity to provide feedback on the Commission’s proposal (Ref. Ares (2019) 10/01/2019 141469).

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Comments FROM RALVA, S.A. TO THE PUBLIC CONSULTATION ON THE CLASSIFICATION OF TITANIUM DIOXIDE (TiO2) as a carcinogenic CAT. 2 RALVA, S.A., a Spanish company in the manufacture of Pintures for Decoration, Industry and Horizontal Road Signs uses Titanio dioxide as a pigment, for brightness, and as a load, to give opacity or a hiding power.

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With this statement we would like to comment on the proposal to classify titanium dioxide (TiO2) as Carcinogen Category 2 (H351) (inhalation). The observed adverse effects in the lungs of animals chronically exposed to TiO2 were very likely caused by the so-called "lung overload".

Mapaero designs and manufactures technical paints and coatings for the aerospace industry. We are challenging the proposed classification for Titanium Dioxide (TiO2) for the following reasons: - The unique properties of Ti02 (refractive index 2.61 to opacify, lightness) make it irreplaceable in 95% of our formulations. - Other pigments that would give similar performances don't exist.

CERAMICOLOR is the Italian Association of Ceramic Glaze, Inorganic Pigment and Metal Oxides Manufacturers, which also involves Italian and multinational companies that produce frits, enamels, dyes and ceramic auxiliaries, inorganic pigments and metal oxides. It represents 15 companies. TiO2 is used as a starting material for the synthesis of important inorganic coloured and white pigments (e.g.

Tikuria Sverige AB is a leading colour supplier in Sweden with over 300 employees and known trade marks. In view of the uncertainties and inconsistencies that still exist in relation to the correct classification and risk communication of titanium dioxide, it is premature to have titanium dioxide in the ATP to which the Commission is to decide.

Filed in Swedish · English published by the European Commission

Tikkurril is the leading Nordic producer of the paint industry with experience over 150 years of age. We would like to express my opinion on the proposal to classify TiO2 as a carcinogen Cat.2. We consider that the proposed TiO2 classification at this stage is at least premature if at all, ATP for CLP is justified.

Filed in Polish · English published by the European Commission

A vote on the classification of cobalt will be held at the February meeting of the REACH committee. According to the current information, the vote at the meeting will be held on the Commission’s proposal for a new hazard classification, with the main topic being that cobalt is carcinogenic 1B on all exposure routes, with a GCL (General concentration limit) of 0.1, and a new working group should be established to…

As paint producers we fully support the position of TDMA (titanium dioxide manufacturers association) regarding the inclusion of titanium dioxide in Annex VI of CLP regulation as a carcinogen category 2 by inhalation. CLP regulation relates to chemical properties of the substances and it is not the most proportionate and effective tool for the TiO2 case.

V33 is a manufacturer of paints, varnishes, woodstains for the European market for more than 60 years. Titanium Dioxide is a key component of coatings, providing whiteness and opacity. It allows paint to effectively hide the substrate to which it is applied and is more effective than any other pigment in doing so.

Romanian Asociation of Construction Products concerning: Initiative Hazardous chemicals — new rules on classification, labelling and packaging We request that an impact assessment is carried out for this file as required by Better Regulation Guidelines for EU decisions, expected to have significant environmental, social or economic impacts.

Titanium dioxide from an ink manufacturer point of view: Titanium dioxide is used as white pigment with highest covering power in water and solvent based liquid inks for flexographic and gravure printing intended to be used for non-food and food contact materials: envelopes, paper bags, flexible packaging, foil carrier bags, napkins, tissue, wrapping paper , corrugated cardboard, composite foils, outdoor packaging…

NovoSystem GmbH produces paints for the plastic processing industry in 35 years. Our business is based on the processing of titanium dioxide (TiO2), 80 %. We therefore comment on the specific proposal for classification of titanium dioxide (TiO2), which is in that form a viable one.

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Federchimica is the Italian Federation of the chemical industry. At the present time 1400 companies, with a total of 90.000 employees, are part of Federchimica. They are grouped into 17 Associations, articulated into 38 product groups. Federchimica is a member of Confindustria (General Confederation of the Italian Industry) and CEFIC (European Chemical Industry Council).

We are the most important Italian Paint Producer for decorative and yachting since 1831 and we are really disappointed for this possible scenario In a general moment of stagnation of the economies of the different countries and producers that are confronted with increasingly limited margins, we would be obliged to intervene with important investments to make our plants compliant for: 1) the industrial management of…

1 General The HDE rejects the classification of titanium dioxide as a hazard if there is a suspicion of a carcinogenic effect. Harmonised classification is not appropriate. However, this would create significant burdens and disadvantages for the economy and consumers, which are not justified.

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• Delfortgroup is a specialty papers producer with paper mills in Austria, Finland, Czech Republic, Hungary and Vietnam and sales to over 120 countries worldwide. • Delfortgroup has been following with concern the process of harmonized classification and labeling of titanium dioxide and from delfortgroup’s perspective it is significant that titanium dioxide is left out of the final proposal for the REACH committee…

Metal Packaging Europe input to the public consultation on hazardous chemicals - new rules on classification, labelling and packaging; particularly with respect to titanium dioxide Metal Packaging Europe welcomes this public consultation under the Better Regulation initiative. Metal Packaging Europe represents the manufacturers of coated and uncoated metal packaging.

AssICC, an Italian chemical business association, represents distributors of chemical products in several industrial sectors. Titanoxide is a widely used product in various applications including paints and varnishes, plastics, cosmetics, but also in industrial processes linked to food. Its inclusion in Annex VI to the CLP Regulation would create significant negative economic impacts.

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The Titanium Dioxide Manufacturers Association (TDMA) has become aware that the adaption to technical progress (ATP) that is the subject of this public consultation has been updated and a new version with substantive changes has been made available on the Commission Comitology Register.

Smurfit Kappa Piteå urges the European Commission and the Member States to postpone the final decision, concerning DTPA and chelating agents in general, on the proposed Cat. 1B classification for developmental toxicity. Smurfit Kappa Piteå supports the comments made by the Lead registrants that DTPA does not deserve the proposed Cat.

Ahlstrom-Munksjö is a global leader in fiber-based materials, supplying innovative and sustainable solutions to customers worldwide. Annual net sales are about EUR 3 billion and we employ around 8,000 people. We are dedicated to sustainability and are a participant in the UN Global Compact. Ahlstrom-Munksjö is one of the leading producers of decor paper in Europe.

As one of the leading producers of surface and colours in Germany, we were surprised by the French authority’s proposal, ANSES, with titanium dioxide as a carcinogen. The astonishment was that the proposal put forward has been followed up at European level in the discussions and decision-making bodies. The currently negative highlight is the publication of the draft 14.

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We appreciate the opportunity to contribute to the public consultation on the 14th draft of CLP regarding the classification of titanium dioxide (TiO2) with the comments from a paint manufacture. Our customers are constantly facing new classification on our products, and to some extend our customers are drowning in the hazard information, which potential could end up in our customers not being able to distinguish…

I represent the company Paulypaint Coatings established in the EU Member State Belgium and respond on behalf of that company. We are manufacturer of industrial and professional coatings and are concerned about the proposal for classifying titanium dioxide as a carcinogen category2 by inhalation. We have been using this substance for 50 years.

We strongly believe that the classification of titanium dioxide (TiO2) as a suspected carcinogen (cat. 2) is inappropriate from the toxicological and epidemiological perspective. Our Industries are downstream users and in case of a classification they will face major uncertainty and reservation from customers side as well as commercial losses with impacts on growth and job security.

The proposed classification of Titanium dioxide TiO2 as a carcinogen category 2 by inhalation is solely linked to a general particle effect and not specifically to the substance itself. This “dust-effect” applies to many other substances in powder form: Poorly soluble particles with low toxicity (PSLTs). TiO2 has been used for many decades in countless products and articles, safely bound in a polymeric matrix.

Classification of TiO2 would create a precedent for all dust materials: As stated in the RAC opinion, the TiO2 classification is not based on substance-specific toxic properties but on its dust form. A similar hazard profile is also characteristic for other poorly soluble low toxicity particles (PSLTs). There are about 320 chemicals as well as other materials, e.g. road dust that have a corresponding hazard profile.

On behalf of Omar Coatings, S.A., as an SME manufacturer of paints and varnishes, we would like to thank you for the opportunity to comment and provide our opinion on the possible re-classification of titanium dioxide as a cat-carcinogen. 2: “Suspected of causing cancer by inhalation”.

Filed in Spanish · English published by the European Commission

DVSI welcomes the possibility of publicly expressing its concerns about the proposed classification of titanium dioxide. Please see our comments on the draft of the 14th ATP on the CLP Regulation in the attached document.

Filed in German · English published by the European Commission

ESTAL, the European association for Surface Treatment on Aluminium, represents several hundreds of plants where aluminium profiles and sheets are painted for architectural applications, such as window frames or façade elements.

The European Ceramics industry association (Cerame-Unie) welcomes the European Commission’s commitment to ensuring the efficacy of its legislation through thorough, transparent, and self-critical reviews. We are pleased to contribute to this process and we believe that the evaluations must be based on the best available scientific data to allow the right conditions to design and adapt fit-for-purpose legislation.

The European Association for External Thermal Insulation Composite Systems (EAE) has been working towards a “culture of sustainability” in the construction sector for more than 10 years now. The members of the EAE include 11 national ETICS associations, six major European supplying materials‘ associations and nine supporting members. The EAE represents enterprises from international operating companies to SME’s.

Hereby Eastman would like to submit comments to the public consultation of the draft regulation Ares(2019)141469 - 10/01/2019. In particular, Eastman would like to express concerns on how the proposed classification of titanium dioxide (TiO2) will effect the EU’s circular economy strategy and how it will lead to unnecessary product labelling, and product reformulation.

Titanium dioxide uses titanium dioxide as a white pigment in the coating on plywood boards; This usually amounts to more than 1 %. In the absence of alternatives, the wood materials industry is currently relying on the use of titanium oxide. The customer prefers white decorations, which account for about 45 % of the coatings.

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Wolfram Bergbau und Hütten AG (WBH) is a world-leading supplier of high quality tungsten metal powder. WBH uses primary raw materials, produced in its own mine in Mittersill, Austria and external tungsten concentrates. In St. Martin WBH runs also a plant for the recycling of tungsten and cobalt containing hardmetal. In this operation tungsten, tantalum and cobalt are fully recycled.

Triflex GmbH & Co. kg is a medium-sized family business. Our products are used as liquid seals for dry construction and road markings for transport safety. Titanium dioxide is an important raw material in many of these products without technically comparable alternatives. Titanium dioxide belongs to the group of poorly soluble particles (PSLT).

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We have been employed as a producer of Interior doors and frames with the subject of classification of titanium dioxide as carcinogenic (inhalation). Titanium dioxide is mainly used as a pigment in coatings and coatings in our area. Titanium dioxide is present in a coating in a bonded form (binder matrix). In dusts formed by the possible abrasion of the coating (e.g.

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WSM Wirtschaftsverband Stahl- und Metallverarbeitung e.V. (German Steel and Metal Processing Industry Association) would like to take this opportunity to express serious concerns regarding the proposal for classification and labelling of titanium dioxide, which is inappropriate from the toxicological and epidemiological perspective.

The followmann GmbH & Co. kg is a medium-sized family business. Our products are speciality chemicals for the decorative and functional design of surfaces and compounds in the manufacturing industry. These include printing inks for paper and packaging, posters for wallpaper and technical textiles and adhesives for the wood, paper and packaging industries.

Filed in German · English published by the European Commission

I claim that there is a substance that millions of citizens in EU and the world are using in their daily lives and which has the following harmful effects: - In its solid state it will certainly cause tissue damage upon prolonged exposure, - In its liquid state it can be lethal upon accidental inhalation, - In its gas state it will cause severe burns, - Upon exposure metals will corrode.

We would like to comment the proposal of TiO2 classification as carcinogen Cat.2. Titanium dioxide (TiO2) is a widely used raw-material in industrial processes and various materials for consumers, e.g. paints, paper, plastics, cosmetics, toys and pharmaceuticals.

8. Februar 2019 Contribution VSLF Public Consultation The proposed classification of Titanium dioxide TiO2 as a carcinogen category 2 by inhalation is solely linked to a general particle effect and not specifically to the substance itself. This “dust-effect” applies to many other substances in powder form: Poorly soluble particles with low toxicity (PSLTs).

Teknikföretagen (the Association of Swedish Engineering Industries) welcomes this opportunity to comment on the proposed classification regarding cobalt. We represent almost 4000 companies and many are using cobalt containing materials and products such as steel, hard metal and batteries.

The International Tungsten Industry Association (ITIA) is registered under Belgian law as a not-for-profit association with scientific purposes in support of the tungsten industry. A big part of the produced tungsten is used by the hardmetal industry being also a downstream user of cobalt.

Feedback from: ATTIPAT — The Association of the Iberoamerican Tecnologos de Pinturas, Foros and Adhesive Engineers. ATTIPAT — Asociación de Tecnologos (the Ibero-American Tecnologías de Pinturas, Shatinpin), a member of the Latin American Tecnopin and connected to the International Paint and Printing Ink Council, Inc., or IPPIC, a global non-governmental organisation whose members are national and regional class…

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Report on the classification of titanium dioxide (TiO2) The paint industry uses TiO2. Consider that in order to promulgate the rules one must have a serious and deep knowledge of TiO2 given that it is considered the part of low toxicity. a) CLP. The danger is not in the TiO2, but with the particulate nature of the substance.

The Color Pigments Manufacturers Association (CPMA) appreciates the opportunity to provide input to this open consultation. The whole document will be uploaded in addition to the following text. CPMA is a North American industry trade association comprised of global companies that manufacture and sell raw color pigments, pigment dispersions & preparations, and pigment masterbatches in North America.

The proposal to classify TiO2 is a precedent as for the first time a classification would not be based on intrinsic properties but on general particle effects. ECHA´s Risk Assessment Committee RAC acknowledges that the carcinogenicity profile described for TiO2 is not exclusively characteristic for TiO2 but applies to the whole group of chemicals referred to as “poorly soluble low toxicity particles”, and that the…

Sandvik Coromant AB is a world-leading manufacturer and supplier of metal cutting tools, used in a variety of industries including automotive, aerospace and energy production. Metal cutting tools are made of hardmetal, which contains cobalt as an important constituent.

Classification of Carcinogen category 2 for titanium dioxide Tio2 would impact upon a multitude downstream user sectors. The Carc Cat 2 harmonized classification could lead to the removal from the market of a multitude of consumer formulations and products, such as toys, cosmetics, foodstuff, food contact materials, ....etc.

Being a paint manufacturer, Mankiewicz uses large quantities of titanium dioxide as a pigment. Titanium dioxide has been used for decades in the world for painting, both in the field of building painting and for the decoration of many objects of everyday life. In paint, titanium dioxide pigment is embedded in a matrix and is no longer present in powder form.

The impact of this specific classification proposal would have a so large impact on many industries (including paint and coatings representing 60% of the TIO2 manufactured) that we need to make sure that such a decision is made based on a right understanding of TIO2 and other poor soluble low toxicity particles.

Submission of Mark Cancilla Global Vice President, Environment, Health, and Safety, PPG I have significant concerns about the proposed classification of Titanium Dioxide (TiO2). As the global leader of Environment, Health, and Safety (EHS) and Product Stewardship for PPG, my primary focus is on the health and well-being of people who work for PPG; for those who use and handle our products; and for the environmental…

The Committee of PET Manufacturers in Europe (CPME) is a European non-profit trade association based in Brussels. It represents all of the European poly ethyleneterephthalate (PET) resin producers who are collectively responsible for more than 3.3 million tonnes of European PET Resin production.

The proposed classification is linked to a dust effect, i.e. the lung overload of solid particles of poor solubility. Therefore, it deserved a broader discussion before a harmonized classification could have been justified. Titanium dioxide has been used for decades safely in thousands of products and articles.

AB Sandvik Materials Technology is a major producer of stainless and special steels in Europe and we would like to express our views about the proposed classification of cobalt. All stainless steels contain small amounts of cobalt as an impurity. This is due to the raw materials used in production; mainly steel scrap and, to a lesser extent, virgin alloys containing nickel.

Acerinox is a stainless steel manufacturer in the EU located in Spain and we share the concern about the proposal of classification of cobalt with the rest of EUROFER members. Cobalt is not an intentionally added substance; it is present in stainless steels as an impurity.

Japan Business Machine and Information System Industries Association (JBMIA) appreciates the opportunity to give feedback on this public consultation under the Better Regulation initiative on the proposal for classification and labelling of titanium dioxide (TiO2). JBMIA represents the global leading companies of business machines industry.

We, as PPG Coatings Deutschland GmbH wish to agree with the specific proposal for classification of titanium dioxide (TiO2).In the paints and varnish industry, more than 80 % of the TiO2 products are used and approximately 60 % of the TiO2 produced is consumed.

Filed in German · English published by the European Commission

ABRAFATI — the Brazilian Paints Association is affiliated to the International Paint and Printing Ink Council, Inc., or IPPIC, a global non-governmental organisation whose members are national and regional class associations representing the paint and printing industry worldwide. Thank you for the opportunity to respond to this open consultation under the terms of the Better Regulation of the European Union (EU).

Filed in Portuguese · English published by the European Commission

Cristal is one of the largest producers of titanium dioxide (TiO2), a leading producer of titanium chemicals. and a fast-growing producer of mineral sands and titanium metal powder. Cristal operates eight manufacturing plants in seven countries on five continents and employs nearly 3,400 people worldwide. At Cristal, we are committed to being exemplary in our Safety, Health and Environmental (SHE) Performance.

There are significant scientific issues and uncertainties in the evidence used in the RAC opinion on titanium dioxide (TiO2). In the attachment, I briefly describe some of the significant issues and provide new important scientific information which has been put forward since the RAC gave its opinion or which was not considered in the RAC process due to inadequate consultation procedures (summarized below).

The Salamander Industrie-Produkte GmbH is an European PVC-Material based “Window Profile and Industrial Profile Maker” serving mainly the Window Making Industry in the European Union. We have three profile making sub-companies and production sites in Germany and Poland - Salamander Extrusion GmbH & Co.

The proposed classification of titanium white is premature in the light of the enormous socio-economic impact and the limits of toxicity studies. 1 The classification is based on laboratory testing in rats with exposures to immature high concentrations for a long time. These conditions lead to overloading of the lungs if natural treatment can take place.

Filed in Dutch · English published by the European Commission

Please refer to the appended position paper for a better explanation of arguments and background. The new classification proposal of TiO2 is neither an efficient, nor a proportionate risk management option and therefore infringes the Principle of proportionality.

Titanium dioxide is widely used in the products of the German wood industry as an important component of paints and materials that cannot be replaced without serious disadvantages in terms of availability, quality, environment and health.

Karl Bubenhofer AG, Paint manufacturer, since 1908. The substance TiO2 has been used for a long time because of its excellent properties. We request that the proposal be rejected for the following reasons: There is no significant scientific evidence to support the classification of TiO2. In the highly controversial 1995 study, the test animals were exposed to extreme TiO2 dust doses.

Filed in German · English published by the European Commission

Borealis would like the Commission to clarify the following points: • Formulation in Annex III regarding term “powder form” • Labelling of solid mixtures: does the 10 µm criteria given for the liquid form also apply to solids? It is not specified in the draft ATP text.

Kronos is a leading manufacturer of titanium dioxide (TiO2) with manufacturing operations in multiple EU jurisdictions. As a key stakeholder, we appreciate this public consultation opportunity. After extensive legal and technical analysis of the current proposed CLP entry for TiO2 we submit that the fundamental legal principles of proportionality and legal certainty as well as the Commission’s own Better Regulation…

Our experiences and consultations with our OHMP show in our Staff has no significant incidence of lung disease. Therefore, we think that work with TiO2 is not subject to any further limitation if the existing occupational exposure limit values are complied with and proper use of appropriate protective equipment.

Filed in German · English published by the European Commission

Merck is deeply convinced that from a scientific point of view there is no comprehensible reasoning for the proposed classification as a CMR substance, hence Merck’s position is “no classification of titanium dioxide”.

We reject the change of the titanium dioxide category. It is a key component in our elastomeric mixtures for food contact. There are currently no substitutes. The inhalable fraction is completely absent in our finished products that comply with the regulations and customer requirements. We have also taken samples when we use our raw materials to ensure that we do not decline the threshold values.

Filed in French · English published by the European Commission

- We (paint company, 100 years of history) join the main positions of our CEPE branch organization: because it is not a "intrinsic property" CLP classification is not an appropriate place to communicate this info across the supply chain; - Titanium dioxide is one of the most widespread chemicals in the production of coatings for many years; from our statistics (regarding the monitoring of adverse effects), there are…

Dear Sir/Madam, we are producers of egg paints for household use. In addition to small quantities of pure titanium dioxide, however, inorganic pigments based on small quantities of titanium dioxide incorporated into an inorganic matrix are used to produce a large number of specific eggplants.

Filed in German · English published by the European Commission

INCO INDUSTRIA COLORI SPA supports the position of the Titanium Dioxide Manufacturers Association (TDMA) and the Inorganic Pigments Consortium regarding the inclusion of titanium dioxide in Annex VI of CLP Regulation as a carcinogen category 2 by inhalation. This proposal is disproportionate and would not bring any real benefits in terms of protection of human health or the environment.

We would like to thank the Commission for the opportunity of responding to the proposed amendment to the CLP Regulation which will classify titanium dioxide as a Category 2 carcinogen and introduce waning label requirements on products containing it. We would like to make the following points: • The RAC apparently believe that the proposed classification is associated with a dust effect, i.e.

Ferro is a global manufacturing company of performance coating, color & glass and color solutions, with several locations in Europe: Belgium, France, Germany, Italy, Poland, Portugal, Romania and Spain. Ferro, as several associations and industry, welcomes this public consultation initiative.

We are a factory of paints and varnishes with more than 35 years of experience in the production of titanium dioxide and, throughout this trajectory, in the beginning without adequate protection and progressively with the improvement of EPICs, we have never had a low level of work due to the use of this pigment.

Filed in Spanish · English published by the European Commission

Dear Sirs , The romanian paint producer company – Druckfarben Romania would like to inform you that : we do not agree with a classification of titanium dioxide in Annex VI of the CLP regulation as unjustified and support the alternative regulatory options proposed by Germany, UK and Slovenia . Please, find attached our arguments . Druckfarben Romania

Seco Tools AB is one of the world’s largest providers of comprehensive metal cutting solutions for milling, stationary tools, holemaking and tooling systems. In our opinion some work would be required before inclusion of cobalt in the ATP.

Geberit International AG fully agrees and supports the statement provided by the confederation of the associations of the German Fine Ceramic Industry (BVKI). Additionally, we believe the studies conducted so far do not provide enough evidence, which justifies proposed classification of Titanium dioxide. Quality of conducted studies are either limited or relevance to humans was considered unclear.

Jotun A/S being a multinational paint and coating company welcomes this public consultation under the Better Regulation initiative. Titanium dioxide is an essential white pigment in more than 95% of all our colors.

Regarding Titanium Dioxide, the notified draft contains a warning for the packaging of all liquid and solid mixtures (Annex II to CLP Regulation). For liquid mixtures, like toy finger-paints, a warning would need to be included that dangerous droplets may be formed when sprayed. For solid mixtures, like toy chalks, a warning would need to be included that dangerous dust may be formed when used.

VITEX is an independent paint manufacturer with the most advanced factory in Greece, active in the development and production of high-quality products for the construction industry since 1932. The company offers integrated solutions for: Architectural paints, Waterproofing and insulation, External thermal insulation and Yacht paints and focuses on quality and innovation.

The Grupa Azoty group SA as one of the European producers of titanium dioxide pigments (TiO2) welcomes the announcement of the public consultation on the TiO2 classification project, relying on the fact that they will provide a large number of valuable comments and opinions on the subject.

Filed in Polish · English published by the European Commission

The proposal for classification and labelling of titanium dioxide is inappropriate and unjustified. It is based on lung overload studies on rats whose results cannot be transferred to humans. This is clearly stated in the very guidance documents of ECHA and OECD. Titanium dioxide has been used safely for many decades. Epidemiological studies give no hints for any problems.

The UK Chemical Industries Association (CIA) welcomes the opportunity to provide input to the European Commission’s consultation on the draft Regulation (Ref. Ares(2019)141469 - 10/01/2019) on Hazardous Chemicals – new rules on classification, labelling and packaging. CIA is the trade association representing and advising chemical and pharmaceutical businesses across the UK.

The classification given to TiO2 has been considered following studies which consider it to be dangerous by inhalation of inert dust and its particle size, not because of direct effects of the substance within the organism. There would also appear to be no clear evidence of harm to individuals.

Filed in Spanish · English published by the European Commission

EPF, the European Panel Federation, has members in 25 countries and represents the manufacturers of particleboard, medium density fibreboard (MDF), oriented strand board (OSB), hardboard, softboard and plywood. The European wood-based panel industry has an annual turnover of about 22 billion Euros, creates over 100,000 jobs directly and counts more than 5,000 enterprises in Europe.

I comment on the proposal for classification of TiO2 as a Category 2 Carcinogen – Inhalation Route. TiO2 is a naturally occurring substance with a long history of safe use in a wide variety of industries ranging from paints to cosmetics to medicines. Within the Paint industry (which consumes ~80% of TiO2 production) it is used as a pigment conferring excellent opacity & durability to paint.

Titanium dioxide has been used for decades safely as white pigment in thousands of products and articles. TiO2 is necessary to ensure the functionality of about 77% of the European plastics articles production. Given the ubiquitous use of TiO2, even a limited switch will cause damages in the supply chain.

Dear EU! Enclosing the Swedish part of three papers (links below) on cancer mortality and morbidity in cohort of Swedish hard metal workers, our work is part of an international study with cohorts from the US, Austria, the UK, Germany, published in the same edition and paper as ours. Hopefully this will contribute to a proper risk assessment of cobalt exposure.

GSB Wahl GmbH is a small enterprise producing printing inks for various applications. Many of our products contain titanium dioxide. The proposed amendment to the CLP Regulation would have far-reaching consequences for us as TiO2 is not to be replaced by other substances. The opacity is unique and it is therefore absolutely essential.

Filed in German · English published by the European Commission

Dear Sirs , The Romanian Paint Industry Association – AIVR represents and promotes the interests of the Romanian paint producers . We would like to inform you that we do not agree with a classification of titanium dioxide in Annex VI of the CLP regulation as unjustified and support the alternative regulatory options proposed by Germany, UK and Slovenia because : 1.

TiO2 is a inert substance widely used in plastics, pharma and chemical industry. As any other material in Nanoparticles form it can be harmful. As expert in Plastics this material introduced as filler or doesn't represent a problem even in Nanoparticles form since no migration is produced.

Sandvik Osprey is a major producer of specialty alloy powders including stainless steels, nickel base superalloys, cobalt alloys, tool steels and magnetic powders, each of which can contain cobalt as a deliberate and essential addition. These powders are used in processes such as metal injection moulding, additive manufacturing/3D printing, coating and hot isostatic pressing.

Fritta S.L.U supports the position of the Titanium Dioxide Manufacturers Association (TDMA), the Inorganic Pigments Consortium and the Frits Consortium regarding the inclusion of titanium dioxide in Annex VI of CLP Regulation as a carcinogen category 2 by inhalation. This proposal is disproportionate and would not bring any real benefits in terms of protection of human health or the environment.

J. WAGNER GmbH is a global market leader in the manufacture of technologically advanced equipment and systems for wet paint spraying and powder coating. The three different customer groups that we serve with our products are craftsmen, do-it-yourselfers and industrial companies. This is not about the substance titanium dioxide, but about dust pollution in the work environment.

ESMALGLASS-ITACA Group supports the position of the Titanium Dioxide Manufacturers Association (TDMA), the Inorganic Pigments Consortium and the Frits Consortium regarding the inclusion of titanium dioxide in Annex VI of CLP Regulation as a carcinogen category 2 by inhalation. This proposal is disproportionate and would not bring any real benefits in terms of protection of human health or the environment.

Our comments are focussing on the following topics, which are comprehensively outlined in the enclosed document (see download): Lack of appropriate replacement TiO2 is chemically inert white powder, which is widely used as pigment in paints, coloured pencils, lacquers and coatings, chalks or modelling clays.

— TUPRET has been French manufacturer of coated paint for 80 years. Our coatings are powdered or powdered products for professional applicators and a general public on the European market. We would like to comment on the proposal on the classification and labelling of Tihane dioxide (TiO2). 1°) Our products and TiO2: Some of our dough products, in the water phase, not classified as hazardous, contain TiO2.

Filed in French · English published by the European Commission

ASFAIP is grateful for this public consultation within the framework of the European Commission Better Regulation initiative. ASFAIP represents Spanish paint and printing makers. The sector to which we represent is the main industrial sector of titanium dioxide, a key pigment in our industry.

Filed in Spanish · English published by the European Commission

Umicore comments to Co metal harmonized classification and labeling proposal - Draft Act ref. Ares (2019)141469/1 Umicore supports the comments submitted by the Cobalt Institute/Cobalt REACH consortium. In addition we want to emphasize the importance of the proposed Generic Concentration Limit (GCL) of 0,1% for Carc. 1B.

As a major producer of hardmetal tools containing cobalt, Walter has followed the cobalt classification process. Some further clarifications and scientific investigations are required before concluding on the cobalt classification. A big amount of new important epidemiological data* became available after the previous Public Consultation in Feb 2017 and just before the final RAC meeting (21 Sep 2017).

Tronox is a vertically integrated group of companies with titanium ore mining operations in Australia and South Africa and pigment plants in Europe, Australia and the US. While we fully support efforts to better ensure safe use of our products we believe that the inclusion of TiO2 in the 14th ATP is at worst, incorrect and at best, premature for these reasons: • The science on which it is based is incomplete and…

Titanium Dioxide is a natural mineral Used not only in paints, but also in textiles, paper, toothpaste, sun-scream, medicine, plastics and more. Because the industry is already using Titanium Dioxide for hundreds of years, there is a lot of knowledge / facts about potential risks, and it is a fact that the 24.000 workers in the TiO2 industry do not shown a higher risk on cancer.

JTI disagrees with the proposal to classify titanium dioxide as Carcinogenic Cat.2; H351 (i.e. suspected human carcinogen) for the following reasons: 1. Le et al., (2018), concluded that “there is no clear evidence of an association between occupational exposure to TiO2 and lung cancer”. 2.

Sika, a producer of roofing membranes, sealants, adhesives and coatings (among other products) with 2‘500 Mill. € turnover and 10000 employees in Europe is using titanium dioxide since long for coloring its products. We fully support the technical, scientific and economic argumentation brought to the attention of the EU Commission in detail by various industry associations, e.g. CEPE.

Metsä Board supports the comments made by the Lead registrants that DTPA does not deserve the proposed Cat. 1B classification for developmental toxicity and urges the European Commission and the Member States to postpone the final decision on this until RAC has had a chance to review the new information provided by the dossier submitters and until there is additional clarity on the key concepts involved in the…

As one of Europe’s biggest masterbatches, we process over 10,000 tonnes of titanium dioxide to white masterbatch. Protecting the environment, our staff, customers and consumers from dangers is very important to us. In the applications of our customers, titanium dioxide does not have an equivalent alternative but is neither technically nor commercially available.

Filed in German · English published by the European Commission

Titanium dioxide is the most widely used pigment in coatings industry. Our company uses titanium dioxide pigment in 65% of our products. It is used in both water based and solvent based paints, for deco and industrial applications, to produce almost all colored shades, starting from white up to dark shades. It has unique properties regarding opacity, scattering, color and durability.

The Spanish Association For Importers of Raw Materials for Ceramic Use “AIMPR” supports the position of the Titanium Dioxide Manufacturers Association (TDMA) regarding the inclusion of titanium dioxide in Annex VI of CLP Regulation as a carcinogen category 2 by inhalation. This proposal is disproportionate and would not bring any real benefits in terms of protection of human health or the environment.

Rio Tinto Iron & Titanium (RTIT) is a world leader in the production of titanium feedstocks for the titanium dioxide (TiO2) industry since 1950. The wide range of RTIT’s products is processed by its customers for the production of titanium dioxide pigment (TiO2) which ultimately goes into end uses applications like paints, plastics, and etc.

The proposed modification of Annex II of Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging (CLP) of substances and mixtures for mixtures containing titanium dioxide (TiO2), in which the substance is classified as carcinogenic to humans by inhalation (carcinogenic, category 2), has been analysed from ACOPLASTICS.

Filed in Spanish · English published by the European Commission

The European UP/VE Resin Association is a CEFIC sector group representing suppliers of the Un-saturated Polyester (UP) and Epoxy Vinyl Ester (VE) resins. The UP Resins market in the European Union includes approximately 8,000 companies. That is ap-proximately 100,000 direct employees and an added value of €60 billion that is expected to grow to €85 billion by 2020 (1) .

As an addition to our earlier feedback we would say that in our opinion, a differentiated approach of hazard classification for Titanium dioxide would be necessary. In particular, a split entry for titanium dioxide could be implemented; like the listing of titanium dioxide in the State of California which is limited to “titanium dioxide (airborne, unbound particles of respirable size)”.

Craig & Rose Ltd. is a manufacturer of paints for the European market. We seek to provide comment and express our concern on the proposed classification of Titanium Dioxide (TiO2) as a Cat 2 carcinogen. Titanium Dioxide is a key component of paints and coatings, providing whiteness and opacity.

This opinion refers to the classification and labelling proposed in the draft Regulation (Ares (2019) 141469 and Annex) and further requirements for the substance titanium dioxide (CAS 13463-67-7).Sto SE & Co. KGaA and its subsidiaries (‘Sto’) produces fabrics, paints, adhesives, sealants, coatings and similar products for a wide range of construction applications.

Filed in German · English published by the European Commission

Titanium dioxide is not taken into account as a chemical element, but as a possible harmful element because of a respirable powder by the employees. The sources of dust emitted may be detected in the paint manufacture field concerned, such as dust which is released into the atmosphere at the time of the late arrival of the raw material in the packaging, bags or sacconi, and the mixing mixer.

Filed in Italian · English published by the European Commission

Tim Knavish Senior Vice President, Global Architectural Coatings for PPG President, PPG Europe, Middle East and Africa (EMEA) I am concerned about the specific classification proposed for Titanium Dioxide (TiO2) and ask you to consider a pause in enacting the classification. My company, PPG, is a leading, global manufacturer of paints, coatings and specialty materials, with over 14,000 employees in the EU.

REHAU is a manufacturer of plastic profiles containing more than 0.1 % titanium dioxide. With our production volume of more than 100.000 tonnes a year, we would be very much more than the proposed change in the CLP Regulation on 14. ATP concerned. Titanium dioxide is an essential pigment for us to colour our products. There is no viable technical alternative for titanium dioxide.

Filed in German · English published by the European Commission

The coil coating industry in Europe is an important downstream user of TiO2 as it consumes ~200kt of paint each year for the manufacture of prepainted steel and aluminium for a range of end-uses, such as construction and domestic appliances.

The Finnish Commerce Federation welcomes this public consultation. We have followed the process with concern from the beginning. We believe that the consumers would be confused by the proposed labeling for products containing TiO2. Overall, the classification and labelling would be disproportionate in our view.

The proposed classification of TiO2 as carcinogen category 2 by inhalation concerns a general property of the particle and not as such the substance. From the moment that there is no hazard from TiO2 when is bonded in a paint to consumers or to professional painters, the inhalation risk refers only to workers in industrial environments, where occupational dust limits apply to protect them.

The position of the Hungarian Chemical Industry Association (MAVESZ) is 14. In connection with the proposal for classification of titanium dioxide in the ATP draft, please find below: Our member companies also include paint, pharmaceutical and plastic producers, in which the titanium dioxide is the commonly used source of raw materials.

Filed in Hungarian · English published by the European Commission

Titanium dioxide is used as a white pigment in the paint industry. Paints do not primarily have an aesthetic function, but have an important security mission (anti-corrosion, etc.) and security mission (flame retardant, road markings, etc.).

Filed in Spanish · English published by the European Commission

Besides the obvious and enormous social and economic impact that the implementation of the proposed Classification of TiO2 to Carcinogenic Cat.2 will have within the EU and its citizens, this decision represents also a major hit to a science-based approach to consumers exposure risk and occupational hazard.

FSKI, the associations of the German Ceramic Sanitary Ware Manufacturery welcomes this public consultation under the Better Regulation initiative on the classification of Titanium dioxide (TiO2). In addition to its wide spread use as a white pigment in glazes, TiO2 is also present, up to 4%, in a number of naturally occurring minerals that are used in the ceramic industry.

The Franz Kaldewei GmbH & Co. KG supports the position of the Titanium Dioxide Manufacturers Association (TDMA) and the Frits Consortium regarding the inclusion of titanium dioxide in Annex VI of CLP Regulation as a carcinogen category 2 by inhalation. This proposal is disproportionate and would not bring any real benefits in terms of protection of human health or the environment.

I would like to comment on the proposed classification of the titanium dioxide (TiO2). The paint and coatings industry, which uses TiO2 in more than 80 % of its products and consumes 60 % of production, has already contested this proposal.

Filed in French · English published by the European Commission

The proposal on classification and labelling of titanium dioxide cannot be justified and therefore titanium dioxide should not be included in the 14. ATP. The planned classification is not specific in substance and ultimately applies to all substances in powder form with low solubility.

Filed in German · English published by the European Commission

As a manufacturer of paints in Luxembourg, we hereby inform you of our opinion on the classification of TiO2 in H351 (inhalation). We believe it is necessary to split into two parts: 1 Use of TiO2 by our production operators and 2 Use of paint by consumers In terms of factory use, we are exposed to the dangers of handling powders and other chemicals.

Filed in French · English published by the European Commission

This is N. KRALLIS S.A., a company established in 1887. We have been merchandizing, as agents and distributors, TiO2 since 1963, so over 50 years, always partnered with the same producer. We have a leading position in the Greek, Cypriot and Albanian markets, therefore an excellent knowledge of the possible consequences in the case of a negative outcome.

Brenntag is the global market leader in chemical distribution. The German based international company manages complex supply chains for both chemical manufacturers and consumers by simplifying market access to thousands of products and services. It combines a global network with outstanding local execution.

Since the creation of the CWS, titanium dioxide is used as a white pigment and thus the main raw material is used. This is contained in more than 95 % of preparations. The practical experience of dealing with titanium dioxide and the potential health effects/risks are completely unremarkable.

Filed in German · English published by the European Commission

The Chemours Company welcomes the opportunity to provide comments into the “Better Regulation consultation on the 14th ATP to the CLP Regulation”. As a major titanium dioxide (TiO2) manufacturer, we are concerned about the proposed entry to classify TiO2 and the lack of application of due diligence in the transposition of the ECHA Risk Assessments Committee (RAC) opinion into a legislative proposal and its impact on…

To European Commission, We are Japan Chemical Fibers Association (JCFA). The proposal for the powder containing 1 % and over of 10 μm or less TiO2 to be classified as carcinogenicity 2 (inhalation) holds varied problems in predicted practical operations. Specific explanations will be pointed out as under; 1.

DFL welcomes the public consultation of the 14th alignment to the CLP Regulation under the Better Regulation initiative. DFL represents producers and importers of paints, inks, glues and sealants in Denmark; An industry where the use of titanium dioxide is extensive. Only the TiO2 classification proposal, DFL, will focus on the following comment.

Filed in Danish · English published by the European Commission

A vote on the classification of cobalt will be held at the February meeting of the REACH committee. According to the current information, the vote at the meeting will be held on the Commission’s proposal for a new hazard classification, with the main topic being that cobalt is carcinogenic 1B on all exposure routes, with a GCL (General concentration limit) of 0.1, and a new working group should be established to…

Hellenic Coatings Association (HCA) represents the Hellenic Coating and Printing Inks Industry, our Members are small and Medium sized enterprises. We welcome the invitation to participate in the public consultation. We express our disappointment about the proposal of the European Commission after such long time of discussions.

The Hellenic Association of Chemical Industries (HACI) represents the Hellenic Chemical companies mainly SMEs, many out of them use TiO2 in activities such paints, printing inks, papers, plastics, packaging materials etc. HACI welcomes this public consultation under the Better Regulation initiative.

ANFFECC, the Spanish Association for frits, glazes and inorganic pigments supports the position of the Titanium Dioxide Manufacturers Association (TDMA) and the Inorganics and Frits Consortia regarding the inclusion of titanium dioxide in Annex VI of CLP Regulation as a carcinogen category 2 by inhalation.

EDRA welcomes this public consultation. EDRA is the European association that represents European DIY retailers. As such, we are by far the largest paint retailers. On safety, the hazard is only relevant for workers in industrial environment. Indeed, TiO2 dust is generated during production of the substance itself or in the production of mixtures containing the substance.

SAMIA S.p.A., for over 40 years, is a company producing leather finishing products, among which pigment pastes are very important. The danger represented by the titanium dioxide is not due to the chemical composition, but is related only to the size of its particles, as is the case for many other substances.

Classification proposal for Titanium Dioxide: Titanium Dioxide is a natural mineral, which is already used for hundreds of years. Not only in paints, but also in textiles, paper, toothpaste, sun-scream, medicine, plastics and more. For paints it’s used as raw material which gives white opacity and outdoor durability performances. 80% of all paints are containing Titanium Dioxide.

The Frit Consortium represents 34 frits manufacturers from 8 EU Member States (Spain, Italy, Germany, France, Belgium, The Netherlands, Czech Republic and UK). The production of frits and frits-containing mixtures with TiO2 in the European Union accounts for over 230.000 tonnes annually and represents an estimated turnover of 130 million € approximately, employing more than 3200 workers.

The Inorganic Pigments Consortium represents 24 manufacturers and importers of complex inorganic pigments, from 5 EU Member States (Spain, Italy, Germany, The Netherlands and UK). The production of pigments and mixtures with TiO2 in the European Union accounts for over 11000 tonnes annually and represents an estimated turnover of 35 million € approximately, employing more than 2000 workers.

Venator is a leading chemical company focused on the development and manufacture of titanium dioxide pigments and performance additives. Venator’s products are used as intelligent ingredients in thousands of everyday items including coatings, plastics, cosmetics, paper, pharmaceuticals, fibers, films, inks, catalysts, concrete, building materials and in water purification.

The Irish Decorative Surface Coatings Association represents manufacturers and distributors of paint and coatings products in Ireland. Titanium Dioxide (TiO2) is a key substance in the majority of paint lines and we, as well as our colleagues throughout Europe, have made representations in relation to our serious reservations about its proposed classification as a carcinogen category 2.

European Man-made Fibres Association (CIRFS) welcomes this public consultation under the Better Regulation initiative. CIRFS is the representative of major man-made fibres manufacturers in Europe. For our industry titanium dioxide is the essential pigment and is used as one of the most important delustering agent additives in man-made fibre production.

A medium sized manufacture making paint mainly for the protection of steel using Titanium Dioxide as our primary white opacifying pigment. Chemical Effects v Physical Effect of Lung Overload Our understanding is that the regulations were written with the intention that they would cover chemical rather than physical effects.

VVVF/VLK represent the Dutch paint, printing ink, adhesive and sealants manufacturers. First of all we regret that proposed classification was submitted before the REACH dossier was evaluated under CoRAP. The scientific data on titanium dioxide shows that the potential for carcinogenicity by inhalation is related to the effects of inhaling the chemically inert dust.

Titanium dioxide is a substance widely used in paints and various coatings. As a result of the high luminous dissipation capability of its crystals, titanium dioxide has the highest surface coating capacity. No alternative substitutes have been created so far. Titanium dioxide is added to the paints as an pigment, and then it is permanently tied to a binder matrix.

Filed in Polish · English published by the European Commission

SOCOL SA has been a Swiss paint and varnish production company for 80 years. The classification of TiO2 as a carcinogen category 2 by inhalation will put at risk the coating industry without any significant improvement from a health point of view.

Filed in French · English published by the European Commission

1. TiO2 shall be completely exempted from ATP 14 2. CLP regulation is not suitable for classification of poorely soluble, low toxicity particles (PSLTs), they are covered by the legislation on safety and health at work 3. Evaluation of the TiO2 dossier is still in process (CoRAP), it is unacceptable to decide upon any question regarding TiO2 prior to conclusion of this process 4.

General comments: 1. classification of titanium dioxide as carz. Cat. 2 is disproportionate In accordance with the principle of EU proportionality, which is one of the fundamental principles of the EU, the Commission must choose the least burdensome regulatory measure in order to achieve the objective pursued.

Filed in German · English published by the European Commission

We regret the proposal to classify titanium dioxide as a carcinogen. In our sector, furniture and wood, titanium dioxide is widely used in the paper layer for decoration on plates and laminate flooring. We have the impression that this classification is based on the fact that titanium dioxide gives rise to the formation of dust and that dust may in general be carcinogenic and therefore not typical of titanium…

Filed in Dutch · English published by the European Commission

Czech Technology Platform Plastics does not agree with the proposed entry of titanium dioxide (TiO2) into Annex VI (CLP Regulation) and is convinced that alternative proposals (UK, Slovenian and German) address the issue of TiO2 in a more proper way while taking real concerns described by ECHA into account.

Romanian Chemical Producers and Distributors Association – APDCR is a non-profit, non-governmental organization founded in August 2013. Through its mission, APDCR promotes the scientific, technical, environmental, economic and legal aspects of companies established in Romania in the chemical, petrochemical, plastic and pharmaceutical sectors, contributing to their sustainable development.

DAW SE is a family owned company since 1895 and one of Europe's leading suppliers of coating systems with approximately 5600 employees within Europe. Titanium dioxide is one of the most important raw materials for the production of high quality paints, lacquers, renders, plasters and other coating materials. There are no equivalent alternatives from a technical and economical point of view.

Romanian Chemical Producers and Distributors Association (ROMANIA) Romanian Chemical Producers and Distributors Association – APDCR is a non-profit, non-governmental organization founded in August 2013. Through its mission, APDCR promotes the scientific, technical, environmental, economic and legal aspects of companies established in Romania in the chemical, petrochemical, plastic and pharmaceutical sectors…

BVKI, the confederation of the associations of the German Fine Ceramic Industry (sanitary ware, table & decorative ware, technical ceramics and abrasives) welcomes this public consultation under the Better Regulation initiative on the classification of Titanium dioxide (TiO2).

Pfleiderer Company is one of the leading producers of wood based panels in Europe. In 9 plants (5 in Germany, 4 in Poland), Pfleiderer is producing 3,2 million m³ particleboards, 0,6 million m³ MDF boards, 112 million m² laminated boards, 33 million m² of HPL and approximately 380.000 tons of gluten. About 50 % of the row boards are covered with Defative paper it for the European Furniture Industry.

Filed in German · English published by the European Commission

Cromology produces paints for over 250 years and is today a world player in the decorative paint sector. The Group ranks in second place in France and is the market leader in Southern Europe (Italy, Spain and Portugal).

We oppose the classification of titanium dioxide as carcinogenic. This measure is disproportionate because it does not contribute to better human protection. Alternative regulatory options are available which would better address the potential concerns, including EU harmonised health and safety measures. For further details, see the attached document.

• I question why the proposed classification for all forms of titanium dioxide was submitted before the expected CoRAP evaluation, which had already been scheduled for 2018. Carrying out two evaluations within a short timescale is not good regulation. Relevance of CLP and the proposed classification • The effect observed in rats is not an intrinsic property of titanium dioxide and this should be out of scope of CLP.

In Annex III, titanium dioxide should be deleted and the new observations V and 10 should not be inserted. In Annex I, under point 2.12, it should be added that the two sets of EUH rates are only applicable to consumer products. Justification 1 No occupational disease: Statutory accident insurance in Germany has no evidence of lung cancer cases at workplaces where titanium dioxide is used.

Filed in German · English published by the European Commission

Apart from any economic and technical consideration, the classification of the titanium dioxide as a carcinogenic substance descends from its particle size and not from its chemistry. Every dust in fine particle size can affect the lungs of the people exposed to it, and all the possible technical substitution for titanium dioxide will be in powder form and will lead to the same (or worse) toxicity.

Cinkarna Celje, d.d. as producer of titanium dioxide, is pleased to have the opportunity to give our input to the public consultation on 14th ATP proposal to CLP, where TiO2 CLH inclusion in Annex VI and II is proposed. Based on our experience with Titanium dioxide, we have to express our non-agreement with the current proposal.

We agree with the reasoning of the VdL: 1 It is not about the substance titanium dioxide, but dust at the workplace. Most Member States have already introduced national dust levels. European harmonisation of these national limit values would be useful and has already been initiated by the DG Employment.

Filed in German · English published by the European Commission

Regarding the classification of TiO2 there are a number of points that Paragon Inks would like to purvey. 1. Why the proposed classification was submitted before the expected CoRAP evaluation? 2. We question the testing methodology used. The lung overload used on the rats was unnatural and unrealistic to the actual/real conditions in the potentially most affected area, the industrial environment.

We are manufacturers of dry mortar, pasty plasters and colours. In order to colour our construction products, we use titanium dioxide as an important raw material in our formulations. Titanium dioxide is used by us as a raw material that is currently not available to achieve high quality product qualities.

Filed in German · English published by the European Commission

We question why the proposed classification for all forms of titanium dioxide was submitted before the expected CoRAP evaluation, which had already been scheduled for 2018. Carrying out two evaluations within a short timescale is fundamentally scientifically flawed. The effect observed in rats from one study alone is not an intrinsic property of titanium dioxide and therefore is outside of CLP.

Industrievereinigung Chemiefaser e.V. (IVC) welcomes this public consultation under the Better Regulation initiative. IVC is the representative of major man-made fibres manufacturers in Germany, Austria and Switzerland. For our industry titanium dioxide is the essential pigment and is used as one of the most important delustering agent additives in man-made fibre production.

1 Titanium dioxide dust should not be classified under CLP, as it is not the chemical composition of the dust; But particulate matter. These should be regulated differently. 2 All white paints should not be classified with CLP because titanium dioxide dust is bound by the paint and therefore it will not be affected by it.

Filed in Danish · English published by the European Commission

Outokumpu is a major producer of stainless steel in the EU and we are deeply concerned about the proposed classification of cobalt and the implications it will have on stainless steel due to the small amounts of cobalt that are present in all stainless steel as impurity.

The paint industry is a major consumer of titanium dioxide. It is applied in a large part of the range and the proposed classification for TiO2 will have far-reaching consequences. These must be seen as disproportionate.

Filed in Dutch · English published by the European Commission

The proposed classification of titanium dioxide (TiO2) is disproportionate and does not meet the burdens of legal compliance or certainty. The proposal is at odds with the stated positions of several Member States due to concerns about its added value for protection of human health and its wide-ranging impacts.

Aprochimide srl is a TiO2 dispenser on the Italian market in a variety of sectors; The classification proposed by the EC is considered to be an inadequate step compared to the real risks and concerns raised by the relevant studies. The proposed classification therefore did not improve the human health of workers and users of products containing TiO2.

Filed in Italian · English published by the European Commission

Japan Paint Manufacturers Association (JPMA) is affiliated with the International Paint and Printing Ink Council, Inc. (IPPIC), a global non-governmental organization whose membership is comprised of national and regional trade associations representing the paint and printing ink industry around the world.

1 The downstream content of titanium dioxide would be disproportionately affected by the classification given the low level of scientific deposit. We reject the proposal for scientific, economic and political reasons. 2 The wood-based industry and producers of wood and wood-based materials use titanium dioxide as a white pigment in the coating; This usually amounts to more than 1 %.

Filed in German · English published by the European Commission

Dear Sir and Madam, I am glad to have this opportunity to submit out opinion to you. We are Titanium Dioxide Manufactures Association in Japan. (JTDMA) The proposal for the powder containing 1 % and over of 10 μm or less TiO2 to be classified as carcinogenicity 2 (inhalation) holds varied problems in predicted practical operations. Specific explanations will be pointed out as under; 1.

In Mexico, I am a manager of the paint manufacturing industry and I am very alarmed that this regulation may become effective because it would set a disastrous precedent. The paints industry uses 60 % of the global refined titanium dioxide annually and is present in 80 % of globally produced paints and coatings providing them with hiding, opacity and whiteness.

Filed in Spanish · English published by the European Commission

These comments are published on behalf of BASF, Dow and Nouryon (the "Dossier Submitters" on DTPA). Due to character number limitation, the full comments are provided as an attachment to this introduction. Please consider the attached pdf document as the full set of comments submitted by the Dossier Submitters.

The National Association of Paints and Printing Manufacturers, A.C. (ANAFAPYT) is a representative of paint and inks manufacturers and raw material suppliers in Mexico, we express concern at the European Union (EU) initiative of cataloguing two for Titanium Dioxide (TiO2) as carcinogenic category two as carcinogenic category two to Titanium Dioxide (TiO).

Filed in Spanish · English published by the European Commission

The Tobacco Industry Platform on REACH ("TIP") is an industry group representing trade associations and companies involved in the manufacturing of tobacco products. The objective of TIP is to facilitate compliance with REACH and related EU legislation by TIP Members by addressing issues related to substances used in tobacco products.

Titanium dioxide TiO2 is a key raw material for all industrial coating manufacturers. As a responsible user of chemicals, we fully support CLP and REACH but fundamentally disagree with the treatment of TiO2 in this way. To base a potential classification on a single study for dust and lung overload in rats does nothing to assess the potential hazard of TiO2.

The proposed classification of Titanium dioxide TiO2 as a carcinogen category 2 by inhalation is solely linked to a general particle effect and not specifically to the substance itself. This “dust-effect” applies to many other substances in powder form: Poorly soluble particles with low toxicity (PSLTs). TiO2 has been used for decades in countless products and articles, safely bound in a matrix.

We would like to express our position on behalf of our company in response to the consultation on the proposed classification of titanium dioxide. Research Researcher at the paint industry. In industrial paints (FKI), it carries out a wide range of activities, services and services as leaders of many products. o Our accredited laboratory carries out paint industry tests in accordance with EN ISO/IEC 17025.

Filed in Hungarian · English published by the European Commission

We are a major paint manufacturer in Europe and consume several thousand tonnes of Ti02. TiO2 is indispensable for the production of paints. There are no equivalent alternatives in terms of performance. The classification of titanium dioxide would set a dangerous precedent in European chemical policy because the risk described for TiO2 is not specific to the substance itself, but it applies to many other substances…

Filed in Portuguese · English published by the European Commission

PRECHEZA a.s., the manufacturer of TiO2 pigments, considers the classification as proposed by the EC to be an inadequate step in relation to real risks as well as to concerns raised by relevant studies. The classification as such does not bring any benefits for human health but rather a lot of negative impacts coming from procedures set in the EU and national legislations.

There is no evidence that liquid droplets of TiO2 mixtures have the same toxicological properties of the TiO2 . In fact as a paint chemist i am sure that a droplet even when it is pulverized by spray , all the time the particles of TiO2 are envolved by a binder and other components that avoid the TiO2 particles to be free , and so without no other evidence i do not believe that cancerogenic effect of TiO2 when mixed…

The Hungarian Manufacturers’ Association (MAFEOSZ) is pleased to have the opportunity to express their views/concerns/opinions on 14. In connection with the proposal for classification of titanium dioxide in the ATP draft. Our association represents the professional interests of the companies active in the Hungarian paint industry.

Filed in Hungarian · English published by the European Commission

Titanium dioxide is the most common white pigment. It has been used from the twenties of the last century, when it replaced the toxic lead white, or other white pigments exhibiting a lower refractive index. IARC in their 2010 publication evaluated TiO2 as possibly carcinogenic for humans (2B class) based on inadequate evidence in humans and sufficient evidence in experimental animals.

The German Chemical Industry Association (VCI) welcomes this public consultation under the Better Regulation initiative. The proposal for classification and labelling of titanium dioxide is inappropriate from the toxicological and epidemiological perspective. The criteria for classification are not met. Consequently titanium dioxide should not be included in the 14.

The hubergroup produces inks for a wide range of applications. A very large number of our products contain titanium dioxide. Therefore, the planned classification would have far-reaching consequences for our group of companies.

Filed in German · English published by the European Commission

IKEM — Innovations and chemical industries in Sweden would like to take the opportunity to comment on the proposal of 14th ATP to CLP. The draft ATP contains the titanium dioxide listed, and our appeal to the Commission and the Member States is to remove the titanium dioxide from the proposal for an ATP, since there are still a number of unresolved questions and uncertainties. We list the most important ones below.

Filed in Swedish · English published by the European Commission

We are a paint manufacturer for the area of Decoration and anti-corrosion protection. In our view, the scientific relevance of the carcinogenic tests carried out on TiO2 and its conclusions should be questioned. The proposed classification is related to particle size and is not specific to TiO2. many pigments and loads with low solubility and toxicity may apply. Thus, TiO2 should not be regulated under CLP.

Filed in Spanish · English published by the European Commission

IKEM — Innovations and chemical industries in Sweden support BASF, Dow and Nouryos (the owners of the file) in their argumentation that DTPA should not be classified as category 1B reproductive toxicant. We therefore urge the Commission and the Member States to defer the inclusion of DTPA and its salts in the ATO of the ATO, until the Pelagic RAC has been able to review all data, including the one that has been…

Filed in Swedish · English published by the European Commission

IMA-Europe, the European Industrial Minerals Association, does not support the adoption of the draft act with regard to the Annex VI listing of TiO2 as a carcinogen 2 by inhalation. The primary goal of CLP is to ensure a high level of protection of human health and the environment, as well as the free movement of substances.

Represented by the spoon PPG Deco Czech a.s. makes a negative opinion on the proposed amendment to the classification of titanium dioxide (TiO2) in the direction of the classification ‘Carciningen Category 2’. We are asking for the suspension of negotiations, the examination of the studies carried out, the initiation of new correctly defined studies and the taking into account of the potentially huge consequences of…

Filed in Czech · English published by the European Commission

The proposed classification is linked to a dust effect, i.e. the lung overload of solid particles of poor solubility. Therefore it deserved a broader discussion before a harmonized classification could have been justified. Titanium dioxide has been used for decades safely in thousands of products and articles.

Dear Sir/Madam, as a pigment processing company, we would like to reiterate our opposition to the classification of titanium dioxide as a hazardous substance and to the inclusion of this substance in the 14. The ATP and the German proposal to address this issue.

Filed in German · English published by the European Commission

Emil Frei GmbH & Co KG is manufacturers of industrial paints, pulps, electric boxes and glass fibre products. For the production of paint, there is currently no equivalent alternative to titanium dioxide, either as regards its performance or its availability on the world market.

Filed in German · English published by the European Commission

1 It is not about the substance titanium dioxide, but dust at the workplace. Most Member States have already introduced national dust levels. European harmonisation of these national limit values would be useful and has already been initiated by the DG Employment.

Filed in German · English published by the European Commission

Siegwerk is an international manufacturer of printing inks for packaging of any kind. Our industry is certainly amongst the major users of titanium dioxide, in the form of white printing inks, but also in many other colour shades. The proposed classification would have a massive and dramatically misleading influence on our industry. Liquid mixtures like printing inks would carry a warning label stating “Warning!

FIPEC (Fédération des Industries des Paints, Encres, Colles, Colles and adhesives, preservation of wood) is the professional organisation representing businesses in the sector in France. FIPEC represents 150 companies with a turnover of EUR 4.5 billion with 17 000 employees. The FIPEC welcomes the public consultation launched by the European Commission.

Filed in French · English published by the European Commission

The proposed classification of Titanium dioxide TiO2 as a carcinogen category 2 by inhalation is solely linked to a general particle effect and not specifically to the substance itself. This “dust-effect” applies to many other substances in powder form: Poorly soluble particles with low toxicity (PSLTs). TiO2 has been used for decades in countless products and articles, safely bound in a matrix.

We are one of Europe’s leading paint manufacturers (18th in European Coatings Journal of May 2018) and consume several thousand tonnes of Ti02 per year in about 3000 Building, Industry and anti-corrosive coatings. Firstly, we question the scientific relevance of the carcinogenic tests carried out for TiO2 and their results.

Filed in Portuguese · English published by the European Commission

EFCC is the European Federation for Construction Chemicals. Based in Brussels since 2005, EFCC represents Construction Chemicals Companies (both raw materials producers for construction chemicals and formulators of construction chemicals) and Associations in Europe. Directly and indirectly EFCC represents more than 120 Companies covering most of the Construction Chemicals Market in Europe.

The Portuguese Association of Paints is clearly against the proposal for the classification of TiO2 as a substance suspected of having carcinogenic effect in humans, inhalation (category 2) by economic impacts, but above all because it is not public health, and because the carcinogenic effect in the case of the use of titanium in liquid mixtures is not proven.

Filed in Portuguese · English published by the European Commission

A classification of titanium dioxide would introduce severe limitations to the European circular economy model, which is based on recycling tools/modules. For example, every waste with a titanium dioxide content of 1% or more would have to be treated as "hazardous waste”.

TiO2 has been used for decades in countless products and articles that are securely attached in a matrix. Exposure is only relevant for workers in the industrial production environments where the limit values for protection against dust at work apply.

Filed in German · English published by the European Commission

We provide comment on the specific classification proposal for Titanium Dioxide (TiO2). The paint and coatings industry, which has TiO2 present in more than 80 percent of our products and uses 60 percent of all TiO2 manufactured, has challenged this proposal.

The British Ceramic Confederation (BCC) is the trade association representing the collective interests of the UK ceramic manufacturing industry. Our 90-plus member companies cover the full spectrum of ceramic products and over 90% of the UK industry’s manufacturing capacity. The sector directly employs over 22,000 full-time employees in the UK, with many more in the supply chain, and generates £2bn in annual sales.

1 It is not about the substance titanium dioxide, but dust at the workplace. Most Member States have already introduced national dust levels. European harmonisation of these national limit values would be useful and has already been initiated by the DG Employment.

Filed in German · English published by the European Commission

“ADLER-Werk Lackfabrik Johann Berghofer GmbH & Co KG” is a manufacturer of paints, varnishes and wood preservatives in Austria. A very important substance of the majority of these products is titanium dioxide. Titanium dioxide has the highest covering capacity of all white pigments. There are no comparable substances existing, which have such good technical properties, sustainability and availability.

The Federal Association for Colour Design & Protection of Structures is an employer association, which represents the skilled craft of painters in Germany. The new regulatory proposal would have a serious negative impact on our market, but would not benefit occupational health and safety for professional painters.

The proposed classification of Titanium dioxide TiO2 as a carcinogen category 2 by inhalation is solely linked to a general particle effect and not specifically to the substance itself. This “dust-effect” applies to many other substances in powder form: Poorly soluble particles with low toxicity (PSLTs). TiO2 has been used for decades in countless products and articles, safely bound in a matrix.

IGI – The Global Wallcoverings Association – does not support the inclusion of titanium dioxide and other PSLTs (Poorly Soluble Low Toxicity substances) in REACH annex VI, for the CLP regulations. This proposed classification for titanium dioxide is based on a test of lung overload in rats, and has no relevance to humans or any exposure situation experienced in reality.

The evaluation of the scientific evidence has made clear that there is no evidence that titanium dioxide presents a risk for humans. On the opposite: Extensive epidemiological studies on 24,000 workers in titanium dioxide factories over many decades, inter alia in Germany, showed no negative health effect. The classification proposal on the other hand is based on a single controversial rat study from 1995.

Association of Chemical Industry of the Czech Republic disagrees with the TiO2 entry to Annex VI (CLP Regulation) for the following reasons: 1. Particle effect is not intrinsic property The intrinsic property is the one that can be allocated to a specific substance. RAC’s recommendation operates with a general particle effect assigned for the group of Poorly Soluble Low Toxicity (PSLT) particles.

Verband der Mineralfarbenindustrie e.V. (VdMi) represents the German manufacturers of inorganic and organic pigments, fillers, carbon black, ceramic colours, food colourants, artists’ and school colours, masterbatches, and products for applied photocatalysis. VdMi represents in total 75 companies, about 75 % of the companies are SME’s. The combined annual turnover of the sectors is about 4 billion Euro.

The German Association of Plastics Converters (GKV) is the leading organization of the German plastics processing industry. As an umbrella organization, it bundles and represents the common interests of its member associations and acts as a voice to politics and the public. GKV is opposed to the intended classification and labeling of powdered titanium dioxide and mixtures containing titanium dioxide.

The classification of titanium dioxide in the European chemical policy, but applications to numerotus other substances in the form (known as PSLL). Therfore, any decision taken on titanium dioxides seek to effect the entire group of substances, including many alternative pigments. In our view, such a classification would be out of the legal scope of the CLP regulation.

Filed in German · English published by the European Commission

Article 5 of CLP requires that the information used to classify a substance shall include "epidemiological data and experience on the effects on humans, such as occupational data.." NO POSITIVE CORRELATION FOUND [Fryzek et al.2003; Boffetta et al.

CEPE welcome this public consultation under the Better Regulation initiative. CEPE represents the paint, printing ink and artists’ colours manufacturers in Europe. Our industry is the main user (60% of total volume) of the essential pigment titanium dioxide.

Geholit+Wiemer GmbH produces protective coatings for the industrial and construction sectors. The new classification proposal of TiO2 affects the paint and coatings industry immensely. About 70% of our products contain TiO2, most of them more than 1%, and would have to be labelled with EUH211. This would have immediate unintended consequences of no avail for us and our customers.

The position of the Czech Association of Paint Industry for Better regulation public consultation We oppose the proposal for the classification of titanium dioxide as drafted by the European Commission in Draft regulation - Ares(2019)141469 and Annex - Ares(2019)141469/1.

CPCA represents manufacturers and suppliers in the paint and coatings industry in Canada, representing 90 percent of the volume of coatings sold in Canada. Recently Canada signed the Canada European Trade Agreement and the outcome of this process is likely to reparably harm trade between our two countries related to coatings, something which CETA, signed by all 28 States, was meant to prevent.

The problem is not the substance titanium dioxide, but dust in the workplace. Most Member States have already introduced national threshold limits for dust. A European harmonization of these national limit values would make sense and has already been initiated by Directorate-General for Employment. Titanium dioxide is not a risk to humans.

The BCF is the trade association representing the interests of the decorative, industrial and powder coatings, printing inks and wallcovering manufacturers of the UK. It covers 140 manufacturing members encompassing 95% of the UK sales of this sector.

(note: I am an administrator of a Portuguese paint producing SME) The whole process of possible TiO2 (mainly this substance) appears absurd from the outset. The scientific evidence supporting the beginning of this discussion is the antipoess of what is meant as a recurring evidence for the purpose of making science.

Filed in Portuguese · English published by the European Commission

Working 30 years with materials for plastic and coating industry and knowing various processing technology I see new rules concerning TiO2 and cobalt as very questionable. TiO2 - studies shows negative impact of TiO2 nanoparticles on human health - BUT all nanoparticles can have negative impacts on human health and especially by inhalation! So better to list all nanoparticles as potentially risky. Why only TiO2?

Although Mastersweet and plastic products within the meaning of the European Commission’s proposal may not have to be marked, the classification of TiO2 would result in some negative effects for the plastic industry: — Negative perception of the public to use TiO2 as a carcinogen in products, particularly in more sensitive areas such as toys or plastics coming into contact with food.

Filed in Czech · English published by the European Commission

The American Coatings Association Supports its EU-based Trade Association Members Position The American Coatings Association (ACA) is a member of the International Paint and Printing Ink Council, Inc. (IPPIC), a global non-governmental organization whose membership is comprised of national and regional trade associations representing the paint and printing ink industry around the world.

IPPIC Supports its EU-based Trade Association Members Position The International Paint and Printing Ink Council, Inc. (IPPIC), a global non-governmental organization whose membership is comprised of national and regional trade associations representing the paint and printing ink industry around the world.

The classification proposal suggests that titanium dioxide is more dangerous than other substances which are also hazardous in the form of dust. However, there is no basis for this. On the contrary, like many other substances, the inhalation of the dust is avoided. There are strict limits in Germany. These limits should be introduced across the EU.

Filed in German · English published by the European Commission

In its opinion on the draft regulation of the European Commission, which seeks to adapt to scientific and technical progress Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures, it should be pointed out that it included the classification of titanium white (TiO2) as a carcinogen category 2 (inhalation exposure).

Filed in Polish · English published by the European Commission

Titanium dioxide is the only covering pigment for all white or light coloured paints. The colour of titanium dioxide does not include titanium dioxide. There is no alternative. If a label is to be used, all white colours would have to disappear from the “Do it yourself” area and even the technicians must receive additional training.

Filed in German · English published by the European Commission

Dear, we produce anti-rust paints and varnishes. About 75 % of products contain titanium dioxide. The majority of products are authorised for contact with food and/or for children’s toys (EN 71-3), or used in the automotive diet or in the supply of drinking water or for swimming pools (also light blue contains titanium dioxide), etc.

Filed in German · English published by the European Commission

ACUERDO DIPLOMÁTICO ENTRE EMBAJADAS Moscow – Madrid : Informe Brexit sobre la planificación de contingencia para la salida del Reino Unido de la Unión Europea sin acuerdo. Viernes 11 de enero de 2019 El Consejo de Ministros ha presentado el Informe sobre la planificación de contingencia para la salida del Reino Unido de la Unión Europea (UE) sin acuerdo.