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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.

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) .

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".

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.

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.

THOR is a global producer of speciality chemicals, delivering high-performance biocide, flame-retardant and personal-care solutions. Founded in England, we operate world-wide, enhancing the safety, durability and functionality of products across construction, coatings, hygiene, automotive, water treatment, personal care, textile sectors and more.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Peroxygens, a Cefic sector group, represents the European producers of hydrogen peroxide, we welcome the European Commissions evaluation of the Biocidal Products Regulation and the opportunity to contribute to this exercise, which assesses the Regulations fitness for purpose after more than a decade of implementation, in line with the Better Regulation Guidelines.

Biocides for Europe, a sector group of Cefic, would like to take this opportunity to present our 4-point action plan to simplify the BPR. The document outlines key actions and enablers to enhance the EUs competitiveness, improve time to market, remove uncertainty, and strengthen the innovation framework. The document draws on the experience of the Biocides for Europe membership and reflects our initial findings.