Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Company · Germany
Industry association · Finland
Declared costs: €100K+ a year · in the register since 2011
Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669 · Evaluation of the Biocidal Products Regulation
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
THOR GmbH · filed 8 Feb 2019 · source
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".
Chemical Industry Federation Finland · filed 8 Feb 2019 · source
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.
THOR GmbH · filed 5 Mar 2026 · source
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)
Chemical Industry Federation Finland · filed 5 Mar 2026 · source
The Chemical Industry Federation Finland supports the revision of the BPR. The availability of biocidal active substances and market for new biocidal solutions in EU is diminishing due to the strict interpretation of exclusion criteria, high uncertainty in getting approval, disproportionately high costs and long time-to-market.
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