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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.

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.

VVVF and VLK, the Dutch Association of Paint and Printing Inks and the Dutch association of Adhesives and Sealants, welcome the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR). In its current form, the BPR is overly complex and not fit for purpose for the paints, printing inks, adhesive and sealant industry. See the attached document for our main recommendations

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.