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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.

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.

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 Confederation of Danish Industry share the Commissions view that the current BPR framework presents substantial regulatory and practical challenges. We are ready to contribute to identifying and implementing constructive solutions to improve the system, and our members are committed to ensuring high standards to protect the environment.