­­REACH committee convenes over cancer classification and labelling of titanium dioxide
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­­REACH committee convenes over cancer classification and labelling of titanium dioxide

Titanium dioxide is a whitening agent that comes in many forms, shapes and sizes. It is used in a tremendous range of applications, including food, cosmetics, sunscreens, paints, and printing.

Titanium dioxide is also a suspected carcinogen and studies conducted on rats show that inhalation of it induces lung tumours.

The legislative process surrounding the substance has been covered in the media at great length over recent years. 11 April marks another important date in this continuing story, as this is when the REACH Committee will discuss classification and potential labelling of the substance.

“We know titanium dioxide can cause cancer if the substance is inhaled. It should therefore be classified and require labelling. Industry counter-arguments against labelling suggest it is not necessary if inhalation is not likely. However, in the case of classification and labelling, it is the intrinsic hazard of the substance that should decide the label, not the route of exposure. A good reason for this is that many products are not always used in the way that industry intends”, says Frida Hök, ChemSec Senior Policy Advisor.

The process of classifying titanium dioxide has been lengthy and paved with controversies. It started in 2016 when France proposed that the substance be classified as a 1B carcinogen. This level of classification would in turn be enough for an SVHC (Substance of Very High Concern) identification and listing on the REACH Candidate List.

“We know titanium dioxide can cause cancer if the substance is inhaled”

This caused unprecedented levels of lobbying from an industry group calling themselves TDMA – The Titanium Dioxide Manufacturers Association – as reported by, for example, the Corporate Observatory and the Guardian.

In 2017, discussions in the Risk Assessment Committee eventually resulted in a proposal to classify the substance as a potential carcinogen, class 2, which is not enough for SVHC identification. It does, however, require labelling of products containing the substance.

This was not the end of the discussion, but just the beginning. One of the main arguments concerned the number of products that would be affected by labelling.

As one example, a German association of the paint and printing industry claimed that the classification would affect 90 percent of the paints and varnishes on the market and hence about 25,000 jobs.

Warning labels about potential carcinogens obviously make products less attractive to consumers. Equally important, labelling would require waste to be treated as hazardous.

“The main problem is if the Commission does not follow the recommendations from the scientific committee, but bows to industry pressure. Classification and labelling must be based on properties only and not on socio-economic considerations. Even though we understand the vast implications, including treatment of waste, a potential carcinogen must be treated exactly as such”, says Frida Hök.

“A potential carcinogen must be treated exactly as such”

The lobbying has resulted in lengthy discussions about what products should be exempted from the carcinogenic label, based on the different forms of titanium dioxide and the different routes of exposure.

Member states have not been able to agree on a proposal, in fact, the disagreement has been used as an argument to drop the whole attempt to classify titanium dioxide.

The proposal as it looks now, which comes up for discussion by the REACH committee on 11 April, is that titanium dioxide does not have to be labelled as a carcinogen if it is part of a mixture. Instead there should be a general warning about inhaling the product that does not mention the word “carcinogenic”. In addition, the classification proposal only applies to specific forms of titanium dioxide.

“To open the opportunity to derogate mixtures from classification is to open a Pandora’s box. It is not a precedent we would like to see”, says Frida Hök.