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EUROPEAN ASSOCIATION FOR SURFACE TREATMENT ON ALUMINIUM

ESTAL

ESTAL acts as umbrella association of its members, aims to defend, promote and serve the interests of its members at European level, to actively contribute towards finding solutions to technical, economic and ecological issues associated with the production and utilisation of surface treated aluminium and to encourage the sharing of knowledge and the development of new technologies among its members.

Lobbying Activity

Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

8 Feb 2019

ESTAL, the European association for Surface Treatment on Aluminium, represents several hundreds of plants where aluminium profiles and sheets are painted for architectural applications, such as window frames or façade elements. We understand that there is considerable medical and scientific controversy over the opinion of ECHA’s RAC Committee, and the ensuing Commission’s draft amendment to classify TiO2 powders as Carc.Cat.2 in the framework of the CLP Regulation. We believe that the measure of classification is disproportionate and unnecessary. In powder coating on aluminium, an overwhelmingly high percentage of powders used are TiO2 powders. In the coating process, the applied powders are baked to above 180 to 200 °C after which there is no powder anymore, the TiO2 has become part of the solidified paint layer. Because the end product does not contain powder, classification of TiO2 powder does not add any value to the end user, who is not exposed in any way. As far as the workers in the coater’s plants are concerned, exposure to TiO2 powders is well understood and effectively under control since decades. The existing Safety Data Sheets are sufficient and appropriate to inform management and workers of the protection measures that have to be taken in the plant. Classification Carc.Cat 2 would lead to strange, terrifying labeling requirements on the powder boxes. The psychological impact of classification would be unnecessarily alarming. Also, the recycling possibilities of 'waste' or left-over powders could be seriously impacted. Transport from the coater’s plant to recycling facilities and reuse of left-overs would become much more complicated, thus unduly hampering the efforts of our industry to promote a circular economy approach. For the above reasons we ask the Commission to delete the paragraphs relating to TiO2 from the draft document.
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