Fachverband Sanitär-Keramische Industrie e.V.
FSKI
Vertretung der Interessen der deutschen Sanitär-Keramischen Industrie z.B.
ID: 99756723537-03
Lobbying Activity
Response to Review of the Construction Products Regulation
30 Jun 2022
Dear DG GROW
please find our comments in the attached file.
Best regards
Martin Hartmann
Read full response6 Feb 2019
FSKI, the associations of the German Ceramic Sanitary Ware Manufacturery welcomes this public consultation under the Better Regulation initiative on the classification of Titanium dioxide (TiO2).
In addition to its wide spread use as a white pigment in glazes, TiO2 is also present, up to 4%, in a number of naturally occurring minerals that are used in the ceramic industry. TiO2 is also an essential raw material for the production of different types of technical ceramics and abrasive products.
The proposal for classification and labelling of TiO2 is inappropriate from the toxicological and epidemiological perspective. The criteria for classification are not met. In addition, it is highly questionable if the CLP regulation legally allows a classification based on non-substance specific effects.
Consequently, the BVKI is against the inclusion of TiO2 in the 14th ATP.
The hazard described for TiO2 (“general particle effects”) is not specific to the substance itself, but applies to all substances in powder form known as “Poorly Soluble particles with Low Toxicity” (PSLTs) and is limited on risks at the workplace. Therefore, any decision taken on TiO2 will set a precedent for this entire group of substances.
Germany/the German authorities had made the alternative proposal to harmonize the different general dust limits which are currently applied in Europe instead of including TiO2 in the 14th ATP. This approach of harmonization addresses effectively and adequately the potential effects of TiO2 and other PSLTs on European workers health. On the contrary, the proposed classification of TiO2 under CLP would have no direct benefit on the health and safety of workers.
Furthermore, a classification of TiO2 would have far-reaching and significant unintended consequences: For example, every waste with a TiO2 content of 1% or more would have to be treated as "hazardous waste”. This would apply to a variety of waste streams, in the special case of ceramics on construction waste and any broken porcelain. For such waste streams a classification would drastically reduce the options for recycling and increase costs to the economy and consumers. Such classification would also have significant negative effects on food contact materials made of ceramic.
The proposed warning label for liquid and solid mixtures (in Annex II CLP regulation) is misleading, disproportionate and therefore also rejected.
Conclusion
As a result, the proposed classification of TiO2 would have serious and disproportionately problematic effects on all other European or national regulations
which are based on the CLH classification of a material. This would impact the classification
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