FEPA, the Federation of European Producers of abrasives welcomes the opportunity to provide comments to this public consultation under the Better Regulation initiative on the classification of Titanium dioxide (TiO2).
FEPA represents over 200 companies (140 headquarters) gathering 90% of European abrasives producers. With a turnover estimated at €3.5 billion and 20.000 salaries in the EU , the abrasives industry is of major importance for the European Union. This is further emphasized by the fact that many industry sectors in Europe are supplied by the abrasive industry and depend on their products.
TiO2 is an essential raw material for the production of different types of abrasive products. Titanium dioxide is e.g. an intrinsic component of many corundum grains which are essential raw materials for the production of abrasive products.
In our view, the proposal for classification and labelling of TiO2 is inappropriate from the toxicological and epidemiological perspective. FEPA fully supports the argumentation against the proposed classification submitted by TDIC and TDMA.
In addition, a classification of TiO2 as Carc. 2 would have far-reaching and significant unintended consequences with respect to classification of waste. Waste containing more than 1% TiO2 would have to be classified as "hazardous waste” which would reduce the options for recycling and increase costs. We remain at your disposal.