Gesamtverband Kunststoffverarbeitende Industrie e. V.
GKV
Der GKV ist die Spitzenorganisation der deutschen Kunststoff verarbeitenden Industrie.
ID: 580953824885-92
Lobbying Activity
28 Jan 2019
The German Association of Plastics Converters (GKV) is the leading organization of the German plastics processing industry. As an umbrella organization, it bundles and represents the common interests of its member associations and acts as a voice to politics and the public.
GKV is opposed to the intended classification and labeling of powdered titanium dioxide and mixtures containing titanium dioxide. Titanium dioxide is the most widely used white color pigment in the plastics industry. It is characterized by a high UV stability, which is essential for plastic products in outdoor applications. 23 percent of the titanium dioxide converted in Europe are used in the plastics industry.
The results of actual studies show that TiO2 is currently a no-alternative white pigment in plastics processing. Although there are other white pigments, the optotechnical and processing-relevant properties are generally worse than those of TiO2.
In addition to its use as a white pigment, titanium dioxide also is used for brightening or reinforcement of other color pigments and as opacifier. In addition, titanium dioxide is used as an inorganic flame retardant, UV stabilizer and for the production of photocatalytic self-cleaning surfaces. About half the amount of titanium dioxide used in the plastics industry goes into primary products such as masterbatches or compounds.
The classification proposal is essentially based on animal studies. In the experimental animals exposed to extremely high concentrations of titanium dioxide dusts were that led to so-called "lung overload" effects. The dust concentrations used in the experiment were up to 200-fold higher than those for the respirable dust fraction (A-dust) applicable occupational exposure limit. Titanium dioxide has been used safely for decades and there are none practical problems known. A possible connection between titanium dioxide exposure and lung cancer has been analyzed in several epidemiological studies (case studies and cohort studies involving 20,000 workers in 15 titanium dioxide production sites). In no relevant study any link between TiO2 exposure and lung tumors is detected.
The effect of titanium dioxide to be considered is based solely on particle-induced inflammations in the lungs after inhalative dust exposure. This is however not substance-specific for titanium dioxide, but characteristic of a variety of dusts, regardless of the underlying substance. Possible substitutes are in relation to the achievable stability and color intensity as well as with respect to the wear behavior clearly less suitable than titanium dioxide and in turn pose specific risks. Possible Substitutes would be associated with additional costs for the processors and would also no benefit in terms of overall toxicity associated with the risk to provide inhalation of dusts. In the context of applications of titanium dioxide in the plastics industry are exclusive possible risks related to exposure of workers in the workplace. A workplace limit value, which also includes titanium dioxide, in Germany is given with the General Dust Exposure Limit which is prescribed in the German Technical Rule for Hazardous Substances. Setting such a limit across Europe would be a more appropriate means of ensuring health protection for workers than CLP classification.
In many legal regulations such as environmental and consumer protection regulations a classification and labeling as carcinogenic automatically and without further verification, whether from the use of the substance actually risks extensive obligations and far-reaching prohibitions and restrictions. In addition a classification can have far-reaching negative consequences for plastics recycling and be counterproductive to the ambitious goals of the European Commission on circular economy with plastics.
Please find additional arguments in our position paper attached.
Read full response