New regulations mean that powders, solid and liquid mixtures that contain more than 1% titanium dioxide may have to carry new warning labelling. The new labelling requirements must be implemented by October this year.
Titanium dioxide (TiO2) is a naturally occurring mineral used as a bright white pigment in many industrial applications, including architectural powder coating. It plays a critical role in providing essential properties including whiteness, covering power, brightness, stability and durability of colour that cannot be achieved with other raw materials. The vast majority of powder coating shades are actually produced with some titanium dioxide content.
In March 2020 the EU designated titanium dioxide as a suspected carcinogen (category 2) by inhalation, under the CLP (Classification, Labelling and Packaging) Regulation EC No. 1272/2008. (The EU CLP Regulation as amended, is retained in GB law). This new hazard classification is for titanium dioxide in powder form and in powder mixtures containing more than 1% titanium dioxide particles with an aerodynamic diameter ≤ 10 μm. In addition, all solid mixtures (e.g. pellets or blocks) which contain 1% or more titanium dioxide should also carry a hazard statement warning under EUH212: “Warning! Hazardous respirable dust may be formed when used. Do not breathe dust.”
Independent tests carried out for powder manufacturers on certain powders for powder coating showed that when these powders were used, the coatings and the coating waste generated during the coating process did not contain more than 1% by weight of titanium dioxide with an aerodynamic diameter of less than 10 μm. Even for the most finely grained powders studied, only 0.0081% titanium dioxide particles with an aerodynamic diameter smaller than 10 μm was measured in the production waste. This is about 120 times less than the limit value of 1% that will apply from October 2021. Based on these findings, powder coatings prior to application in powder form containing titanium dioxide do not normally meet the criteria for classification for mandatory labelling as laid down in the CLP Regulation. However, they should be labelled with the warning EUH212.
It is our understanding that articles that are coloured white with titanium dioxide, for example a powder coated aluminium profile, do not have to be classified and labelled as above.