CLP Classification of Titanium dioxide
Titanium dioxide is the most frequently produced and used pigment worldwide. The annual production volume is approximately 7.2 million tons (as of 2016). Due to the immense importance of titanium dioxide for the pigment and filler industry and its wide range of applications, a large number of the products represented in the VdMi are directly or indirectly affected by the classification. The VdMi has therefore accompanied the classification process from the beginning in 2016 and regularly informs about the consequences for the industry, but also for the consumer.
The classification was published on 18 February 2020 in the 14th ATP (EU No. 2020/217). By the end of the transition period on 1 October 2021, the classification was implemented throughout the supply chain.
Industry took legal action at the European Court of Justice and succeeded
Several titanium dioxide manufacturers and 3 paint manufacturers filed a complaint against the classification in summer 2020. On 23 November 2022, the European General Court ruled in their favour: the classification and labelling of titanium dioxide in powder form as a category 2 carcinogen is not justified and is to be annuled. The Commission and France appealed against the ruling. On 1 August 2025, the European Court of Justice dismissed the appeals. The ruling of the European Court is therefore final.
Our position on the CLH classification
The VdMi rejects the classification of titanium dioxide as carcinogenic, as it considers it neither scientifically justified nor appropriate. In our view, this classification was used to classify an individual substance on the basis of substance-unspecific, general particle effects. This is not within the meaning of the CLP Regulation. The classification of titanium dioxide can also be used as a precedent for many other substances. VdMi's detailed position on the classification can be found here.
To support users and consumers in understanding the classification, the VdMi is significantly involved in the Forum Titandioxid (German only), which provides information on the handling of products containing titanium dioxide.