Introduction

The titanium dioxide classification EU has sparked intense regulatory debates in recent years. Discussions have focused on the potential carcinogenicity of titanium dioxide and its impact on the chemical and manufacturing industries.

EU Classification and Regulatory Background

In 2020, the European Commission assigned titanium dioxide in powder form—containing 1% or more of particles with an aerodynamic diameter ≤10 μm—to Hazard Class Carcinogen Cat 2 (H351) when inhaled.

Mixtures containing this substance also required additional EUH statements, depending on whether the product was liquid or solid.

Liquid vs Solid Mixtures: EUH Statements

• Liquid mixtures with 1% or more of titanium dioxide particles ≤10 μm must display:
  EUH211 – “Warning! Hazardous respirable droplets may form when sprayed. Do not breathe spray or mist.”
• Solid mixtures with 1% or more of titanium dioxide must display:
  EUH212 – “Warning! Hazardous respirable dust may form when used. Do not breathe dust.”

Legal Challenges and Court Decisions

This classification significantly impacted the industry and triggered a legal challenge. The EU General Court annulled the classification in November 2022. France, which requested the original classification, appealed. The Court of Justice (ECJ) upheld the annulment in August 2025.

After the ruling, the harmonized classification for titanium dioxide was removed from the CL Inventory. The EUH statements remain in the CLP regulations because they have not yet been updated.

UK Approach Post-Brexit

The UK followed a pragmatic approach after Brexit. Titanium dioxide was initially copied into UK legislation, but legal oversights delayed the 14th and 15th ATPs to CLP. When the UK reinstated substances from these ATPs in June 2024, authorities kept titanium dioxide off the list. Since then, it is considered Not Classified in the UK, unless additional impurities indicate otherwise.

Conclusion

The titanium dioxide classification EU remains a key example of regulatory complexity. Industries must carefully follow both EU and UK regulations to ensure compliance.

For more insights on recent changes to EU classification and labeling, see our article New EU Chemicals Package Simplifies CLP Rules. For official sources, consult the European Commission Regulation (EU).