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Titanium Dioxide: Current Legal Status Following the CJEU Ruling 2025

CJEU overturns CLP classification of titanium dioxide. The labelling requirement for powders and mixtures containing TiO₂, including masterbatches, with the warning labels EUH 211 and EUH 212 has therefore been revoked. All details on the new legal situation can be found here.

Status: September 2025

The white pigment titanium dioxide (TiO₂) is one of the most widely used pigments in the plastics, coatings and paints industries. In recent years, it has been at the centre of regulatory debate after being classified in 2021, in powder form, as “suspected of causing Cancer by inhalation” (Category 2) under the Classification, Labelling and Packaging (CLP) Regulation (EC) No. 1272/2008. This classification brought additional labelling obligations for TiO₂-containing powders and mixtures.

CJEU overturns CLP classification of titanium dioxide

On 1 August 2025, the Court of Justice of the European Union (CJEU) definitively annulled the CLP classification of titanium dioxide.
This confirmed the 2022 judgment of the General Court and dismissed the appeals lodged by the European Commission and France.

Key points of the ruling:

  • The classification was based on an inhalation study on rats that was over 30 years old and whose conditions were not realistic for occupational safety.    
     
  • The classification of TiO₂ was limited to powders containing more than 1% titanium dioxide particles with an aerodynamic diameter of 10 micrometres or less. Measurements showed that most TiO₂ powders and pigment preparations do not fall under the classification.
     
  • The Risk Assessment Committee (RAC) had not taken all relevant scientific evidence into account.
     
  • CLP criteria require proof of an intrinsic carcinogenic property – which, in the Court’s view, was not established in this case.

Implications for labelling and the CLP Regulation

•    The hazard statements EUH 211 and EUH 212 for TiO₂-containing mixtures are no longer required.

•    The European Commission must amend the CLP Regulation accordingly.

•    Manufacturers and processors will no longer have to label TiO₂-containing products as carcinogenic on the basis of the annulled classification.

Impact on Lifocolor products

Our TiO₂-containing masterbatches have always been formulated so that the pigment is firmly bound within the polymer matrix and is not present as inhalable dust. The previous labelling requirement now no longer applies. Our high occupational safety standards – including modern extraction systems, closed handling processes and personal protective equipment – will, of course, remain in place.

Distinction from other regulations

The CJEU ruling relates solely to the chemical classification under the CLP Regulation. It does not affect the ban on titanium dioxide as the food additive E171, in force since January 2022, nor any potential regulations in other sectors such as cosmetics or pharmaceuticals.

Conclusion: The annulment of the CLP classification removes a significant regulatory hurdle for the use of titanium dioxide in industrial applications. For our customers, this means greater legal certainty, reduced labelling requirements and the continued assurance of the highest safety standards in processing.
 

Former Articles:

France and European Commission appeal against titanium dioxide judgement (2023)
Latest news on titanium dioxide (2022)