New Legislation Restrictions for Diisocyanates & Titanium Dioxide come into force

New REACH labelling and training regulations to be introduced, with the first labelling deadline implemented on 24th February 2022.

On 4th August 2020, the EU implemented a new regulation restricting the use of diisocyanates which impacts professional and industrial users. 

The new regulation means that diisocyanates should not be used on their own, or as a constituent in other substances or in mixtures, in concentrations above 0.1 % by weight, unless training has first been provided for industrial and professional users. Placing on the market will be restricted earlier — as of 24th February 2022.

Adhesives and sealants are to remain widely available and the regulation does not impact the DIY market.

What are Diisocyanates?

Diisocyanates are used in coatings, adhesives and sealants and are a family of chemical building blocks mainly used to make polyurethane products.

Diisocyanates are classified as potential human carcinogens and known skin irritants and sensitisers, eye irritants and respiratory sensitisers, which is why a new regulation to enhance the safety measures for industrial and professional users is being introduced.

Labelling & SDS Obligations

Products sold within the EU and UK, with a total monomeric Diisocyanate concentration greater than 0.1%, intended for professional or industrial use, must have the statement below on the product container label by 24th February 2022:

‘As from 24th August 2023, adequate training is required before industrial or professional use of this product’.

This sentence should be visibly distinct from the rest of the label information, and should appear in the Other Information section of the Safety Data Sheet.

Mandatory Training Requirements

Professional and industrial users of diisocyanates will be responsible for seeing to the completion of training for themselves and their employees. The training is mandatory, and may be given online.  Training and certification, which involves passing an examination, must be completed by 24 August 2023. Records of the training given to employees must be maintained by employers. Every five years, renewal of the training will be necessary.  There are three levels of training corresponding to the different levels of risk. Each individual’s required training content, then, will depend upon the level of risk to which they are exposed.  Suppliers are responsible only for informing users of the need for the training, they are not responsible for training workers.

EU titanium dioxide ban in force – New guide available on classifying and labelling

The EU harmonised classification of certain forms of titanium dioxide (TiO₂) as a suspected carcinogen, by inhalation, entered into force on 1^st October 2021, bringing changes to classification and labelling.

What is Titanium Dioxide?

Titanium dioxide (TiO2 ) is a naturally occurring mineral used as a bright white pigment in the paints & coating industries, food and cosmetics industries and other industrial sectors.

ECHA’s guide on the classification and labelling of TiO₂

The European Chemicals Agency (ECHA) has published its Guide on the Classification & Labelling of Titanium Dioxide in order to help companies and authorities understand how mixtures containing titanium dioxide need to be classified and labelled following its classification as carcinogenic if inhaled.

The substance TiO2 must be classified as carcinogen if inhaled (Carc. 2, H351 (inhalation) when supplied on its own or in mixtures, where the substance or mixture contains 1% or more of TiO2 particles with an aerodynamic diameter ≤10 μm.

The label on the packaging of liquid mixtures containing 1% or more of titanium dioxide particles with aerodynamic diameter equal to or below 10 μm shall bear the following statement: EUH211: ‘Warning! Hazardous respirable droplets may be formed when sprayed. Do not breathe spray or mist.’