G/TBT/W/678  
 
23 July 2019  
(19-4889) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
EUROPEAN UNION — REGULATION (EC) NO 1272 /2008 (CLP REGULATIO N) 
STATEMENT BY THE PHILIPPINES  TO THE COMMITTEE ON  TECHNICAL BARRIERS TO TRADE  
20 AND 21 JUNE 2019  
The following communication, dated 23 July 2019, is being circulated at the request of the delegation 
of the Philippines . 
 
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1.  Thank you to the United States and Russia for including this item in the agenda.  Allow me to 
read out the position of the chemical industry association of the Philippines which we in government 
fully endorse.  
2.  The Philippines is of the view that the proposed regulation has serious implications on the trade 
of titanium dioxide which is used extensively as raw material in the manufacture of paint products, 
cosmetics, pharmaceuticals and even food.  
3.  The EU Commission 's classification, labelling and packaging (CLP) regulations may create panic, 
fear and paranoia among consumers as well as potential disastrous financial loss to companies 
engaged in the manufactur e of products containing titanium dioxide in various levels of composition.  
4.  Specifically, we believe the proposed classification and required labelling has the potential to 
result in a significant impact on international trade. This impact is expected desp ite serious and 
ongoing concerns by global experts on the underlying rationale being used to advance this action:  
a. The rodent toxicity studies used to support the classification do not support a finding that 
TiO2 should be considered a human  carcinogen.  
b. The scope of the proposed classification is excessive. The classification would apply to TiO2 
regardless of the physical form. Even though the rodent toxicity studies were performed 
with TiO2 as a respirable dust, the proposed classification would still apply when TiO2 is 
embedded in a liquid or solid matrix as in paints and coatings or present in any waste.  
c. An alternative mechanism to minimize any hazard exposure to TiO2 dust is through the 
use of an appropriate occupational exposure limit.  
d. The social and economic impact of such a classification is enormous, for international trade 
and within the EU, compared to the negligible (or non -existent) benefit for human health.  
5.  The EU would be advancin g an unfounded interpretation of the UN Globally Harmonised System 
of Classification and Labelling of Chemicals (GHS) under its Classification, Labelling and Packaging 
(CLP) regulation. This interpretation has not been advanced by any other national regula tory body 
that has been undertaken the same risk management, and the unwarranted hazard and 
precautionary labelling it would require in the EU markets for widely used consumer products like 
paint and coatings, is not required anywhere in the world. For the se reasons, it is critical for the EU 
to provide the rationale as to why such a significant, unique and highly disruptive interpretation has 
been made.  G/TBT/W/678  
 
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  6.  The economic cost of the trade disruptions is substantial, if not staggering, and wholly 
unnecessary.  
7.  We therefore call on the EU to indefinitely defer adoption of the proposed regulation when the 
REACH Committee meets on 1 July.  
 
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