Changes to the rules for titanium dioxide
There have been significant changes to the Danish regulation of titanium dioxide (TiO₂), which may have implications for companies that handle or use the substance in production, formulation or finished products.
1. Titanium dioxide has been removed from the CMR regulation
BEK no. 1347 of 24/11/2025 Executive Order on measures to prevent the risk of working with carcinogenic, mutagenic or reproductively toxic substances and materials has been updated, and titanium dioxide is no longer listed as a carcinogenic substance in the annexes.
That means:
- The special requirements for carcinogenic substances, such as stricter substitution requirements, registration of exposed employees or special requirements for workplace instructions, no longer apply.
- However, companies must still carry out a chemical APV and ensure that exposure is kept as low as possible in accordance with the general rules for dusty substances.
2. Titanium dioxide still has an administrative limit value, but the note K has been removed.
In BEK no. 1356 of 19/11/2025 Executive Order on limit values for substances and materials (chemical agents) in the working environment, Titanium dioxide is still listed with an administrative limit value, but the K classification (carcinogenic) has been removed.
That means:
- The limit value for inhalable and/or respirable titanium dioxide dust continues to apply.
- The removal of the note K means that the substance is no longer classified as carcinogenic in a working environment context in Denmark.
- Documentation requirements are eased, but companies must continue to monitor dust exposure and ensure appropriate protective equipment, extraction and cleaning procedures.
3. What do the changes mean in practice for companies?
- Reassess chemical APV for raw materials and products with TiO₂.
4. Why the changes?
The changes follow a comprehensive revision of the classification basis for titanium dioxide and reflectors:
- New EU correction and changed assessment of the evidence
- National adaptation of Danish working environment regulations