I have recently received a very interesting question related to the implementation of 14th ATP, specifically labelling of mixtures containing titanium dioxide.
The question was as follows:
"We use titanium dioxide as a raw material for our products; lacquer powders and masterbatches.
We will add the sentence EUH212 to the labels. We have a lot of products in stock that are not yet labeled. Do we also need to label these products with this sentence, despite the fact they were manufactured before October 1, 2021?"
My answer is yes, even mixtures manufactured before 1 October 2021, which will continue to be placed on the market must be labeled with this sentence. That is if the mixture state, content and particle size of titanium dioxide meet the labelling criteria.
I believe the answer will come in handy for you. If you also have some particular question regarding the 14th ATP, we may help you.
Drop me an e-mail at firstname.lastname@example.org and present the challenges you are facing in managing the requirements of chemical legislation in your respective area of expertise.