Tronox REACH Implementation Strategy

Materials that Tronox produces for the European market will be compliant with the REACH (Registration, Evaluation and Authorization of Chemicals) legislation. Some intended uses will include coatings, plastics and paper.

Understanding and Awareness

Tronox has an active REACH group addressing all relevant aspects of the REACH legislation. The REACH Regulation was adopted on 18 December 2006 by the Council of Environment Ministers following the vote in second reading of the European Parliament on 13 December 2006. REACH entered into force on 1 June 2007.

Tronox stays informed regarding the REACH implementation process via the European Chemical Industry Association (CEFIC), the Titanium Dioxide Manufacturers Association (TDMA), the trade press and contacts within industry and the EC.

The company has been preparing for REACH by auditing substances in product portfolios, identifying downstream exposure scenarios, defining supported uses, analyzing cost and timing, and developing strategies with suppliers, customers and industry groups.

This being said, it should be recognized that titanium dioxide is an extremely benign material. The exposure scenarios we have nevertheless considered comprehensively, in regard to human routes of exposure (oral, dermal, inhalation), environmental media exposure (water, air, soil/solid waste) and their exposure patterns (short term and long term). These exposure scenarios in turn differentiate between three main use categories (industrial, professional and consumer). Due to mainly industrial downstream use the focus for titanium dioxide will be on the industrial use category within each of the exposure scenarios.

Implementation

Tronox will fulfill REACH requirements using in-house resources, supported by membership in appropriate trade organizations, through participation in selected consortia and the use of outside consultants and experts.

Tronox plans to follow the registration schedule established by the legislation which is based on annual tons of product manufactured or imported. The following timeline will be observed:

• June 2007 – Entry into force of the REACH-Regulation for all manufacturers and importers of chemicals in or into the European Union
• June 2008 – Start of the preregistration at the European Chemicals Agency in Helsinki
• December 2010 – registration completed for all “phase-in-substances”, that have been preregistered before December 2008 and are marketed in a volume above 1000 tpa.

On Aug. 29, 2008, Tronox had finished the pre-registration of TiO2 manufactured at its Botlek, Netherlands, and Uerdingen, Germany, sites.  Tronox Pigments (Holland) BV will serve as the Only Representative for Imports from Non-EU operations. 

Communication

Tronox’s principal communication tool for REACH with customers and downstream users will be the MSDS (Material Safety Data Sheet) according to EU guidelines. Communication efforts will include appropriate risk management measures, recommendations for specific uses and other relative safety concerns.

Potential business impact

Tronox anticipates that REACH will have limited impact on the company’s investment in the EU, the R&D expenditures or the product mix offered in the European market. Titanium dioxide is chemically inert at conditions encountered in downstream applications. TiO2 also provides beauty and protection to a wide spectrum of consumers, commercial and industrial products.

Tronox remains committed to supplying this product in a safe and environmentally responsible manner.

For more information contact:

Klaus Koehler: klaus.koehler@tronox.com
John Howard: john.howard@tronox.com