Titanium Dioxide

Titanium Dioxide is the INCI name for titanium dioxide, the white powder that adds opacity to a formula and absorbs some ultraviolet radiation. Regulation (EC) 1223/2009 permits two uses: colourant under Annex IV (reference 143) and UV filter under Annex VI (reference 27, and 27a for the nano form). The widely discussed 2022 European ban concerns use in food as additive E 171.

Behind this white powder are three distinct European developments, each with its own scope. Confusion arises when they are treated as one.

The food ban: additive E 171

Commission Regulation (EU) 2022/63 of 14 January 2022 amends Regulation (EC) No 1333/2008 on food additives. Recital 11 reports the conclusion of the European Food Safety Authority's opinion published on 6 May 2021: genotoxicity concerns could not be ruled out, so titanium dioxide (E 171) could no longer be considered safe as a food additive. The Regulation consequently removes its food authorisation. Foods produced under the previous rules could be placed on the market until 7 August 2022 and remain until their minimum durability date. E 171 remained provisionally authorised as a colourant in medicines.

The act's scope is in its title: food additives, and therefore ingestion.

The powder classification and the judgment that annulled it

Commission Delegated Regulation (EU) 2020/217 of 4 October 2019 introduced a harmonised classification into the CLP Regulation on chemical classification and labelling: titanium dioxide powder containing 1% or more particles with an aerodynamic diameter of 10 μm or less was classified as a category 2 carcinogen by inhalation. That entry concerned fine powder that could be breathed in.

That classification has been annulled. The General Court of the European Union partially annulled the Delegated Regulation in its judgment of 23 November 2022 in Joined Cases T-279/20, T-283/20 and T-288/20. France and the Commission appealed, and the Court of Justice dismissed the appeals on 1 August 2025 in Joined Cases C-71/23 P and C-82/23 P. Notice C/2025/6670, published in the Official Journal on 10 December 2025, states that titanium dioxide in that form is no longer subject to harmonised classification as a category 2 carcinogen by inhalation, because the entry with index number 022-006-00-2 was annulled.

Colourant, UV filter and the inhalation entry

Regulation (EC) 1223/2009 lists titanium dioxide among both colourants and UV filters, with cross-references. Annex IV, the permitted colourant list, includes it as entry 143, Colour Index 77891, referring UV-filter use to Annex VI, entry 27. Annex VI, the permitted UV-filter list, gives entry 27 a maximum concentration of 25% and refers colourant use back to Annex IV, entry 143. Entry 27a covers the nano form, also at 25%, permitted only with specified characteristics: purity ≥ 99%, rutile form, mean particle size ≥ 30 nm and a defined list of permitted coatings, including dimethicone. When both forms are combined, their total must not exceed the single 25% limit.

For inhalation, the Cosmetics Regulation has its own entry, Annex III No 321, introduced by Regulation (EU) 2021/850. It concerns the same powder described above and sets product-type limits: 25% in loose facial powders; 1.4% for consumers and 1.1% for professional use in aerosol sprays for hair, beards and moustaches, in both cases only in pigmentary form. For other products, it excludes applications that may expose the end user's lungs by inhalation. That entry remains in the consolidated text dated 1 May 2026.

The four functions recorded in CosIng

The European CosIng database assigns four functions: colourant, opacifying, UV absorber and UV filter. The first two describe a white pigment that reduces transparency. The last is one of the categories the Regulation defines explicitly: Article 2 describes UV filters as substances intended exclusively or mainly to protect skin against certain UV radiation. CosIng lists no skin-conditioning function for this ingredient.

Where to find it on the label

The label name changes with the role. As a UV filter, it appears in full as Titanium Dioxide. As a colourant, it is identified as CI 77891, using the Colour Index nomenclature referenced by Article 19. The nano form carries (nano) in brackets after the name, as required for nanomaterials.

The same article allows colourants, other than those intended for colouring hair, to be listed in any order after other ingredients. For make-up sold in several shades, it also allows all colourants in the range to be listed with 'may contain' or '+/-': that line then covers the whole range.

List order is explained in how to read an INCI list. Read the complete list with the INCI analyser.

Sources: CosIng, European Commission. Regulation (EC) No 1223/2009, consolidated text as of 1 May 2026: Articles 2 and 19; Annex III No 321, Annex IV No 143, Annex VI Nos 27 and 27a. Regulation (EU) 2022/63. Delegated Regulation (EU) 2020/217. Notice C/2025/6670, OJ C series of 10 December 2025.