While loose titanium dioxide presents a problem, titanium dioxide within sunscreen formulations presents a much safer option than conventional sunscreen chemicals like oxybenzone and octinoxate. However, titanium dioxide may become dangerous when it is nanoparticle size. Generally, nanoparticles can be 1000 times smaller than the width of a human hair. Despite nanoparticles becoming increasingly common across industries, they have not been properly assessed for human or environmental health effects, nor are they adequately regulated. Researchers don’t quite understand the impacts nanoparticles could have on human health and the environment. However, because of their infinitesimally small size, nanoparticles may be more chemically reactive and therefore more bioavailable, and may behave differently than larger particles of the same substance; these characteristics may lead to potential damage in the human body or ecosystem.

On the other hand, the U.S. Food and Drug Administration (FDA) in their Final Administrative Order on Sunscreen Drug Products posted in September 2021 still accepts titanium dioxide up to 25% in the list of Generally Recognized As Safe and Effective (GRASE) in the main document, without further clarification on what kind or size of particles [9]. However, on page 24 (Sunscreen containing nanomaterials) FDA clearly “distinguish nanomaterials from other forms of these ingredients'' (zinc oxide and titanium dioxide) and ask for comments on “any particular nanomaterials that you believe should not be permitted for use in OTC sunscreen products”. To the best of our knowledge, this Agency did not ban the use of nanoparticulate titanium dioxide in any form, even though it is mentioned on page 34 that the anatase form is the more photoactive one, due to the lack of evidence with real sunscreens OTC (over the counter) in vivo. Moreover, other regulations in Latin America (MERCOSUR agreement, 2006) do not state clearly their position on the use of nanoparticulate TiO₂NPs [10].

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