Services: Electrical testing and certification, environmental or chemical testing

language
- English
- 中文

400-9269-886

NEWS CENTER

Industry News

Company News

Knowledge

EU REACH Annex XVII plans to add control requirements for 2,4-dinitrotoluene

Time：

2025-09-18

The European Commission plans to revise Appendix XVII of (EC) No 1907/2006 by adding a restriction clause for 2,4-dinitrotoluene. The purpose is to restrict the sale and use of products in the market for professional users or the public, which contain 2,4-dinitrotoluene at a concentration equal to or greater than 0.1% by weight.

On September 15, 2025, the World Trade Organization (WTO) issued a technical barrier to trade notification G/TBT/N/EU/1154 submitted by the European Union, which stated that the European Commission planned to revise Appendix XVII of (EC) No 1907/2006 to add a restriction clause for 2,4-dinitrotoluene. The purpose is to restrict the sale and use of products in the market for professional users or the public, which contain 2,4-dinitrotoluene at a concentration equal to or greater than 0.1% by weight.

The draft of the notice will undergo a 60 day public consultation, with a recommended adoption date of the fourth quarter of 2025, and is expected to take effect on the 20th day after its publication in the EU Official Gazette.

Restricted content

Substance name

Constraints

2,4-dinitrotoluene

CAS No：121-14-2

EC No：204-450-0

1. After [insert date: 12 months minus 1 day after the effective date of this regulation], substances used for professional or general public goods with a concentration equal to or greater than 0.1% by weight shall not be put on the market or used.

2. For the purpose of this provision, "professional user" shall refer to any worker or individual operator who operates outside of industrial premises.

3.Article 1 does not apply to:
(a) Explosives as defined in Article 2 (1) of Directive 2014/28/EU;
(b) Military supplies;
(c) Ammunition used by police or other security forces in accordance with national laws;
(d) Toys within the scope of Regulation (EU) No XX/XXX on toy safety and the repeal of Directive 2009/48/EC of the European Parliament and the Council;
(e) Devices within the scope of EU 2017/745;
(f) Articles that come into contact with food within the scope of Regulation (EC) No 1935/2004.

4.For the purposes of paragraph 3 (a), the following substances shall not be considered explosives
(a) Fireworks products as defined in Article 3 (1) of Directive 2013/29/EU;
(b) Ammunition.

5. According to the exception in paragraph 1, this paragraph shall come into effect from [insert date: 36 months from the date of entry into force of this Regulation] regarding the placing on the market of 2,4-dinitrotoluene and its use for the following purposes, where they are placed on the market for use, or for motor vehicles as defined in Article 3 of paragraph (16), in accordance with Regulation (EU) 2018/858 of the European Parliament and of the Council
(a) Micro gas generators for seat belt pre tensioners and hood actuators;
(b) Spare parts.

6. As an exception, paragraph 1 does not apply to motor vehicles referred to in paragraph 5
(a) Place on the market between [insert date 12 months after the effective date of this regulation] and [insert date 36 months after the effective date of this regulation]; and
(b) Only in the application of paragraph 5 (a) or (b) does it contain 2,4-dinitrotoluene.

7. The first paragraph does not apply to items containing 2,4-dinitrotoluene placed on the market of this alliance, which were placed before [insert the date 12 months after the effective date of this regulation].

Introduction to 2,4-dinitrotoluene

2,4-dinitrotoluene, CAS number 121-14-2, EC number 204-450-0, is classified as a Group 1B carcinogen in accordance with Regulation EC 1272/2008 of the European Parliament and the Council. In addition, 2,4-DNT has been identified as a substance of high concern, meeting the conditions of Article 57 (a) of Regulation EC 1907/2006 Reach, and has been added to Appendix XIV of that Regulation.

According to the archives, a database search conducted on substances of concern in products under Directive 2008/98/EC of the European Parliament and Council shows that 2,4-DNT is present in certain items within the alliance, including electronic devices, ceramic products, and vehicles. During the consultation process regarding Appendix XV archives, the use of 2,4-DNT in seat belt pre tensioners and ammunition was confirmed.

In addition, the institution believes that the exposure potential of 2,4-DNT as a plasticizer for plastic products and as an additive for any plastic material can be considered high. Based on its physical and chemical properties, it is assumed that 2,4-DNT is easily diffused in the plastic matrix and migrates from the surface to the contact medium (water, saliva, or skin). Therefore, exposure to 2,4-DNT when using plastic sample bottles cannot be ruled out.

Introduction to REACH Appendix XVII

EU REACH Appendix XVII - Restrictions on the manufacture, placing on the market, and use of certain hazardous substances, mixtures, and articles.

REACH Appendix XVII (Restriction) is a tool used by the European Union to protect public health and the environment from unacceptable risks posed by chemicals. According to Article 67.1 of the REACH regulation, when a chemical substance is included in Annex XVII (Restriction) of the EU REACH for restriction control, products involving the substance must comply with its prescribed restriction conditions before they can be produced, used, and placed on the market within the EU. The EU's restriction and control of chemicals is a continuous process, and REACH Appendix XVII has undergone dozens of updates and revisions since the REACH regulation came into effect. The authorities have also been evaluating the addition of more restriction requirements. At the same time, it is particularly important to note that there are significant differences in the control of REACH Appendix XVII and SVHC, mainly reflected in the following two aspects:

1. Scope of Control: The control requirements for SVHC apply to products manufactured within the EU or exported to the EU, while REACH Appendix XVII specifies the scope of application for different provisions of the product.

2. Control requirements: When the SVHC content in a product exceeds the threshold, the product can still enter the EU market as long as the relevant enterprises fulfill their responsibilities and obligations to notify the authorities or transmit supply chain information. For products involving restricted substances in REACH Appendix XVII, they must comply with their prescribed restrictions (such as limit requirements for the substance) before they can be produced, used, and placed on the market within the European Union.

Jiayu Reminder

With the continuous updating of REACH controlled substances in the European Union, enterprises are facing more and more control requirements. Jiayu Testing recommends that companies conduct early investigations into their supply chain to respond to regulatory changes and ensure that their products are legal and compliant.

Jiayu Testing Chemical Laboratory can provide one-stop testing and certification services such as RoHS, REACH, SVHC, FCM, etc., to help you efficiently respond to regulatory updates. Welcome to contact us at 400-9269-886!