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EU REACH Appendix XVII officially adds restriction clause for 2,4-dinitrotoluene


Time:

2026-04-21

The EU REACH Regulation Annex XVII has added a restriction clause on 2,4-dinitrotoluene in Article 83. 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 April 20, 2026, the European Union published a revised regulation (EU) 2026/859 to the REACH Regulation (EC) No 1907/2006 in its official gazette, adding a restriction clause on 2,4-dinitrotoluene in Annex XVII of the REACH Regulation. 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. This clause will come into effect on the 20th day after it is published in the official EU gazette.

 

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Add restriction clause

 

 

Substance Name

Constraints

2,4-dinitrotoluene 

 

CAS No:121-14-2

 

EC No:204-450-0

Starting from May 10, 2027, substances intended for professional use or in general public goods shall not be placed on the market or used when their concentration is equal to or greater than 0.1% by weight.

 

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

 

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) 2025/2509 of the European Parliament and of 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.

 

For the purpose of paragraph 3 (a), the following items are not covered:

(a) Fireworks products as defined in Article 3 (1) of Directive 2013/29/EU;

(b) Ammunition.

 

5. The first paragraph shall apply from May 11, 2029, to the placing on the market and use of 1,4-dinitrotoluene in the following applications, where the product is placed on the market for use or used in motor vehicles as defined in point 16 of Article 3 of Regulation (EU) 2018/858 of the European Parliament and of the Council:

(a) Micro gas generator for seat belt tensioner and hood actuator;

(b) Spare parts.

 

6. As an exception, paragraph 1 does not apply to motor vehicles in paragraph 5 that meet the following conditions:

(a) Launch on the market between May 11, 2027 and May 11, 2029; and

(b) Only in the application of paragraph 5 (a) or (b) does it contain 2,4-dinitrotoluene.

 

7. Paragraph 1 does not apply to articles containing 2,4-dinitrotoluene that have been placed on the EU market before May 11, 2027.
 

 

 

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.

 

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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.

 

 

 

 

Compliance recommendations

 

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 recommends that companies conduct early investigations into their supply chain to respond to regulatory changes and ensure that their products are legal and compliant. As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CPSC, and has obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. The laboratory is strictly built and managed according to standards, equipped with advanced instruments and equipment, and has a skilled professional technical team with rich industry service experience and strong testing technology capabilities. It is proficient in various regulatory standards. Jiayu Testing has rich project experience in the field of REACH hazardous substance control, providing customized raw material and whole machine restricted substance testing solutions for customers, assisting enterprises in actively responding to regulatory requirements, helping enterprises achieve hazardous substance risk control, and effectively improving product compliance. Welcome to contact us400-9269-886 !

 

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