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The European Union has published Regulation (EU) 2026/859, amending Annex XVII of the REACH Regulation and introducing a new restriction on 2,4 dinitrotoluene (2,4 DNT). The measure sets concentration limits in articles, defines exemptions and establishes an application timetable that companies will need to take into account.

Regulation introducing the restriction

The restriction on 2,4 DNT is introduced through Reglamento (UE) 2026/859, published in the Official Journal of the European Union in April 2026, which amends Annex XVII of Regulation (EC) No 1907/2006 (REACH). Through this regulation, the new entry 83 is introduced, with the aim of limiting the use of this substance due to the health risks associated with its classification as carcinogenic. 2,4 DNT is mainly used as an intermediate in the manufacture of organic dyes and pigments.

Scope, concentration limit and exemptions

Regulation (EU) 2026/859 sets a maximum concentration limit of 0.1 % by weight of 2,4 dinitrotoluene (2,4 DNT) in the articles concerned. The restriction applies to articles intended for professional use, both by employed workers and self employed persons, including those that may be accessible to the general public. However, the new entry 83 of Annex XVII of REACH does not introduce a total ban, as it provides for exemptions for certain products and uses, such as explosives and pyrotechnic articles, articles intended for military uses, toys regulated by their specific legislation, medical devices and food contact materials subject to sector specific legislation.

Dates of application and transitional periods

The restriction will apply generally from 10 May 2027, from which date articles exceeding the established limit may no longer be placed on the market in the European Union.

However, for certain motor vehicle applications, namely micro gas generators for seat belt pretensioners, bonnet actuators and spare parts, the application of the restriction is postponed until 11 May 2029. In addition, motor vehicles placed on the market between 11 May 2027 and 11 May 2029 that contain 2,4 DNT only in those applications may continue to be used until the end of their service life. Finally, the restriction does not apply to articles placed on the market in the European Union before 11 May 2027.

At Siam we closely monitor the publication of regulations such as Regulation (EU) 2026/859, which amends Annex XVII of REACH. This type of regulatory update requires companies operating in the European Union to review the composition of their articles, assess the applicability of exemptions and adapt their compliance timelines in order to ensure continued access to the European market and minimise regulatory risks.

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