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On April 20, 2026, the European Commission officially adopted and published Commission Regulation (EU) 2026/859. The new regulation introduces Entry 83 under REACH Restriction List (Annex XVII to Regulation (EC) No 1907/2006), specifically targeting 2,4-dinitrotoluene (2,4-DNT) in articles, effectively closing a long-standing regulatory loophole for imported goods.
The regulation will enter into force 20 days after its publication in the Official Journal of the European Union, with most restrictions becoming applicable from May 10, 2027.
Regulatory Background
2,4-DNT is classified as a Category 1B carcinogen. As a non-threshold carcinogen, any level of exposure is considered to pose a potential health risk, making it impossible to establish a safe Derived No-Effect Level (DNEL). While the substance was already included in the REACH Authorization List (Annex XIV), the authorization requirement only applied to EU-based manufacturers.
Previously, this allowed articles manufactured outside the EU—such as automotive safety systems, plastic products, and consumer durables—to be imported even if they contained 2,4-DNT. The new restriction ensures that imported articles meet the same stringent safety standards as those produced within the European Union.
Key Restriction Requirements
According to the new Entry 83 in Annex XVII, the following mandates will apply:
Requirement | Details |
|---|---|
General Prohibition | Shall not be placed on the market or used in articles in a concentration equal to or greater than 0.1% by weight for professional users or the general public. |
Effective Date | May 10, 2027 (General application). |
Automotive Exception | For the following applications in motor vehicles as defined in Article 3, point(16) of Regulation (EU) 2018/858 the restriction applies from May 11, 2029:
|
The regulation provides specific exemptions for certain categories of products already covered by other specialized EU legislation:
Explosives as defined in Directive 2014/28/EU.
Military equipment and ammunition for security forces.
Toys falling under the scope of Regulation (EU) 2025/2509.
Medical devices within the scope of Regulation (EU) 2017/745.
Food contact materials under Regulation (EC) No 1935/2004.
Notably, pyrotechnic articles and ammunition (unless for military/police use) are explicitly not exempt from this new restriction.
Impact on Global Supply Chains
Since EU production of 2,4-DNT has largely ceased, the primary impact will fall on non-EU manufacturers and importers. The automotive, electronics, and plastics industries are expected to be the most affected sectors.
Companies must act swiftly to audit their supply chains. With a 12-month general transition period—and 36 months for the automotive sector—manufacturers need to prioritize the identification of alternatives and ensure compliance with the 0.1% threshold to avoid market disruptions or costly recalls."
Click here for more information on the official text.
