EU REACH New Restriction on 2,4-DNT

Regulation (EU) 2026/859 Official Compliance Guide

On April 21, 2026, the European Commission officially issued Regulation (EU) 2026/859, which formally revises Annex XVII of EU REACH Regulation (EC) No 1907/2006.A new Entry 83 has been added to impose strict concentration control on 2,4-Dinitrotoluene (2,4-DNT, CAS: 121-14-2) in all articles placed on the EU market.

Core Warning:Starting from May 11, 2027, articles with 2,4-DNT ≥ 0.1% (1000mg/kg) are prohibited from being placed on the market, sold and used in EU & EEA regions.

e31d30a1-af0c-4549-a7aa-0c390c59fdd2

1. Key Regulatory Timeline

  1. Official Publication Date: 21 April 2026 (Published in OJ EU)
  2. Regulation Entry into Force: 11 May 2026
  3. Mandatory Compliance for General Products: 11 May 2027 (12-month transition period)
  4. Extended Transition for Automotive Parts: 11 May 2029 (36-month transition period)

Important Note:

All goods and articles legally placed on the EU market before 11 May 2027 are exempted from this new restriction.

2. Core Control Requirements

The newly added restriction clause of REACH Annex XVII clearly stipulates:From 11 May 2027, any articles for professional users and the general public circulating in EU/EEA,if the concentration of 2,4-DNT reaches or exceeds 0.1% by weight, shall be forbidden for market placement, sales and application.

Full supply chain accountability:EU/EEA manufacturers, EU importers and upstream raw material suppliers shall all bear legal compliance responsibilities.

REACH Annex XVII Entry 83 Official Terms

sheet1_Sheet1

3. Introduction to 2,4-DNT & Regulatory Background

2,4-Dinitrotoluene (2,4-DNT) is a high-risk aromatic nitro compound, classified as a highly hazardous chemical with carcinogenic, mutagenic and reproductive toxic properties.It is also a critical chemical intermediate widely used in industrial manufacturing.

3.1 Hazard Classification

  • CLP Regulation: Category 1B Carcinogen, Category 2 Mutagen, Category 2 Reproductive Toxicant
  • IARC: Group 2B, probable human carcinogen
  • Acute hazard: headache, nausea, methemoglobinemia, impaired blood oxygen transport
  • Chronic hazard: long-term exposure causes irreversible damage to liver, kidney, nervous system and blood system
  • Environmental hazard: difficult to degrade, easy to accumulate in soil and water, highly toxic to aquatic organisms
  • Safety risk: easy to explode under high temperature, friction and impact

3.2 Wide Application Scenarios

  1. PU Industry: Core raw material for TDI, widely used in sofa, mattress, cushion and polyurethane foam products
  2. Automotive Industry: Airbag, seatbelt pretensioner, micro gas generator for hood actuators
  3. Industrial Materials: Dyes, rubber additives, electronic components, ceramics and refractory materials
  4. Special Fields: Military supplies, ammunition propellants, plasticizers for industrial explosives

4. Official Exemption List

The 2,4-DNT restriction is not applicable to the following product categories:

  1. Explosives defined by Directive 2014/28/EU (excluding pyrotechnics and ammunition)
  2. Exclusive military articles
  3. Ammunition used by police and security forces in accordance with national laws
  4. Toys covered by Regulation (EU) 2025/2509
  5. Medical devices regulated by Regulation (EU) 2017/745
  6. Food contact materials under Regulation (EC) No 1935/2004

5. Special Policy for Automotive Industry

To reduce the impact on the automotive supply chain, the EU has granted a 36-month extended transition period:

  • Final compliance deadline: 11 May 2029

Applicable Scope

  1. Micro gas generators for seatbelt pretensioners and hood actuators
  2. Aftermarket spare parts for the above automotive safety components

Restrictions for Enjoying Extended Period

  1. Vehicles placed on the EU market from 11 May 2027 to 11 May 2029
  2. 2,4-DNT is only limited to the above specified automotive parts

6. Compliance Suggestions for EU Export Enterprises

Step 1: Full Supply Chain Risk Investigation

Cooperate with upstream suppliers to screen high-risk raw materials such as PU foam, plastic products, dyes and electronic parts.Complete targeted testing to ensure 2,4-DNT content ＜ 0.1%.

Step 2: Priority Rectification for High-risk Industries

Focus on furniture & home textiles, automotive interior parts, daily plastic products, electronic manufacturing and other industries to complete product compliance assessment in advance.

Step 3: Complete Compliance Document Upgrading

Update technical documents, SDS safety data sheets, EU declaration of conformity, and retain test reports & supplier compliance declarations to cope with market supervision and customs inspection.

Step 4: Distinguish Different Transition Deadlines

  • General consumer goods & industrial products: fully compliant before 11 May 2027
  • Special automotive safety components: formulate long-term rectification plan based on the 2029 deadline

Step 5: Sort Out Stock Products

Establish inventory ledgers for stock goods launched in the EU before 11 May 2027, and retain supporting documents to enjoy the stock exemption policy.

7. Conclusion

Regulation (EU) 2026/859 is another key upgrade of EU REACH regulation, expanding hazardous substance control from mixtures to full-article management.With strong toxic and explosive risks, 2,4-DNT has become the key restricted substance in the new round of EU environmental and health regulation.

At present, there is only more than one year left for the general transition period.Export enterprises engaged in furniture, polyurethane materials, auto parts, electronic products and consumer goods must complete raw material screening, product testing and compliance rectification as soon as possible, to avoid risks such as customs detention, market recall, financial penalties and export business suspension.