EU Proposed to Amend REACH to Restrict 2,4-Dinitrotoluene (2,4-DNT)
| Targeted audience | EU/EEA manufacturers, EU/EEA importers and their upstream providers |
| Products concerned | Articles |
| Key industries concerned with this insight | Furniture |
| Application date | 12 months after publication |
| Main content or requirements | On 15 September 2025, the EU proposed to amend REACH Annex XVII by adding a new entry to restrict 2,4-dinitrotoluene (2,4-DNT) in articles to be placed on the EU market. The 2,4-DNT content limit is 0.1% (1000 mg/kg). |
| Reference | https://eping.wto.org/en/Search/Index?documentSymbol=G%2FTBT%2FN%2FEU%2F1154 |
On 15 September 2025, the European Commission proposed a regulation to add a new entry to Annex XVII to the EU REACH Regulation (EC) No 1907/2006, which restricts 2,4-dinitrotoluene (2,4-DNT, CAS No. 121-14-2) in articles to be placed on the EU market. The amendment is scheduled to enter into force on the twentieth day following that of its publication in the Official Journal of the European Union (OJEU) and apply from 12 months after the entry into force of the amendment. The amendment is scheduled to be adopted in the fourth quarter of 2025.
Requirement
2,4-Dinitrotoluene (2,4-DNT) shall not be placed on the EU market, or used, as a substance in articles for professional users or the general public, in a concentration equal to or greater than 0.1% (1000 mg/kg).
Exemption
- The restriction does not apply to:
- Explosives, as defined in Article 2, point (1), of the EU Directive 2014/28/EU.
- Articles for military use.
- Ammunition for use, in accordance with EU Member States national law(s), by the police or other security forces.
- Toys within the scope of the proposed EU Toy Safety Regulation.
- Devices within the scope of the EU MDR Regulation (EU) 2017/745.
- Articles intended to come into contact with food, within the scope of the EU FCM Framework Regulation (EC) No 1935/2004.
- Articles placed on the EU market before the amendment applies.
The transition period for products for use, or used in certain components of motor vehicles is 36 months instead of 12 months.
2,4-Dinitrotoluene (2,4-DNT) is a chemical which were used in production of toluene diisocyanate (TDI) (which is used for the manufacture of flexible polyurethane foams), and as gelatinizing-plasticizing agent for the manufacture of explosives. The substance is classified as a Carc. 1B, Muta. 2 and Repr. 2 substance in the EU CLP Regulation (EC) No 1272/2008. As a result, the 2,4-DNT content limit in the mixtures placed on the EU market for supply to the general public is 0.1% (1000 mg/kg) according to the EU REACH Annex XVII Entry 28. The substance is also identified as an SVHC substance on 13 January 2010 and included into Annex XIV of REACH Regulation (EC) No 1907/2006 with a sunset date of 21 August 2015.
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