REACH Regulation (EU) 2025/1731: 16 New CMR Substances Added

News Brief

Regulation (EU) 2025/1731 formally amended Articles 28, 29, and 30 of Annex XVII to Regulation (EC) No 1907/2006, in order to align REACH restrictions with the latest changes in the EU CLP Regulation.

The newly added substances are classified as CMR category 1B under the CLP framework. Under REACH Annex XVII Entries 28, 29 and 30, substances classified as carcinogens, germ cell mutagens or reproductive toxicants category 1A or 1B, and mixtures containing them above specified concentration limits, are restricted for supply to the general public.

Main Amendments under Regulation (EU) 2025/1731

The amendment updates Appendices 2, 4 and 6 of Annex XVII to include newly classified CMR substances and updates Appendix 11 to introduce a specific derogation for cumene in certain aviation fuels. The change reflects the harmonized classification and labeling updates introduced by Commission Delegated Regulation (EU) 2024/197.

16 New CMR Substances Added to REACH Annex XVII

The amendment adds new entries to Appendices 2, 4 and 6 of REACH Annex XVII. Two substances appear in more than one CMR category: 4-methylimidazole is both a carcinogen and reproductive toxicant, while dimethyl propylphosphonate is both a germ cell mutagen and reproductive toxicant. Therefore, the amendment involves 16 unique substances, while the category entries span multiple appendices.

Appendix 2: 5 New Carcinogens Category 1B

Appendix 4: 1 New Germ Cell Mutagen Category 1B

Appendix 6: 12 New Reproductive Toxicants Category 1B

Exemption for Specific Uses of Cumene

Regulation (EU) 2025/1731 also amends Appendix 11 of Annex XVII to add a derogation for cumene. The derogation applies when cumene is present as a substance on its own or as a constituent of other substances in certain aviation fuels, including kerosene used as aviation fuel conforming to DEF STAN 91-091, ASTM D1655 or equivalent recognized standards, and gasoline used as aviation fuel conforming to DEF STAN 91-090, ASTM D910, ASTM D7547 or equivalent recognized standards.

Corporate Response Measures and Preparations

For substances included in Annex XVII of the EU REACH Regulation, the EU restricts the placing on the market and use of the substances themselves, as well as mixtures containing those substances above specified concentration limits. Where a substance or mixture falls within the restriction and exceeds the applicable concentration threshold, it may be prohibited from being supplied to the general public.

For relevant substances intended for professional use, packaging must be marked with “For professional use only” before the substance or mixture is placed on the market. Companies should review not only substance identity and concentration, but also product use, customer type, labeling, packaging and sales channels.

The newly added CMR substances are used across multiple sectors, including pesticides, coatings, automotive manufacturing, electronics and electrical products, polymers and industrial chemical formulations. Companies supplying these sectors should pay particular attention to EU market restrictions, SDS and label updates, and downstream communication requirements.

• Screen EU-bound substances, mixtures and products against the latest REACH Annex XVII restriction list.

• Review whether any listed CMR substance exceeds applicable concentration thresholds.

• Confirm whether products are supplied to the general public or only to professional users.

• Update SDSs, labels, packaging statements and downstream use instructions where necessary.

• Prepare substitution or formulation adjustment plans for affected products.

• Monitor future CLP harmonized classification updates and REACH Annex XVII amendments.

How REACH24H Can Help

REACH24H provides EU chemical regulatory compliance support for companies placing substances, mixtures and finished products on the EU market. Our services cover REACH registration, restriction screening, CLP classification, SDS and label compliance, SVHC monitoring, supply chain communication and EU market access strategy.

Conclusion

Regulation (EU) 2025/1731 further strengthens the connection between CLP harmonized classification updates and REACH Annex XVII restriction obligations. Companies placing chemicals on the EU market should not only track new REACH restrictions, but also monitor CLP Annex VI updates that may trigger future restrictions.

For affected substances and mixtures, timely product screening, concentration review, SDS and label updates, sales channel control and substitution planning are essential to maintaining compliant access to the EU market.

Recommended Reading

• EU Adds 24 CMR Substances to REACH Restriction List

• EU Issues Regulation (EU) 2025/1222: CLP Annex VI Revised with Over 30 Substances

• EU REACH | One Hazardous Chemical Added to SVHC List by ECHA

• EU REACH Registration & OR Services

• EU CLP Compliance Services

• Global GHS/SDS/MSDS/Label Compliance

Official References

• Commission Regulation (EU) 2025/1731 on CMR substances subject to REACH restrictions

• Regulation (EC) No 1907/2006 concerning REACH

• Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures

• Commission Delegated Regulation (EU) 2024/197 amending CLP Annex VI