April 20, 2026 — The European Commission adopted and published Regulation (EU) 2026/859, amending Annex XVII to Regulation (EC) No 1907/2006 (REACH) explicitly add 2,4-dinitrotoluene (2,4-DNT) as Entry 83. This Regulation shall enter into force on the twentieth day following its publication in the Official Journal of the European Union, with most restrictions becoming applicable from May 10, 2027.
This move signifies that EU supervision of 2,4-DNT now overlaps restrictions on "articles" onto the existing substance authorization and existing restrictions on the substance or in a mixture. It focuses on blocking the entry of imported articles containing the substance into the EU market to more comprehensively eliminate health risks for consumers and professional users.
2,4-DNT: Restrictions Added Atop Authorization
2,4-dinitrotoluene (2,4-DNT) is classified as a category 1B carcinogen. As a non-threshold carcinogen, it is impossible to set a Derived No-Effect Level (DNEL), meaning any level of exposure may pose a health risk.
Years ago, the substance was identified as a Substance of Very High Concern (SVHC) and subsequently added to the REACH Annex XIV Authorization List. Due to its CMR properties, it was also included in Entry 28 of Annex XVII (restricting the placing on the market and use for supply to the general public as a substance or in a mixture).
While the production of articles containing 2,4-DNT has ceased within the EU, the aforementioned controls do not apply to imported articles. This regulatory gap allows articles produced outside the Union—such as vehicle safety systems, refractory products, plastic articles, and civilian ammunition—containing 2,4-DNT to still legally enter the EU market, posing a continuous health risk to consumers and professional users.
The European Chemicals Agency (ECHA) concluded that exposure to 2,4-DNT from these articles poses risks to consumers and professional users that are not adequately controlled. This regulation ensures imported articles meet the same strict standards as those originating in the Union.
Specific Restriction Provisions
In Annex XVII to Regulation (EC) No 1907/2006, the following entry is added:
| Substance | Conditions of restriction) |
|---|---|
| 2,4-dinitrotoluene CAS No 121-14-2 EC No 204-450-0 | 1.After 10 May 2027, shall not be placed on the 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 % by weight. 2.For the purpose of this entry, “professional user” shall mean any worker or self-employed worker operating outside of industrial sites. 3.Paragraph 1 shall not apply to: (a) explosives, as defined in Article 2, point (1), of Directive 2014/28/EU; (b) articles for military use; (c) ammunition for use, in accordance with national law, by the police or other security forces; (f) articles intended to come into contact with food, within the scope of Regulation (EC) No 1935/2004. 4. The following shall not be covered by paragraph 3(a): (a) pyrotechnic articles, as defined in Article 3, point (1), of Directive 2013/29/EU; (b) ammunition. 5. Paragraph 1, shall apply from 11 May 2029 to the placing on the market and use of 2,4-dinitrotoluene in the following applications, where they are placed on the market for use, or used in motor vehicles as defined in Article 3, point (16), of Regulation (EU) 2018/858 of the European Parliament and of the Council (*2): (a) micro gas generators for seat belt pre-tensioners and bonnet actuators;(b) spare parts. 6. Paragraph 1 shall not apply to motor vehicles referred to in paragraph 5, that meet the following conditions: (a) were placed on the market between 11 May 2027 and 11 May 2029;(b) contain 2,4-dinitrotoluene only in applications listed in paragraph 5, point (a) or point (b). 7. Paragraph 1 shall not apply to 2,4-dinitrotoluene in articles placed on the market in the Union before 11 May 2027. |
(*1) Regulation (EU) 2025/2509 of the European Parliament and of the Council of 26 November 2025 on the safety of toys and repealing Directive 2009/48/EC (OJ L, 2025/2509, 12.12.2025, ELI: http://data.europa.eu/eli/reg/2025/2509/oj).
(*2) Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles, amending Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC (OJ L 151, 14.6.2018, p. 1, ELI: http://data.europa.eu/eli/reg/2018/858/oj).’
Compliance Recommendations
Since there is no production of 2,4-DNT within the EU, non-EU enterprises exporting to the Union and their importers will be most affected. REACH24H Consulting Group suggests the following:
1. Conduct Comprehensive Supply Chain Audits: Focus on automotive parts, plastic packaging, refractory materials, and electronics to verify if 2,4-DNT is used as a plasticizer or additive at concentrations ≥ 0.1%.
2. Accelerate Alternative R&D: ECHA indicates alternatives exist for all identified uses. Companies should utilize the 12-month transition (36 months for automotive) to switch materials.
3. Strengthen Compliance Testing: Ensure products meet the 0.1% limit. Request ingredient declarations or third-party test reports from suppliers.
4. Manage Inventory and Disposal: Clear non-compliant stock before the May 2027 deadline to avoid recalls or illegal waste generation.
5. Maintain Communication and Documentation: Update technical files, Declarations of Conformity(DoC), and Safety Data Sheets(SDS), ensuring restriction requirements are communicated throughout the supply chain.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
