EU Amends REACH Regulation Annex XVII, Imposing Strict Restrictions on Carcinogen 2,4-Dinitrotoluene

On April 21, 2026, the EU Official Journal published Regulation (EU) 2026/859, amending Annex XVII to the REACH Regulation (EC No 1907/2006) to impose restrictions on the use of 2,4-dinitrotoluene (2,4-DNT) in articles.

Background

2,4-DNT is a nitroaromatic compound commonly used as a precursor in the production of TNT explosives, as well as an intermediate in the manufacture of dyes and organic pigments. This substance was added to the REACH Authorization List (Annex XIV) as early as August 2015; however, the authorization requirements did not apply to imported articles. This created a loophole where, although the production of articles containing this substance had ceased within the EU, imported products from third countries continued to enter the market.

Core Restriction Provisions

Exemptions

1. Civil explosives (as defined by Directive 2014/28/EU)
2. Military articles
3. Police ammunition
4. Toys (governed by Regulation EU 2025/2509)
5. Medical devices (governed by Regulation EU 2017/745)
6. Food contact materials (governed by Regulation EC 1935/2004)

Note: Pyrotechnic articles and ammunition are not covered by the explosives exemption and remain subject to the restriction.

Transitional Arrangements

1. Automotive Sector

Given the technical complexity of automotive safety systems, the regulation establishes a maximum transitional period of 36 months for specific applications:

• Restrictions on automotive micro gas generators and spare parts: effective May 11, 2029
• Vehicles already placed on the market between 2027 and 2029 may continue to be used until end-of-life, avoiding unnecessary recalls

2. Second-hand Articles

Articles placed on the market before May 11, 2027 are not subject to the restriction.

Further Information

OJ