EU Intends to Restrict 2,4-Dinitrotoluene in Articles under REACH

SafeGuardSAutomotive, Electrical & Electronics, Hardgoods, Personal and Protective Equipment, Softlines, Toys and Juvenile ProductsSep 30, 2025

SG 144/25

On September 15, 2025, the WTO announced a draft regulation from the EU to restrict 2,4-DNT in articles as a new entry under Annex XVII of Regulation (EC) No. 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals’ (Annex XVII of REACH, current consolidated version to September 2025).

2,4-DNT is classified as a carcinogenic category 1B substance under Regulation (EC) No. 1272/2008 on classification, labeling and packaging of substances and mixtures (CLP Regulation). It is on the Candidate List of substances of very high concern (SVHC) for authorization, the Authorization List (Annex XIV), and restricted as a substance, a constituent of other substances or in mixtures under entry 28 to Annex XVII of REACH.

This substance has a variety of uses including, but not limited to automotive airbags, ceramic articles, electronic devices, gelatinizing-plasticizing agent in explosives, plastic bottles for sample taking in industrial settings, production of toluene diisocyanate for manufacturing polyurethane foams, propellants for military and civilian small-arms ammunition such as hunting and sports shooting, refractory products and seat-belt pre-tensioners.

Highlights of the draft regulation are summarized in Table 1.

Substance (CAS)	Scope	Requirement	Proposed date of applicability
2,4-dinitrotoluene (121-14-2)	Articles for professional users and the general public	< 0.1%	12 months after date of entry into force (EIF)¹, ² 36 months after date of EIF for the following motor vehicle applications: a) micro gas generators for seat belt pre-tensioners and bonnet actuators and b) spare parts (Proposed date of adoption = Q4 of 2025)
¹Exempts, among other things, food contact materials and articles, medical devices and toys ²Exempts a) motor vehicles placed on the market 12-36 months after the date of EIF and b) motor vehicles containing 2,4-DNT only in the applications in the second point

Table 1

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