SG 153/25
Montenegro has revised its lists of restricted chemicals and persistent organic pollutants (POPs) to further align with those in the European Union (EU).
In 2018, Montenegro issued the nation’s ‘Regulation on prohibited or permitted use, production and placing on the market of chemicals that pose an unacceptable risk to human health and the environment’ (‘the Regulation’, Official Gazette of Montenegro (OGM) No. 70/2018). Since its publication, Annexes 1 and 2 have been revised on several occasions (OGM Nos.76/2020, 134/2022 and 57/2024).
The Regulation contains three annexes governing the management of certain chemicals:
- Annex 1 ‘Chemicals that pose an unacceptable risk to health and the environment and whose use, production and placing on the market is prohibited or restricted’. These are similar to ‘Restricted Chemicals’ 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 for reference)
- Annex 2 ‘List of persistent organic pollutant (POP) substances subject to bans’ (similar to Annex I of Part A to Regulation (EU) 2019/1021 (POP Recast Regulation, current consolidated version to August 2025 for reference)
- Annex 3 ‘Permitted VOC content values in coating (paints and varnishes), similar to Directive 2004/42/EC (current consolidated version to July 2021 for reference)
On October 6, 2025, Montenegro issued an amendment (OGM No. 112/2025) revising Annexes 1 and 2 of the Regulation to further align national safety requirements with those of the EU.
Key changes to Annex I ‘Restricted Chemicals’ include:
- Adding Entry 50a to restrict 18 polycyclic aromatic hydrocarbons (PAHs) in clay targets (as Entry 50a to Annex XVII of REACH, SafeGuardS 53/25)
- Incorporating dodecamethylcyclohexasiloxane (D6) into Entry 70, with revised restrictions and derogations (similar to Entry 70 to Annex XVII of REACH)
- Introducing Entry 79 on undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances (similar to Entry 79 of Annex XVII of REACH, SafeGuardS 145/24)
Highlights of key revisions to Annex 2 ‘POPs’ include:
- Amending the permitted use of hexabromocyclododecane (HBCDD) by, inter alia, strengthening its concentration in substances, mixtures, articles, or as constituents of flame-retarded articles from ≤ 100 mg/kg to ≤ 75 mg/kg (similar to POP Recast Regulation, SafeGuardS 148/24)
- Permitting no more than 0.01 mg/kg methoxyclor in substances, mixtures or articles
OGM No. 112/2025 will enter into force on October 14, 2025 (eight days following its publication in the OGM).
We are committed to providing information about regulatory developments for consumer products as a complimentary service. Through our global network of experts and laboratories, we provide a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.
© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.
16th Floor, Block A, No.73 Fucheng Road, Century Yuhui Mansion,
Beijing, Haidian District,
China