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New restriction in REACH Annex XVII: Entry 83 of 2,4-dinitrotoluene (2,4-DNT)
The European Union continues to strengthen its regulatory framework to protect human health from hazardous substances present in articles.
Commission Regulation (EU) 2026/859, published on April 21, 2026, introduces a new restriction in Annex XVII of the REACH Regulation: Entry 83 concerning 2,4-dinitrotoluene (2,4-DNT).
This amendment prohibits placing articles on the market or using them in products intended for both the general public and professional users when the concentration is ≥0.1% by weight.
This measure represents a significant change for importers, distributors, and manufacturers of articles that may contain 2,4-dinitrotoluene (2,4-DNT), especially in sectors such as automotive, electronics, plastic materials, or articles with explosive components.
Why is 2,4-dinitrotoluene (2,4-DNT) regulated?
2,4-dinitrotoluene (2,4-DNT) (CAS No. 121-14-2, EC No. 204-450-0) is classified in accordance with Regulation (EC) No. 1272/2008 of the European Parliament and of the Council as a Category 1B carcinogen.
The Regulation itself states that it is a non-threshold carcinogen, meaning that it is not possible to establish a safe level of exposure:
“For this substance, it is not possible to establish a derived no-effect level (DNEL), and therefore it is a non-threshold carcinogen.” (Regulation (EU) 2026/859)
Although its use as a substance or in mixtures was already restricted in the EU, the Commission identified a gap: imported articles were not covered by REACH authorization.
This allowed products manufactured outside the EU to enter the European market with 2,4-DNT incorporated.
In which articles has 2,4-DNT been found?
The ECHA dossier identified current or past uses of 2,4-dinitrotoluene (2,4-DNT) in:
Airbags and seatbelt pretensioners
Civil and military ammunition
Plastic bottles for sample collection
Refractory articles
Electronic and ceramic components
Additionally, it was found that the substance may be released during normal use, leading to exposure via inhalation or skin contact.
What exactly does the new REACH Entry 83 establish?
The key restriction for 2,4-dinitrotoluene (2,4-DNT) is clear:
“After May 10, 2027, it shall not be placed on the market or used […] in articles for professional users or for the general public, at a concentration equal to or greater than 0.1% by weight.” (Annex XVII, Entry 83, point 1)
Definition of professional user
The Regulation clarifies that a professional user is considered to be:
“Any worker, employed or self-employed, operating outside industrial installations.” (Entry 83, point 2)
Exceptions to the 2,4-DNT restriction
The regulation excludes certain articles where the use of 2,4-dinitrotoluene (2,4-DNT) is governed by other legislation or where its removal could compromise safety:
Explosives as defined in Directive 2014/28/EU
Articles for military use
Ammunition for police and law enforcement
Toys regulated by Regulation (EU) 2025/2509
Medical devices (Regulation 2017/745)
Food contact materials (Regulation 1935/2004)
Additionally, it is clarified that pyrotechnic articles and civil ammunition are not exempt.
Differentiated timelines for the automotive sector
One of the most relevant aspects of the restriction on 2,4-dinitrotoluene (2,4-DNT) is the differentiated treatment for airbags, pretensioners, and spare parts.
The restriction will apply from May 10, 2027, but an additional transition period is granted for the automotive sector:
“Point 1 shall apply from May 11, 2029 […] to gas microgenerators for seatbelt pretensioners and bonnet actuators; [and] spare parts.” (Entry 83, point 5)
Additionally, vehicles placed on the market between 2027 and 2029 may continue to be used until the end of their service life.
Which articles are exempt due to age?
To avoid mass withdrawals of products already in circulation:
Articles that were already on the market before May 11, 2027, are excluded from the scope of the new restriction.
Therefore, it will not be necessary to withdraw them or apply retroactive measures, as established by the Regulation itself:
“Point 1 shall not apply to 2,4-dinitrotoluene in articles placed on the market in the Union before May 11, 2027.” (Entry 83, point 7)
This exemption also includes second-hand articles.
Implementation timeline of 2,4-DNT under REACH
Date | Obligation |
Before 2027 | Articles already placed on the market are exempt |
May 10, 2027 | General prohibition enters into force for articles ≥0.1% of 2,4-DNT |
May 11, 2029 | Prohibition enters into force for airbags, pretensioners, and spare parts |
Who is affected by this new restriction?
The new restriction on 2,4-dinitrotoluene (2,4-DNT) mainly affects:
Importers of articles manufactured outside the EU
Distributors of products with plastic, electronic, or pyrotechnic components
Automotive manufacturers and spare parts suppliers
Civil ammunition companies
Laboratories and industrial sectors using specific plastic bottles or materials
Regulatory impact of 2,4-dinitrotoluene (2,4-DNT)
The new Entry 83 of Annex XVII REACH represents another step in the European strategy to eliminate non-threshold carcinogenic substances from consumer and professional-use products.
The Commission summarizes it as follows:
“Exposure to 2,4-DNT in articles poses an unacceptable risk to the health of the general public and professional users.”
The business sector must strengthen control over its supply chain, require verifiable documentation, and replace materials or parts containing 2,4-dinitrotoluene (2,4-DNT).
Comply with the 2,4-DNT restriction with eQgest
At eQgest, we provide the technical and regulatory support necessary for your company to adapt its processes and ensure compliance with Entry 83 of Annex XVII REACH.
If you would like more information about Commission Regulation (EU) 2026/859 of April 20, 2026, you can consult it here
You can also contact our team to receive specialized advice and ensure regulatory compliance of your products.
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