REACH Annex XVII – Entry 83 Updated: Restrictions on 2,4-Dinitrotoluene

CDX has been updated to reflect the amended Entry 83 of REACH Annex XVII, addressing restrictions applicable to 2,4-Dinitrotoluene (2,4-DNT).

Background
2,4-Dinitrotoluene is a chemical intermediate primarily used in the manufacture of toluene diisocyanate (TDI), which is a key building block in the production of polyurethane materials including flexible foams, coatings, adhesives, and sealants. 2,4-DNT is classified as a Substance of Very High Concern (SVHC) due to its carcinogenic, mutagenic, and reprotoxic (CMR) properties, and has been subject to increasing regulatory scrutiny at both EU and global level.

The amendment to Entry 83 introduces updated concentration limits and clarifies the scope of restrictions applicable to mixtures and articles containing 2,4-DNT placed on the EU market. The restriction is intended to minimize occupational exposure and reduce risks across the supply chain.

Industry Relevance
While 2,4-DNT is primarily an industrial intermediate rather than a substance intentionally incorporated into finished products, its presence in supply chains is often indirect — typically through TDI-derived polyurethane components. Industries most likely to be affected include:

• Aerospace & Defence — structural adhesives, interior sealants, polyurethane-based coatings, and in some cases propellant-related manufacturing processes
• Automotive — polyurethane seating foams, acoustic insulation, interior panels, and TDI-based adhesives and coatings
• Electronics — encapsulants, potting compounds, and flexible foam components derived from TDI-based polyurethane systems
• Heavy Equipment — operator cab interiors, noise insulation materials, seating assemblies, and structural adhesives

Compliance Implications
Manufacturers and suppliers placing articles or mixtures on the EU market that contain or are derived from TDI-based polyurethane systems should verify whether their products fall within the scope of the updated Entry 83. This includes reviewing substance declarations submitted through CDX and ensuring that Full Material Declarations (FMD) from suppliers accurately reflect compliance with the revised thresholds.

The updated Entry 83 is now active within CDX. Companies are advised to engage their supply chain partners to confirm compliance status and update relevant declarations accordingly. For the full regulatory text, refer to the ECHA REACH Annex XVII register.