REACH adds a 2,4-DNT restriction: how one nitrotoluene residue enters the articles compliance boundary

Commission Regulation (EU) 2026/859 adds 2,4-dinitrotoluene, 2,4-DNT, to REACH Annex XVII as new entry 83. This is not a broad story about REACH reform. It is a specific boundary change: how a hazardous substance, when present in articles at a defined concentration, becomes subject to placing-on-the-market and use restrictions.

The important feature of 2,4-DNT in this entry is that the legal text does not focus only on supply of a substance as such. It focuses on articles, especially articles supplied to the general public or to professional users outside industrial sites. The question therefore moves from the substance alone to finished articles, components, accessible parts and residue concentration.

What the legal text changes

Commission Regulation (EU) 2026/859 was published in the Official Journal on 11 May 2026. It amends REACH Annex XVII by adding 2,4-DNT to the list of restricted substances.

The substance is 2,4-dinitrotoluene, EC No 204-450-0, CAS No 121-14-2. The regulation notes that it is classified as carcinogen category 1B. After its addition to Annex XVII, 2,4-DNT is not treated in the same way in every possible context. Entry 83 defines a specific article boundary.

The core restriction applies from 10 May 2027. Articles or accessible parts of articles containing 2,4-DNT at a concentration equal to or greater than 0.1% by weight may not be placed on the market for supply to the general public or to professional users outside industrial sites, and may not be used by those users.

The legal text frames the restriction around two actions: placing on the market and use. The first concerns supply of the article to the market; the second concerns use by the defined user groups. Entry 83 therefore combines a concentration threshold with a market and use boundary.

0.1% w/w is the technical boundary

The key number in the new entry is 0.1% w/w. The restriction is not written as a simple "detected equals restricted" rule. It is written as a weight-based threshold.

The object of assessment is also precise: the article or accessible part of the article. That matters because a product may contain several materials or components. The concentration in an accessible part can be a separate factual boundary, not only an average across the whole finished article.

That is why the 2,4-DNT restriction is not best described as "a raw material is banned". It is closer to article-level residue control, where substance identity, concentration, component accessibility, user group and application date all interact.

The restriction does not cover every user scenario

The new entry distinguishes between user groups. It expressly points to the general public and to professional users outside industrial sites. It therefore does not apply in the same way to every industrial internal use.

That boundary is one of the central facts of entry 83. The text gives the carcinogenic classification, then connects concentration in accessible articles with the target user scenario. The scope is formed by those conditions together, not by the substance name alone.

Automotive pyrotechnic articles receive a longer transition

The regulation treats pyrotechnic articles in vehicles separately. The text refers to micro gas generators, seat belt pre-tensioners, bonnet actuators and related spare parts.

These uses do not simply follow the 2027 date. The regulation sets a longer transition until 11 May 2029. It does not put all articles on the same timeline; specific automotive safety-related components receive more time.

The longer transition does not change the basic restriction in entry 83. It shows that, under the same substance restriction, different article types and uses may receive different application dates.

Exemption boundaries are part of the rule

Regulation 2026/859 also defines situations where the new entry does not apply. The text excludes certain explosive articles because they are covered by other specific legislation.

It also refers to toys, medical devices and food contact materials where relevant risks are already addressed under other EU legislation. In other words, entry 83 does not pull every possible product containing 2,4-DNT into one rule.

The factual boundary of the new restriction therefore has two sides: the prohibition conditions in Annex XVII entry 83, and the stated exclusions from that entry. Both sides are needed to understand which articles are actually covered.

References

• Commission Regulation (EU) 2026/859, Official Journal of the European Union
• EUR-Lex: Commission Regulation (EU) 2026/859 landing page
• ECHA: REACH Annex XVII restricted substances