Notification to the WTO of Restrictions on 2,4-DNT
The European Commission has notified the WTO of a draft REACH restriction on 2,4-dinitrotoluene (2,4-DNT) in articles
19 Sept 2025Following the public consultation launched in 2021 and the subsequent favourable opinions from RAC and SEAC (2022), the European Commission has notified the World Trade Organization (WTO) of a draft regulation to amend Annex XVII of Regulation (EC) No 1907/2006 (REACH). The aim is to introduce a restriction on the use of 2,4-dinitrotoluene (2,4-DNT) in articles intended for consumers or professional users.
2,4-DNT (CAS No. 121-14-2) is classified as a Category 1B carcinogen (H350) under Regulation (EC) No 1272/2008 (CLP) and is included:
- in the SVHC Candidate List;
- in Annex XIV of REACH, among substances subject to authorization.
The proposed amendment prohibits the placing on the market and use of 2,4-DNT in all articles intended for consumers or professional users (outside industrial sites), when the concentration of the substance is equal to or greater than 0.1% by weight in such articles.
Exemptions from the ban include:
- Explosives (excluding pyrotechnic articles and ammunition),
- Articles intended for military use,
- Ammunition for police or security forces,
- Toys,
- Medical devices,
- Food Contact Materials (FCM), already regulated under Regulation (EC) No 1935/2004.
A 36-month transitional period from the entry into force of the regulation is foreseen for:
- Gas micro-generators for seatbelt pretensioners,
- Hood actuators,
- Spare parts containing 2,4-DNT for motor vehicles.
As the adoption of the regulation is expected by the end of 2025, companies are strongly advised to promptly assess the impact of the restriction and verify product compliance. Normachem Srl is fully available to support you in evaluating and understanding the implications of this proposal and assisting in the management of this upcoming obligation.