According to the Official Journal of the EU of 21 April 2026, the European Commission has formally adopted Regulation (EU) 2026/859, adding 2,4-dinitrotoluene (2,4-DNT) as entry 83 of Annex XVII (Restrictions) to the REACH Regulation.

Core requirements

The new rule addresses the 2,4-DNT content of articles. The specific restrictions are as follows.

Subject: articles for use by professional users (workers outside industrial sites, or self-employed persons) or by the general public.

Entry into force: applicable from 10 May 2027.

Concentration limit: articles containing 2,4-DNT in a mass concentration of 0.1 percent or more may not be placed on the market or used.

Scope note: the restriction mainly targets imported articles. 2,4-DNT had already been placed on the Authorisation List (Annex XIV), which restricts production within the EU, but imported articles are not subject to the authorisation requirement, which is why they are the focus of this restriction.

Specific exemptions and transition periods

The regulation provides for exemptions and longer transition periods in specific cases.

Exemptions: explosives, military articles, police ammunition, toys, medical devices and food contact materials are explicitly exempt.

Automotive transition period: in view of the complexity of automotive safety systems, a longer transition period applies to micro gas generators and spare parts used in applications such as seat belt pre-tensioners and bonnet actuators, with the restriction applying to those uses from 11 May 2029.

Articles already on the market: articles placed on the EU market before the restriction takes effect on 11 May 2027 are not covered.

Sectors most affected

2,4-DNT is an important chemical intermediate, and the following industries need to pay particular attention.

Automotive industry: used in micro-explosives in safety components such as airbag gas generators and seat belt pre-tensioners.

Energetic materials: used in the production of TNT, propellants and similar products.

Chemicals and dyes: used as an intermediate in the production of toluene diisocyanate (TDI), dyes and organic pigments.

Note in particular that 2,4-DNT was already placed on the SVHC candidate list in 2011, and information transfer and SCIP notification obligations already applied. Listing it in Annex XVII means a comprehensive tightening of controls. Companies should review their use of the substance in products as soon as possible and ensure compliance before the May 2027 deadline.

If you need further assessment of the compliance risk of 2,4-DNT in your products, tell us your product type at any time and we will provide more targeted advice.