New lead and diisocyanate limits 2026: what affected companies must do

Key data

If your company works with lead or products containing diisocyanates, you have a new legal obligation as of October 23, 2026. The Royal Decree 846/2026 transposes Directive (EU) 2024/869 and modifies two pillars of occupational health and safety regulations: Royal Decree 665/1997 on carcinogenic, mutagenic and reprotoxic agents, and Royal Decree 374/2001 on chemical agents.

The change is not merely technical. It affects risk assessment, health surveillance of your workers and the technical measures you must have in place. Failure to adapt can result in serious penalties for breach of occupational health and safety regulations.

What does this regulation establish?

RD 846/2026 introduces two distinct blocks of changes:

1. Lead and its inorganic compounds

The binding environmental and biological limit values (VLA) for lead and its inorganic compounds are reduced. The previous standard already established limits, but the new ones are stricter as they incorporate the most recent scientific evidence.

The most relevant novelty from a personnel management perspective: lead is formally recognized as a reprotoxic agent with no safe threshold for workers of reproductive age. This means there is no level of exposure considered safe for this group, requiring the application of the principle of exposure minimization with special rigor.

2. Diisocyanates

For the first time, binding environmental limit values are established for diisocyanates, compounds present in two-component paints, polyurethane foams and industrial adhesives:

Additionally, the regulation requires consideration of dermal absorption of diisocyanates, not just the respiratory route. This broadens the scope of necessary protective measures.

Economic and operational impact

The impact is not measured only in fines: adaptation costs can be significant depending on each company's starting point.

• Environmental measurements: It will be necessary to hire industrial hygiene measurements to verify that current exposure levels are below the new, more demanding limits.
• Risk assessment review: The prevention service (internal or external) must update documentation. If the new limits are not met, additional technical measures must be implemented (ventilation, product substitution, encapsulation).
• Health surveillance: Medical protocols for workers exposed to lead and diisocyanates must be reviewed in light of the new values. For workers of reproductive age exposed to lead, management of reprotoxic risk requires specific attention.
• Personal protective equipment (PPE): Consideration of dermal absorption of diisocyanates may require reviewing or expanding current PPE (gloves, protective clothing).
• Penalty risk: Non-compliance with the new limits can result in serious breaches of occupational health and safety regulations, with corresponding economic sanctions.

Who does it affect?

This regulation affects any company where workers may be exposed to lead, inorganic lead compounds or diisocyanates. The most directly involved sectors are:

• Foundries and metallurgy: Direct exposure to lead and its compounds.
• Battery manufacturing and recycling: Intensive use of lead.
• Construction and rehabilitation: Presence of lead in old paints, welding and construction materials.
• Paint and coating manufacturing: Use of diisocyanates in two-component formulations.
• Foam and polyurethane industry: Diisocyanates are essential raw material.
• Industrial adhesive manufacturing: Frequent presence of diisocyanates.
• Vehicle body shops and paint shops: Application of diisocyanate-based paints.
• Any company with workers of reproductive age exposed to lead: Reinforced obligation due to recognition of lead as reprotoxic with no safe threshold.

Practical example

Imagine a body shop with 8 workers using two-component diisocyanate-based paints. Until now, the company conducted annual industrial hygiene measurements and results were at the upper limit of what was permitted under the previous regulation.

With RD 846/2026, the new daily exposure limit is set at 6 μg NCO/m³. If previous measurements were approaching a higher value, the company is now in breach as of October 23, 2026. It must:

1. Commission new environmental measurements to verify actual levels under the new limits.
2. Review the risk assessment with its prevention service.
3. Evaluate whether current PPE covers dermal absorption as well, not just the respiratory route.
4. Update health surveillance protocols for exposed workers.

If among those 8 workers there are people of reproductive age exposed to lead (for example, in welding operations with materials containing it), the company must also apply the principle of maximum exposure minimization, with no level considered safe.

What should companies do now?

1. Identify if your company is affected: Review whether your activity uses or generates lead, inorganic lead compounds or diisocyanates. If in doubt, consult the safety data sheets of the products you use.
2. Contact your prevention service: Inform the prevention service (internal or external) of the entry into force of RD 846/2026 and request an urgent review of the risk assessment.
3. Commission updated industrial hygiene measurements: Verify that environmental exposure levels comply with the new limits: 6 μg NCO/m³ (daily) and 12 μg NCO/m³ (short duration) for diisocyanates, and the new reduced VLA for lead.
4. Review health surveillance: Update medical protocols for exposed workers. Pay special attention to workers of reproductive age exposed to lead, given its recognition as reprotoxic with no safe threshold.
5. Evaluate dermal protection against diisocyanates: Verify that current PPE covers the dermal absorption route as well, not just the respiratory route.
6. Document all changes: Update the risk assessment, prevention plan and health surveillance records. This documentation is essential in case of a labor inspection.

Official source

Consult complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-22080