2,4-Dinitrotoluene in articles: what manufacturers and importers must do

Key data

Manufacturers and importers of articles using elastomers, rubbers or certain plastics have a new compliance obligation from April 2026. Regulation (EU) 2026/859 amends Annex XVII of the REACH Regulation (EC) No 1907/2006 to include specific restrictions on 2,4-dinitrotoluene (2,4-DNT) in articles.

The reason is clear: 2,4-DNT is toxic to reproduction and potentially carcinogenic. Its presence as an impurity in commonly used materials makes this restriction an operational priority for the entire manufacturing and distribution chain.

What does this regulation establish?

The Regulation introduces a new entry in Annex XVII of REACH, which is the list of substance restrictions in the EU. From now on, articles may not contain 2,4-DNT above the concentration limits established in the standard.

The key points of the regulatory content are:

• 2,4-dinitrotoluene (2,4-DNT) is added as a restricted substance in articles in Annex XVII of REACH.
• The restriction applies to articles where 2,4-DNT may appear as an impurity in materials, not only as an intentional ingredient.
• Companies must verify that their articles comply with the new concentration limits established.
• The supply chain must ensure traceability and control of this substance in the materials used.
• Non-compliance may result in market withdrawal of affected products and administrative sanctions.

This standard amends the REACH Regulation, which is the European reference framework for the registration, evaluation, authorization and restriction of chemical substances and mixtures. Annex XVII already contained restrictions for other hazardous substances; 2,4-DNT is now added to that list.

Economic and operational impact

The impact is not only regulatory: it has direct consequences on purchasing, production and marketing processes.

The cost of adaptation will depend on the volume of affected articles and the degree of control the company already has over its suppliers. Companies with long supply chains or suppliers outside the EU will have greater verification effort.

Who does it affect?

This regulation directly affects:

• Manufacturers of articles that use elastomers, rubbers or certain plastics in their products (automotive components, footwear, sports articles, seals, hoses, etc.).
• Importers that introduce into the EU articles that may contain 2,4-DNT as an impurity, regardless of origin.
• Distributors that market potentially affected articles and must ensure the compliance of products they place on the market.
• Procurement and quality managers in industrial companies that manage suppliers of raw materials or semi-finished products with rubber or elastomers.
• Regulatory compliance and REACH advisors that support companies in the industrial and consumer sectors.

The sectors with the greatest exposure are those that commonly use elastomers, rubbers or technical plastics: automotive, footwear, sports articles, construction industry and industrial component manufacturing.

Practical example

A Spanish sports footwear manufacturer that purchases rubber soles from an Asian supplier must, from the entry into force of this regulation, verify that those soles do not exceed the concentration limits of 2,4-DNT established in the new Annex XVII of REACH.

If the supplier cannot demonstrate compliance through testing or certification, the manufacturer has two options: require the supplier to conduct the necessary tests or change suppliers. If it markets the product without this verification and the articles exceed the limits, it is exposed to mandatory market withdrawal of the affected batches and administrative sanctions by the competent authorities.

The same applies to an importer bringing rubber or technical plastic articles from outside the EU: the responsibility to verify compliance rests with them before placing the product on the European market.

What should companies do now?

1. Identify potentially affected articles in the product catalog: those containing elastomers, rubbers or certain plastics where 2,4-DNT may appear as an impurity.
2. Review the supply chain to locate materials and suppliers that may be a source of 2,4-DNT in final products.
3. Request from suppliers documentation, analysis or declarations that demonstrate compliance with the new 2,4-DNT concentration limits.
4. Establish internal traceability controls to ensure that materials used comply with Annex XVII REACH requirements on an ongoing basis.
5. Consult the exact date of entry into force in the official source of Regulation (EU) 2026/859 to plan adaptation timelines.
6. Document all verification and compliance actions to be able to demonstrate conformity to the competent authorities in case of inspection.

The risk of not acting is concrete: product withdrawal from the market and administrative sanctions. The sooner the supply chain review is initiated, the lower the operational impact.