ECHA Proposes Restriction on 2,4-DNT

2021-11-08

Starting on 2021-09-22, the European Chemicals Agency (ECHA) launched a public consultation on the proposal to restrict 2,4-dinitrotoluene (2,4-DNT) under REACH Annex XVII. This consultation on the proposed restriction will end on 2022-03-22.

Significance:

2,4-dinitrotoluene (2,4-DNT) is classified as a carcinogen category 1B (associated with renal cell cancer), it was included in the candidate list for authorization and into Annex XIV of REACH with a sunset date of 2015-08-21.

The ECHA determined that there are uses of 2,4-DNT in articles such as refractories, automotive airbags, seat belt pre-tensioners, plastic bottles used in industrial settings for sample taking purposes, and propellants for military and civil small-arms ammunitions. Consumer and professional exposure may occur from the uses identified and due to the non-threshold effects of 2,4-DNT; these exposures may pose a risk that is not adequately controlled. The Dossier Submitter concluded that action is required to reduce risks for consumers and professional workers on a union-wide level and proposed that restriction is the most appropriate measure.

The restriction is assumed to impose very low costs to reduce potential risk and alternatives to 2,4-DNT exist for the identified uses; given the information at hand, it is assumed that the measure is proportionate to the risk assuming a 12-month transition time.

Proposed Restriction:

Restricted Substance	2,4-dinitrotoluene (2,4-DNT)
Proposed Scope of Restriction	Articles for supply to the general public or professional workers
Proposed Limit	< 0.1% by weight
Proposed Exemption	Articles placed on the market or used in explosives and ammunition used for military use
	Articles regulated by Directive 2009/48/EC on the safety of toys
	Articles regulated by Regulation (EU) 2017/745 on medical devices