REACH Legislation

REACH is the European Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force in 2007, replacing the former legislative framework for chemicals in the EU.

A restriction – as one of several legislative options under REACH - is used to protect human health and the environment from unacceptable risks posed by chemicals.  On 4 February 2020, the REACH Committee (established under REACH, consisting of representatives of the Member States and the EU Commission) voted in favour of the European Commission’s proposal for a REACH restriction on diisocyanates. The Restriction was published on 4 August 2020 applying from 24 August 2023 after a transition period of 3 years.

Scope of the Restriction

The Restriction states that:

“Diisocyanates, O = C=N-R-N = C=O, with R an aliphatic or aromatic hydrocarbon unit of unspecified length

1. Shall not be used as substances on their own, as a constituent in other substances or in mixtures for industrial and professional use(s) after 24 August 2023, unless: (a) the concentration of diisocyanates individually and in combination is less than 0,1 % by weight, or (b) the employer or self-employed ensures that industrial or professional user(s) have successfully completed training on the safe use of diisocyanates prior to the use of the substance(s) or mixture(s).

2. Shall not be placed on the market as substances on their own, as a constituent in other substances or in mixtures for industrial and professional use(s) after 24 February 2022, unless: (a) the concentration of diisocyanates individually and in combination is less than 0,1 % by weight, or (b) the supplier ensures that the recipient of the substance(s) or mixture(s) is provided with information on the requirements referred to in point (b) of paragraph 1 and the following statement is placed on the packaging, in a manner that is visibly distinct from the rest of the label information: “As from 24 August 2023 adequate training is required before industrial or professional use”.”

Under the new Restriction, on the one hand, suppliers of diisocyanates shall ensure that the recipient is provided with training materials and courses in the official language(s) of the Member State(s) where the substance(s) or mixture(s) are supplied. On the other hand, employers are responsible for ensuring that their employees have successfully completed the training on the safe use of diisocyanates prior to the use of the substance or mixture. The training shall take into consideration the specificity of the products supplied, including composition, packaging, and design.

Source: https://echa.europa.eu/documents/10162/503ac424-3bcb-137b-9247-09e41eb6dd5a

 

List of substances (please note, that this list of Diisocyanate is not exhaustive):

The following table has been prepared by the European Chemicals Agency (ECHA) to facilitate the searching of restricted substances in the Annex XVII of the REACH Regulation. Please note the list is not exhaustive.

Name

EC / List no.

CAS no.

2-methyl-m-phenylene diisocyanate

202-039-0

91-08-7

3,3'-dimethylbiphenyl-4,4'-diyl diisocyanate

202-112-7

91-97-4

4,4’-Methylenediphenyl diisocyanate

202-966-0

101-68-8

Hexamethylene diisocyanate

212-485-8

822-06-0

4-methyl-m-phenylene diisocyanate

209-544-5

584-84-9

4,4'-methylenedicyclohexyl diisocyanate

225-863-2

5124-30-1

m-tolylidene diisocyanate

247-722-4

26471-62-5

2,4,6-triisopropyl-m-phenylene diisocyanate

218-485-4

2162-73-4

2,2’-Methylenediphenyl diisocyanate

219-799-4

2536-05-2

1,3-bis(1-isocyanato-1-methylethyl)benzene

220-474-4

2778-42-9

1,5-naphthylene diisocyanate

221-641-4

3173-72-6

1,3-bis(isocyanatomethyl)benzene

222-852-4

3634-83-1

3-isocyanatomethyl-3,5,5-trimethylcyclohexyl isocyanate

223-861-6

4098-71-9

2,4’-Methylenediphenyl diisocyanate

227-534-9

5873-54-1

Source:  https://echa.europa.eu/de/substances-restricted-under-reach/-/dislist/details/0b0236e185347b62

Training levels

The Restriction specifies 3 different levels of training required for various uses of diisocyanates, the General Training as a minimum requirement and depending on the exposure an Intermediate Training and an Advanced Training.

 training levels

training levels description