REACH Adds New CMR Substance Limits

The European Commission has published Regulation (EU) 2025/1731, amending the REACH Regulation (EC No 1907/2006) to introduce new restrictions on substances classified as carcinogenic, mutagenic, or toxic to reproduction (CMRs). The update was published on 11 August 2025 and will take effect on 1 September 2025.

Alignment with CLP Hazard Classifications

The amendment updates Appendices 2, 4, and 6 of Annex XVII of REACH to reflect substances reclassified as CMR Category 1B under the CLP Regulation (EC No 1272/2008), following Delegated Regulation (EU) 2024/197.

This change ensures continued alignment between REACH and the evolving CLP classification system, enhancing regulatory coherence across EU chemical laws.

Newly Restricted Substances

The following substances have been added to REACH Annex XVII:

📌 Appendix 2

• Diuron (ISO): 3-(3,4-dichlorophenyl)-1,1-dimethylurea
• Tetrabromobisphenol-A
• N,N-Dimethyl-p-toluidine
• 4-Nitrosomorpholine
• 4-Methylimidazole

📌 Appendix 4

• Dimethyl propylphosphonate

📌 Appendix 6

• Diphenyl(2,4,6-trimethylbenzoyl) phosphine oxide

Effective Date

⏳ In Force: 20 days after publication
🚫 Compliance Required: 1 September 2025

From this date, placing these substances on the market or using them within the EU will be restricted, unless specific exemptions apply.

Business and Regulatory Impact

Companies handling any of the newly listed substances—whether as manufacturers, importers, formulators, or downstream users—must take immediate action to ensure compliance.

Key Actions for Stakeholders

• Review substance use across products and supply chains
• Update compliance protocols to reflect new legal obligations
• Seek safer alternatives where substitution is required
• Notify internal regulatory and safety teams
• Consult EU guidance or chemical safety experts for support

Importance of the Update

🔒Stronger Public Health Protections: The restriction of these substances under REACH strengthens the EU’s stance on hazardous chemical control, especially in protecting vulnerable populations and workers.
⚖️Regulatory Consistency: By updating Annex XVII based on CLP’s latest classifications, the amendment ensures REACH remains synchronized with broader EU chemical legislation.
📉Operational Implications: Affected businesses must act now to avoid supply chain disruptions, regulatory penalties, or loss of market access within the EU.

Reference: Official EU Regulation – OJ L 2025/1731 PDF