📅 Report Date: May 5, 2026
🏷️ Policy Areas: EU REACH · US TSCA · China GB Standards
⚠️ Overall Risk Level: Medium — Key regulatory transition window ahead
I. EU REACH — Significant Updates
1. REACH Annex XVII: New Restriction on 2,4-Dinitrotoluene
On April 20, 2026, the EU Official Journal published Regulation (EU) 2026/859, amending REACH by adding a new Entry 83 to Annex XVII, imposing restrictions on 2,4-dinitrotoluene (2,4-DNT):
- Restriction: Products marketed for professional users or the public containing 2,4-DNT at concentrations ≥ 0.1% by weight are restricted
- Effective date: 20 days after publication in the EU Official Journal
- Affected products: Coatings, adhesives, inks, and dyes containing 2,4-DNT
2. SVHC Candidate List Updated to 253 Substances
The ECHA SVHC Candidate List has officially grown to 253 substances. Key additions include:
- n-Hexane — Reproductive toxicity (Article 57c)
- BPAF (4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol) and its salts — Endocrine disrupting properties (Article 57f)
II. US EPA TSCA — Baseline Activity
EPA finalized the PFAS Reporting Rule under TSCA Section 8(a)(7) (40 CFR Part 705) on October 11, 2023. All persons who have manufactured (including imported) or imported articles containing PFAS at any time since January 1, 2011, are required to electronically report information on uses, production volumes, disposal, exposures, and hazards.
Additionally, EPA’s final rule on five PBT substances (DecaBDE, PIP(3:1), 2,4,6-TTBP, PCTP, and HCBD) has been progressively enforced since February 5, 2021.
III. China GB Standards — Key Reminders
【Effective June 1, 2026】Two Mandatory Coating Standards
- GB 30981.1—2025 — Limits of Harmful Substances in Coatings, Part 1: Architectural Coatings
- GB 30981.2—2025 — Limits of Harmful Substances in Coatings, Part 2: Industrial Coatings
【Effective August 15, 2026】Environmental Code of the People’s Republic of China
Enacted by the NPC Standing Committee on March 12, 2026, this is a comprehensive legal compilation covering hazardous chemical safety and pollutant discharge standards in China’s environmental sector.
IV. Recommended Actions
| Priority | Action Item | Timeline |
|---|---|---|
| 🔴 High | Screen products for n-Hexane, BPAF, and other SVHCs; verify concentration is below 0.1% | Immediately |
| 🔴 High | Test coating products for 2,4-DNT content; prepare REACH Annex XVII compliance documentation | By end of May |
| 🟡 Medium | Gap assessment against GB 30981.1/2—2025 for all coating products | By end of May |
| 🟡 Medium | Build PFAS substance inventory; evaluate EPA TSCA Section 8(a)(7) reporting obligations | Ongoing |
| 🟢 Low | Monitor Environmental Code implementation details and assess impact on chemical production | Before Aug 15 |
V. Baseline Reference
- EU REACH SVHC Candidate List current total: 253 substances
- REACH Annex XVII active restriction entries: 75 categories
- US TSCA Chemical Substance Inventory: ~86,557 substances
- EPA PFAS Reporting Rule: 40 CFR Part 705
📌 This report is compiled from publicly available regulatory information for compliance reference only. Specific compliance determinations should be made in consultation with qualified regulatory professionals based on actual product circumstances.
发表回复