EU REACH Restriction Roadmap
ANNEX I – Rolling List of (groups of) substances for restriction
Pool 0: Intention to prepare restriction dossier already on the Registry of Intention (RoI) or mandate to prepare a restriction dossier provided to ECHA
Pool definition: Pool 0 contains substances that are already included in the Registry of Intention (RoI) for restrictions1 or where the Commission has requested ECHA to prepare a restriction dossier. Restriction dossiers that have already been submitted are not included in pool 0 but are listed in Appendix 1.
1. Pool 0 – Commission mandates to ECHA
| Subject of restriction proposal | Group restriction or number of substances to be restricted | Hazards in scope Confirmed or [suspected hazards] | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | State of play | |
|---|---|---|---|---|---|---|
| 1.1 | CMRs in childcare articles | Group | CMR | A | Restriction proposal by Commission based on Article 68(2). Commission request to ECHA to support (investigation report). Annex XV is not applicable (Article 68(2) process). The scope covers substances which are classified as carcinogen, germ cell mutagen or reproductive toxicant category 1A or 1B in Part 3 of Annex VI to Regulation (EC) No 1272/2008. | ECHA investigation report submitted to the Commission. Planned first discussion in REACH committee in October 2025 |
2. Pool 0 – ECHA Article 69.2
None
3. Pool 0 – Member States
| Subject of restriction proposal | Group restriction or number of substances to be restricted | Hazards in scope Confirmed or [suspected hazards] | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | State of play | |
|---|---|---|---|---|---|---|
| 3.1 | 1,4-dioxane DE | 1 | C, Equivalent level of concern having probable serious effects to human health and environment (‘PMT-like’) | I, P, C, | Restriction of the manufacture, placing on the market and use of 1,4-dioxane in surfactants | RoI entry updated in October 2023. Submission of Annex XV planned for October 2025 (delayed) |
| 3.2 | Octocrilene FR | 1 | Aquatic toxicity | Risks are mainly observed for the specific use of octocrilene in plastisol, and as UV filter in cosmetic ingredients | Restricting the placing on the market of mixtures containing octocrilene | RoI entry added October 2023. Submission of Annex XV dossier planned for 18 July 2025. |
Pool 1: Planned restrictions not yet on the RoI for restriction
Pool definition: Pool 1 contains substances for which work is already very advanced and that are under consideration by ECHA, Member States, or the Commission for restriction. For some of these substances, preparatory work towards a planned restriction dossier has already started. Furthermore, for some (groups of) substances classification under the CLP Regulation or SVHC-identification under REACH is discussed as the next regulatory action.
4. Pool 1 – Anticipated Commission request to ECHA
| Subject of restriction proposal | Group restriction or number of substances to be restricted | Hazards in scope Confirmed or [suspected hazards] | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | State of play | |
|---|---|---|---|---|---|---|
| 4.1 | PVC and its additives | Group | Multiple hazard properties | A | Possible mandate to ECHA for a restriction dossier perparation as follow-up from the published investigation report on PVC and PVC additives. | TBD |
| 4.2 | Flame retardants (investigation report and potential restriction) | Group | TBD | I, P, C, A | Mandate to ECHA for an investigation report on flame retardants with a particular focus on aromatic brominated flame retardants to gather further information that can support the strategy on flame retardants. The investigation report was delivered by December 2024. The Commission will consider in Q3 2025 mandating ECHA to prepare a restriction dossier (scope to be decided) taking into account the investigation report and the ECHA's Regulatory strategy for flame retardants. | Q3 2025 (decision on mandate for restriction dossier) |
| 4.3 | Organophosphate flame retardants (OPFRs), (tris(2-chloroethyl) phosphate (TCEP), tris(2-chloro-1-methylethyl) phosphate (TCPP), tris(2-chloro-1-(chloromethyl)ethyl) phosphate (TDCP)) | 3 | CR | A | Withdrawn from RoI until clarity on hazard (US NTP study with TCPP was ongoing). The Commission will consider mandating a restriction dossier to ECHA after hazard clarification and taking into account the ECHA strategy on flame retardants and the ECHA investigation report on flame retardants. See also entry 4.2 on 'flame retardants' and entry 1.1 on 'CMRs in childcare articles'. DK indicated interest in collaboration in case of a mandate for a restriction. | TBD |
| 4.4 | Ortho-phthalates (C4-C6) | Group | R, ED | P, C, A | From ECHA's assessment of regulatory needs on phthalates. Possible restriction via Article 69(1) extending the existing restriction on 4 phthalates in articles. Restriction may cover in addition to phthalates on Annex XIV some other ortho-phthalates currently under the group work in ECHA. Ongoing study for developing the dossier for CLH and/or SVHC identification for around 40 C4-C6 ortho-phthalates could be used to complement the restriction. France is preparing a group entry for C4-C6 phthalates and plans to submit the CLH report in 2024, RAC opinion earliest September 2025. | Not before Q4 2025 |
| 4.5 | Hydrocarbyl siloxanes | Group | PBT/vPvB | (I), P, C, A | ECHA, Member States and COM are currently assessing the need for further regulatory management measures for a group of hydrocarbyl siloxanes (linear and branched aliphatic and aromatic siloxanes), as well as cyclic siloxanes and polymeric siloxanes notified under previous legislation (NONS). ECHA's Assessment or Regulatory Needs for hydrocarbyl siloxanes suggests restricting industrial, professional and consumer uses and articles based on PBT/vPvB properties. | Not before 2025 |
| 4.6 | Bisphenols (4,4'-isopropylidenediphenol (bisphenol A) and structurally related bisphenols (including derivatives) | Group | R, ED HH | I, P, C, A | COM and ECHA are currently assessing the need for further regulatory action, including restrictions, SVHC-identification or CLH for bisphenols and taking into account the work on the restriction dossier of bisphenol A and structurally related bisphenols (including derivatives) of similar concern for the environment (pool 1, entry 6.1). Depending on the outcome of these discussions, COM could request ECHA to prepare a restriction dossier that may complement the restriction of some bisphenols for environmental risks (pool 1, entry 6.1) due to concerns for human health as well as to cover additional bisphenols. | Timing not decided |
| 4.7 | Substances in thermal paper | Group | R, ED (maybe others) | P, C, A | Follow-up to restriction of bisphenol A in thermal paper, which asked to monitor the use of bisphenol S as a potential substitute in thermal paper. The possible restriction might target bisphenols but also other substances. Hence, the scope of substances might partly overlap with those in pool 1, entry 4.6. | Timing not yet decided. |
5. Pool 1 – ECHA Article 69.2
| Subject of restriction proposal | Group restriction or number of substances to be restricted | Hazards in scope Confirmed or [suspected hazards] | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | State of play | |
|---|---|---|---|---|---|---|
| 5.1 | Lead chromate; Lead sulfochromate yellow (C.I. Pigment Yellow 34); Lead chromate molybdate sulphate red (C.I. Pigment Red 104) | 3 | CR | A | Art 69(2) proposal to target other materials than PVC (Risks from these substances in PVC articles are covered by the existing restriction of lead in PVC). | Timing not yet decided |
6. Pool 1 – Member States
| Subject of restriction proposal | Group restriction or number of substances to be restricted | Hazards in scope Confirmed or [suspected hazards] | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | State of play | |
|---|---|---|---|---|---|---|
| 6.1 | 4,4'-isopropylidenediphenol (bisphenol A) and structurally related bisphenols (including derivatives) of similar concern for the environment DE | Group | ED for ENV | I, P, C, A | The German authorities have withdrawn their proposal to restrict bisphenols that have endocrine disrupting properties to the environment from the opinion-making process. They intend to re-submit an updated proposal to ECHA once theu have considered the information submitted by stakeholders during the six-month consultation and reworked the scope of the restriction. See also entry 4.6 in pool 1 regarding bisphenols and human health. | To be announced. |
| 6.2 | N-1,3-dimethylbutyl-N'-phenyl-p-phenylenediamine (6PPD) and related substances NL and AT | Group | Aquatic toxicity and R | A | Restriction is suggested by NL in the RMOA for 6PPD and related compounds in rubber tires and potentially other rubber goods. | Q1 2026 |
Appendix 1 – Restriction cases under opinion making, decision making or recently decided
Restriction cases in opinion making
Submitted restriction dossiers that are subject to opinion-making procedure in the ECHA Risk Assessment and Socio-Economic Assessment Committees are listed here.
| Restriction case | Link to the RoI |
|---|---|
| Per- and polyfluoroalkyl substances (PFAS) ('Universal PFAS restriction') | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18663449b |
| Certain chromium(VI) oxides, oxyacids and salts | https://echa.europa.eu/restrictions-under-consideration/-/substance-rev/80128/term |
Restriction cases under decision making
Restriction cases under decision making by the Commission are listed here: i.e. cases where ECHA’s committees have adopted their opinions and the Commission will provide, or has provided, a draft amendment to the list of restrictions in Annex XVII to REACH, but the final decision is yet to be taken in a comitology procedure with scrutiny involving the Member States and the European Parliament. Alternatively, in case no restriction is proposed by the Commission, a Commission Decision on the termination of the restriction procedure is yet to be adopted.
| Restriction case | Link to the RoI |
|---|---|
| Calcium cyanamide | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1824484f8 |
| Skin sensitising, irritative and/or corrosive substances in textile, leather, hide and fur articles | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e182446136 |
| Medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths within the range from C14 to C17 | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18682f8e1 |
| Lead in outdoor shooting and fishing | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1840159e6 |
| Terphenyl, hydrogenated | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1862d9f6a |
| Dechlorane Plus™ | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e184a168c4 |
| 2,4-dinitrotoluene | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e185d7af0b |
| Creosote and Creosote related substances | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e187fd0b65 |
| Substances in single-use baby diapers | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1840698d5 |
Restriction cases recently decided
Restriction cases for which, following the publication of the first Restrictions Roadmap of April 2022, a decision has been taken to amend the list of restrictions in Annex XVII to REACH or a Commission Decision to terminate a restriction procedure has been adopted.
| Restriction case | Decision | Link to the RoI |
|---|---|---|
| Octamethylcyclotetrasiloxane (D4); Decamethylcyclopentasiloxane (D5); dodecamethylcyclohexasiloxane (D6) | Voted in REACH Committee – under scrutiny by EU Parliament and Council | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e181a55ade |
| Microplastics | Commission Regulation (EU) 2023/2055 of 25 September 2023 | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18244cd73 |
| Lead and its compounds in PVC | Commission Regulation (EU) 2023/923 of 3 May 2023 | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e180a40af7 |
| Formaldehyde and formaldehyde releasers | Commission Regulation (EU) 2023/1464 of 14 July 2023 | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e182439477 |
| Cobalt carbonate; cobalt di(acetate); cobalt dichloride; cobalt dinitrate; cobalt sulphate | Commission Decision of 8.4.2022 to terminate the restrictions process | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e181d575c8 |
| Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds | Regulation (EU) 2022/2400 of 23 November 2022 and Commission Delegated Regulation (EU) 2023/1608 of 30 May 2023 (Listed under the Stockholm Convention and listed under the POPs Regulation) | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1827f87da |
| Undecafluorohexanoic acid (PFHxA), its salts and related substances | Commission Regulation (EU) 2024/2462 of 19 September 2024 | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18323a25d |
| Substances containing polycyclic aromatic hydrocarbons (PAHs) in clay targets for shooting | Commission Regulation (EU) 2025/660 of 1 April 2025 | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e186716202 |
| N,N-dimethylacetamide (DMAC); 1- ethylpyrrolidin-2-one (NEP) | Commission Regulation (EU) 2025/1090 of 2 June 2025 | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1844d552a |
| Per- and polyfluoroalkyl substances (PFASs) in firefighting foams | Voted in REACH Committee – under scrutiny by EU Parliament and Council | https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1856e8ce6 |
Annex II – Groups of substances under assessment with a restriction as a potential regulatory management option
Annex II lists substances that are under assessment with restrictions as a potential regulatory management option. For the time being, no decision has yet been taken on whether a restriction will be prepared, nor on who submits the dossier (a Member State, or ECHA on behalf of the Commission). Annex II also serves as a list for authorities to develop their priorities for future restriction dossiers. Similar as for pool 1, for some (groups of) substances classification under the CLP Regulation or SVHC-identification under REACH might be the next regulatory action, which is then potentially followed by a restriction.
Substances are listed in Annex II for different reasons. It includes (groups of) substances for which:
- ECHA’s Assessment of Regulatory Needs suggests a restriction as a potential regulatory management option;
- ECHA, in accordance with Art. 69(2), identified a restriction as a regulatory follow-up action;
- Preliminary assessments of Member States, the Commission or working groups involving Member States, the Commission or ECHA suggest that a restriction could potentially be an adequate regulatory management option;
- Review reports or previous assessments indicate that revising a restriction could be necessary (e.g. lead in consumer articles; nickel in articles intended to come into direct and prolonged contact with the skin).
1. Substances under assessment with restrictions as a potential regulatory management option
| Subject of potential restriction proposal | Group restriction or number of substances to be restricted | Known or potential hazards | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | |
|---|---|---|---|---|---|
| 1.1 | Formaldehyde and formaldehyde releasers | Group | C | A | Potential occupational risk to workers not covered by the Binding Occupational Exposure Limits (BOEL) e.g. professional and self-employed. Follow up to review report to be considered. |
| 1.2 | Lead in consumer articles | Group | R | A | Follow-up to review report not a priority due to current state of play of alternatives |
| 1.3 | Skin sensitisers in consumer mixtures | Group | Skin Sens | C | Investigative work has begun by a group of Member States |
| 1.4 | Hydrocarbylphenols (formerly the entry was called "Substances containing 4-tert-butylphenol (4-TBP), 4-nonylphenol and other alkylphenols") | Group | ED, R, (PBT) | I, P, C, A | The ECHA's Assessment of Regulatory Needs for hydrocarbylphenols suggests restriction (potentially as a stepwise approach) for certain hydrocarbylphenol substances as such, substances containing hydrocarbylphenols as minor constituents, precursors that degrade to hydrocarbylphenols and other substances potentially relevant due to structural similarity. As a first step, it is suggested to focus on hydrocarbylphenols with confirmed environmental effects (ED, ENV, and/or PBT/vPvB). |
| 1.5 | Petroleum substances used in consumer and/or professional mixtures | Group | PBT, CMR | P, C | Scope to be further clarified taking into account the need for data generation, CLH, SVHC-identification or candidate listing. |
| 1.6 | Substances in fertilisers | Group | To be defined | I, P, C | Following the results of a COM study, it may be discussed whether there is need for further regulatory action and the possible substances in scope of such action. Could include contaminants in phosphate fertilisers and possibly other substances intentionally used in fertilisers such as pyrazoles (see also entry 3.1 of Annex II) |
| 1.7 | PAHs | Group | CM, PBT | P, C, A | ECHA's investigation report of 14 June 2023 does not recommend preparing an Annex XV restriction report on PAHs in rubber granules and mulches in loose form in domestic applications and considers that a holistic approach to PAHs would be the most effective way to regulate these substances. |
| 1.8 | Formamide | 1 | R | A | ECHA’s Assessment of Regulatory Needs for aliphatic primary amides concluded that the substance formamide may need to be restricted in a similar way as for toys. The substance may be released from ethylene vinyl acetate (EVA) foam articles (e.g. fitness mats, puzzle mats). The concern is specific to toys and childcare articles. Any presence of formamide in childcare articles is expected to be addressed through the upcoming restriction for CMRs in childcare articles (see entry 1.1 of Annex I). |
| 1.9 | Nickel in articles intended to come in direct and prolonged contact with the skin | Group | Skin Sens | A | In 2019, ECHA and COM decided to discontinue the work on a guideline on Annex XVII entry 27 on nickel and its compounds. At CARACAL 29, COM expressed its intention to assess the possibility to request ECHA to review the current restriction as regards points b) and the associated point c). The risks posed by nickel in contact with the skin should be reassesed, in particular with a view to potentially modifying the scope by removing reference to direct and prolonged contact with the skin. The potential review of entry 27 on nickel and its compounds is regarded as being low priority. |
| 1.10 | CMRs in textiles | Group | CMR | ECHA's Assessments of Regulatory Needs regularly suggest adding substances to REACH Appendix 12 through Article 68(2) and reviewing the current concentration limits (e.g. on quinoline). This would expand the current list of substances or their limits that are restricted in textiles through entry 72 of REACH Annex XVII. | |
| 1.11 | Tetrahydrofuran (THF) in consumer products | 1 | Carc cat. 2 | C | An RMOA from Germany suggested to consider restricting THF in glues that are used by consumers indoors21 . Following further assessment of publicly available data, information received in a stakeholder consultation and data from the German product register, which has been looked into after finalising the RMOA, the German CA has come to the conclusion that the substance is of less relevance to consumers than originally anticipated. There are only few consumer products on the market and products containing the substance are rarely used in DIY applications. Germany therefore refrains from further pursuing the restriction route, while still looking into the harmonisation of the classification and labelling as indicated in their RMOA (although with low priority). |
| 1.12 | Substances in fibre form (excluding asbestos) | Group | Carc. | An RMOA from Germany suggests restricting fibre materials (as substances as such, in mixtures or articles) with the potential to release biopersistent fibre dusts fulfilling the WHO criteria. | |
| 1.13 | Phthalic anhydrides and hydrogenated phthalic anhydrides | Group | Resp. Sens. | P, C (and I) | Most of the substances in the group (26 out of 36) have a harmonised classification as respiratory sensitiser. ECHA’s Assessment of Regulatory Needs for phthalic anhydrides and hydrogenated phthalic anhydrides23 considers restriction as a potential risk management option. A possible restriction may target substances in mixtures handled by professional users and some consumer uses (e.g. bi-component adhesives, hardener for epoxy resins). |
| 1.14 | Photoinitiators | Group | R | P, C, A | 4 substances with CLH cover most of the current volumes (further substances may be included but need CLH first). ECHA’s Assessment of Regulatory Needs for photoinitiators (benzoyl radical precursor type)24 considers that possible restriction may target professional uses and the presence in articles reported for several substance due to use in e.g. coatings and paints, inks and toners, and paper and board treatment products. |
| 1.15 | Branched carboxylic acids and their salts (2- ethylhexanoic acid and salts + other acids and salts with reprotox properties) | Group | R | I, P, (C), A | 2-ethylhexanoic acid and its salts already have CLH for Repr. 1B (covering 16 group members) and 3,5,5- trimethylhexanoic acid and its salts have a CLH intention for Repr. 1B (covering 5 group members). ECHA’s Assessment of Regulatory Needs for branched carboxylic acids and their salts25 considers restriction as a potential regulatory management option, which may target certain industrial uses, professional use and articles. |
2. ECHA Article 69.2
| Subject of potential restriction proposal | Group restriction or number of substances to be restricted | Known or potential hazards | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | |
|---|---|---|---|---|---|
| 2.1 | Phenolic benzotriazols UV327, UV-350 and UV-32026 (Entries 52-54 of Annex XIV) | Group | PBT, vPvB | A | Uses of the substance in articles. An Annex XV restriction dossier will be prepared if appropriate. |
3. Groups where CLH or Candidate Listing to be carried out with restriction as suggested risk management
| Subject of potential restriction proposal | Group restriction or number of substances to be restricted | Known or potential hazards | Uses in scope: Industrial (I), Professional (P), Consumer (C), Articles (A) | Additional information | |
|---|---|---|---|---|---|
| 3.1 | Pyrazoles | Group (6) | R, ED HH, PM | P, C | The need for further regulatory risk management measures (e.g. restriction) is under discussion, focusing on their use as a fertiliser and potential reprotoxic and ED HH properties as well as possible persistency and mobility. See also ECHA's Assessment of Regulatory Needs for pyrazoles. 3-MP (EC 215-925-7) already has harmonised classification as Repr. 1B and proposals for CLH have been submitted for four substances. |
| 3.2 | Simple manganese compounds | Group (15) | R, STOT RE, Neurotox. | P, C, A | The need for further regulatory risk management measures (e.g. combination of authorisation and restriction) is under discussion, focusing on subgroups ‘Simple inorganic salts, oxides and manganese metal’ and ‘Permanganates’. Might apply to other substances in the group following steps taken to generate data in order to clarify the hazard. See also ECHA’s Assessment of Regulatory Needs for Simple manganese compounds |
| 3.3 | Simple vanadium compounds | Group (24) | CMR, STOT RE | I, P, C, A | Potential need for an exposure limit for workers under OSH (occupational health and safety) or restriction under discussion as well as a completion of CLH classification mainly for carcinogenicity. See also ECHA’s Assessment of Regulatory Needs for Simple vanadium compounds |
| 3.4 | Acrylates and methacrylates | Group | Skin Sens, Resp. sens. | The need for further regulatory risk management measures (e.g. restriction) under discussion for all acrylates and methacrylates in the group that can be identified as skin sensitisers and/or respiratory sensitiser. See also ECHA’s Assessment of Regulatory Needs for Acrylates and methacrylates. May be covered by the 'skin sensitisers in consumer mixtures' entry above. | |
| 3.5 | Imidazoles | Group | R | P | ECHA's Assessment of Regulatory Needs for imidazoles considers, as first step, a completion of CLH classification for EC 210-484-7 as Repr. 1B (also further members of the group are proposed for CLH). In case of CLH classification, regulatory risk management measures may be considered for the professional uses of 3 substances (EC 206-019-2, 213-234-5, 210-484-7), such as coatings and paints, polymer preparation (roller application, non-industrial spraying, hand mixing). |
| 3.6 | Resin and rosin acids and their derivatives | Group | R | (I), P, (C), (A) | ECHA's Assessment of Regulatory Needs for resin and rosin acids and their derivatives considers, as first step, completion of CLH classification for the potential reproductive toxicity of subgroups or individual substances where there is already sufficient data for classification. In case of CLH classification, regulatory risk management measures may be considered for the substances as such or in mixtures used by professionals. |
| 3.7 | Aralkylaldehydes | Group | R | CLH is ongoing for 2 substances and is suggested as a first step for several members. ECHA’s Assessment of Regulatory Needs for aralkylaldehydes suggests to consider, in case of CLH classification, regulatory risk management measures for 7 substances as such or in mixtures used by professionals (e.g. as fragrance in polishes and waxes, air care products, washing and cleaning products, etc.). |