On August 4, 2020, the European Union published (EU) 2020/1149 in its official bulletin, adding a restriction clause on diisocyanates in Annex XVII, Item 74 of the REACH regulation, officially including diisocyanates in the REACH regulation restriction list due to their respiratory sensitization. The regulation will come into effect on the 20th day after its publication in the official gazette and will be directly applicable to all member states.

Diisocyanate, O=C=N-R-N=C=O, R is an aliphatic or aromatic unit of unspecified length, mainly used to manufacture polyurethane products, such as foam, sealant, paint, etc.

Restrictive conditions

After August 24, 2023, diisocyanates shall not be used in industrial and occupational applications alone, in the form of other substance components or mixtures, unless:

a. Diisocyanate usage concentration is less than 0.1% (w/w%);

b. Ensure that personnel handling diisocyanates or conducting supervisory work have received safety training on the use of diisocyanates.

2. After February 24, 2022, diisocyanates shall not be placed on the EU market for industrial and occupational purposes, either alone or in the form of other substance components or mixtures, unless:

a. Diisocyanate usage concentration is less than 0.1% (w/w%);

b. Suppliers must ensure that downstream users meet training requirements and add a special statement on product packaging stating: 'From August 24, 2023, strict training must be conducted before industrial or occupational use.'.

Response suggestions

With the continuous updating of the REACH regulation restrictions, enterprises are facing more and more control requirements. Enterprises need to improve their risk awareness of their products. After the substance is listed in the restrictions, enterprises within the control scope need to actively respond. It is recommended that enterprises investigate their supply chain as soon as possible to cope with regulatory changes calmly.