On August 31, 2026, the European Commission formally released the latest version of the REACH Restrictions Roadmap. Finalized following discussions at the CARACAL-58 meeting on July 2, 2026, the document comprehensively maps the EU's progress on restricting high-risk chemicals, current decision-making status, and future regulatory directions. CIRS Group offers the following interpretation of this roadmap.
Main Contents
I. Adopted Restriction Measures (Table 1)
Since April 2022, the EU has adopted 15 restriction decisions, mainly covering:
- Substances of Very High Concern (SVHC): 2,4-Dinitrotoluene (carcinogen), DMAC/NEP (reproductive toxicity), formaldehyde and releasing substances, 29/19 groups of newly added CMR (carcinogenic, mutagenic, reprotoxic) substances
- Persistent Organic Pollutants (POPs): Dechlorane Plus, PFHxS (managed under the POPs Regulation)
- PFAS Family: Use of PFAS in firefighting foams; use of PFHxA in textiles, food contact materials, cosmetics, etc.
- Specific Products: Microplastics; siloxanes (D4/D5/D6); lead in PVC; polycyclic aromatic hydrocarbons (PAHs) in clay targets for shooting
II. Restrictions Under Decision-Making (Table 2)
The ECHA committees have completed consultations, and committee drafts have been submitted or are being prepared, awaiting final review by Member States and the European Parliament. A total of 9 items:
- Lead-related: Lead in fishing tackle; lead in ammunition (both received positive votes in the REACH Committee on April 29, 2026, entering the review period)
- New CMR Substances: 26 groups of new harmonized CMR 1A/1B substances (review period to be initiated shortly)
- Others: Creosote-treated wood; hydrogenated terphenyl; calcium cyanamide; CMR substances in child care products; skin sensitizing/irritant/corrosive substances in textiles/leather
III. Restrictions at ECHA Consultation Stage (Table 3)
Currently, 3 restriction proposals are under consultation by ECHA's Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC), expected to be completed in 2026:
- Octocrylene: Restriction at concentrations ≥0.001% in finished cosmetic products
- PFAS "Universal Restriction": Covering manufacture, placing on the market, and use (industrial, professional, and consumer uses)
- Certain Hexavalent Chromium Compounds: Restriction on industrial uses
IV. Preliminary Work for Potential Future Restrictions (Annexes I-III)
Annex I (Rolling List of Potential Future Restriction Substances)
Annex I lists 13 substances (groups) in early preparation stages that may be incorporated into REACH restrictions in the future, divided into two categories:
- Category a: Already included in the Registry of Intentions (RoI) or the European Commission has requested ECHA to prepare restriction dossiers;
- Category b: Under in-depth assessment by ECHA, Member States, or the Commission; may first undergo CLP classification or SVHC identification before proceeding to restriction.
Key substances:
- Non-polymeric aromatic brominated flame retardants (dossier expected December 2026)
- Environmentally endocrine-disrupting bisphenols (expected March 2027)
- 6PPD and related p-phenylenediamine substances in rubber tires (expected March 2027)
- PVC additives (phthalates C4-C6, organotins), organophosphorus flame retardants, alkyl siloxanes, etc.
Annex II (Under Assessment, Restriction as a Potential Management Option)
Covers 21 substance groups, including lead in consumer products, formaldehyde, nickel (skin contact), PAHs, formamide, pyrazoles, manganese/vanadium compounds, etc. Some substances may first undergo CLH classification or SVHC identification before entering the restriction procedure.
Annex III (Post-Sunset Date Assessment of Authorized Substances, REACH Article 69(2))
Screening assessment of 59 substances already listed in the Authorization List (Annex XIV) after their sunset dates. Conclusions include:
- No restriction needed: e.g., musk xylene, MDA, trichloroethylene, arsenic acid, etc.
- Restrictions already adopted: e.g., 4 phthalates including DEHP, PAHs in clay targets
- Restrictions under consideration: e.g., TCEP (grouped with TCPP/TDCP), UV-320/327/350, C4-C6 phthalates, etc.
ChemRadar Insights
The latest REACH Restrictions Roadmap is not merely a regulatory checklist—it is an industrial transformation timetable. From the 13 adopted restrictions, to the 9 draft proposals in the final stretch, to the dozens of high-risk substances queued in the annexes, the EU is accelerating the phase-out of the most harmful chemicals through "rolling review and grouped control." Enterprises should embed "substitution-first" into their core strategies. CIRS Group will continue to monitor REACH-related regulatory developments and provide timely compliance support for enterprises.
CIRS Services
- EU REACH Only Representative (OR) Services
- EU REACH Inquiry Services
- EU REACH Registration Services
- EU REACH Lead Registrant (LR) Services
- Lead Registrant Dossier Evaluation Compliance Response
- Consortium Management
- Joint Registrant Dossier Evaluation Compliance Response
- Data Gap Analysis Services
- Chemical Safety Report (CSR) Preparation Services
- Extended Safety Data Sheet (eSDS) Preparation Services
- Supply Chain REACH Compliance Management Platform Services
- SVHC Notification Services
- Authorization Application Services
- PPORD Notification Services
Further information
