EU REACH Restriction and Mandatory Safety Training Requirement for Diisocyanates
ENFORCEMENT TIMELINE
Full application in force since August 24, 2023 (mandatory training requirement)
Overview
The European Commission adopted Commission Regulation (EU) 2020/1149, amending REACH Annex XVII, introducing strict restrictions on diisocyanates (TDI, MDI, HDI, and others) — substances widely used as raw materials in polyurethane foam, paints, adhesives, sealants, and coatings — to prevent respiratory sensitization and asthma risk.
Since August 24, 2023, workers and companies handling diisocyanates above 0.1% by weight, alone or in mixtures, for industrial or professional use, are legally prohibited from using or working with the substance unless they have first completed and passed accredited Mandatory Safety Training. Product containers must also carry a specific label prompting completion of the training.
Enforcement Timeline
August 3, 2020: The amending Regulation (EU) 2020/1149 is published in the Official Journal.
February 24, 2021: A warning label stating that "appropriate training is required before use from August 24, 2023" becomes mandatory on product containers and packaging.
August 24, 2023: Completion of safety training becomes fully mandatory for industrial and professional workers (renewal required every five years).
Business Impact
Chemical, adhesive, and paint manufacturers, and construction and automotive contractors, must maintain and manage training records for workers handling polyurethane-based adhesives and paints at EU sites, and confirm that Safety Data Sheets (SDS) and labels comply with the restriction's requirements.