
REACH Revision Uncertainty Grows as Comitology Route Gains Attention
The Dutch government says a full REACH revision remains its preferred route, even if the EU shifts towards comitology-driven annex changes.

A recent report has flagged 15 methylenedianilines for potential regulatory risk management, including possible future restrictions. Used in polymer production, adhesives, and coatings, these industrial chemicals raise concerns over carcinogenicity, mutagenicity, and environmental persistence—prompting ECHA to recommend further scrutiny and precautionary measures.
While no formal restrictions have yet been proposed, the report signals that the substances could face tightened controls under REACH if hazards are confirmed.
Methylenedianilines are a group of structurally similar aromatic amines primarily used by industrial and professional users in polymer manufacturing. Several substances in this group, such as 4,4'-methylenedianiline (MDA) and MOCA, are already classified as carcinogenic and included in REACH’s Authorisation List.
ECHA’s grouping approach, based on structural similarity and hazard profiles, highlights widespread risks: five substances are already identified as Substances of Very High Concern (SVHCs), and others display potential for skin sensitisation, repeated dose toxicity (STOT RE), or environmental harm such as aquatic toxicity and possible PBT/vPvB behaviour.
While no immediate legislative action has been taken, ECHA recommends that the group of substances—particularly those already flagged for genotoxic carcinogenicity—be considered for restriction if further hazard confirmation is obtained. The concern stems not only from workplace exposure but also from residual content in finished articles that may lead to uncontrolled release during service life.
Suggested next steps include compliance checks, data generation, and hazard classification. Where hazards are confirmed, REACH restrictions could be used to manage exposure from both imported articles and professional uses, which are often less controlled than industrial settings.
The implications extend well beyond chemical manufacturers. Stakeholders across construction, automotive, electronics, and consumer goods sectors should assess the presence of these substances in their value chains. ECHA’s findings emphasise the need for proactive inventory management and supplier engagement—even in the absence of formal legislative proposals.
Professionals are advised to monitor the development of these assessments closely, as formal regulatory steps such as harmonised classification or SVHC identification could soon follow.




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