The European Commission amended Annex XVII of the REACH Regulation (new entry 74) with Regulation (EU) 2020/1149, which entered into force on August 24, 2020. After 24 August 2023, diisocyanates may no longer be used as substances on their own, as constituent in other substances or in mixtures for industrial and professional uses unless:
- the concentration of diisocyanates individually and in combination is less than 0.1% by weight; or
- the employer or self-employed person ensures that industrial or professional users have successfully completed training on the safe use of diisocyanates before the substance(s) or mixture(s) are used.
The employer must document the certification or proof of successful completion of the training document.
Renewed training is required at least every five years.
Training on how to handle diisocyanates correctly
It is the employer's responsibility to ensure that his employees are properly trained. He must demonstrate that his personnel are qualified upon request by a competent authority. Unskilled workers should not be allowed to use these products by their employers.
To this end, we provide for the placement of the following statement on the packaging in a visibly distinguished manner from the rest of the label information: "by August 24, 2023, for industrial or professional use, appropriate training must have been completed.
Section 2 of the MSDS details the labelling requirements. It will contain hazard pictograms, hazard statements or a mixture of the two. (Example below, for training purposes only)
Picture 1 MSDS Labelling requirement
Safety Data Sheets
A Safety Data Sheet (SDS) is a mandatory document for chemical substances and mixtures that are classified as hazardous under the CLP Regulation. This includes chemicals that have physical, health, or environmental hazards.
Manufacturers and importers of chemicals must also include information about any relevant restrictions outlined in the REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) Regulation within the SDS. Specific restrictions on the production, market placement, or utilization of certain hazardous substances can be found in REACH Annex XVII.
Section 15 of the safety data sheet will indicate whether the diisocyanates restriction REACH Annex XVII 74 is applicable. It will contain the crucial statement: " As from August 24 2023 adequate training is required before industrial or professional use."
For more details about the specific diisocyanate type, please refer to section 3 of the safety data sheet. This section offers in-depth information about the chemicals present in the formulation that contribute to the hazard classification as defined in REACH ANNEX II. To gain an understanding of the overall hazards associated with the mixture, please consult section 2 of the safety data sheet.
The following products are subject to limitation 74:
|57104.2.5||GRAFFITISHIELD POLYCOAT 2.5L||>0.1|
|9720.B.4.5||FAST BALCONY SYSTEM GRIT COAT BASE||>0.1|
|401.BC.12.5||DACFILL PU BASECOAT 12,5L||>0.1|
|402.1.12.5||DACFILL PU TOP.SLATE GREY 12,5||>0.1|
|402.2.12.5||DACFILL PU TOP.DOVE GREY 12,5||>0.1|
|403.1.12.5||DACFILL PU FIBRES 12.5L||>0.1|
|403.1.5||DACFILL PU FIBRES 5L||>0.1|