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Regulation on the restriction of diisocyanates

The European Commission has amended Annex XVII to the REACH Regulation (new entry 74) with Regulation (EU) 2020/1149, which entered into force on 24 August 2020.
After 24 August 2023 diisocyanates may not be used either as substances on their own, as a constituent in other substances, or in mixtures for industrial and professional use(s) unless

a) the concentration of diisocyanates individually and in combination is less than 0.1 % by weight, or

b) the employer or self-employed ensures that industrial or professional users have successfully completed training on the safe use of diisocyanates prior to the use of the substance(s) or mixture(s).

The employer must document the certification or proof of the training's successful completion. Renewed training is mandatory at least every five years.
The supplier of the substance(s) or mixture(s) is responsible for making sure the employer or self-employed person knows about the mandatory training requirement. For this purpose, the supplier has to ensure the placing of the following statement on the packaging in a manner that is visibly distinct from the rest of the label information: "As from 24 August 2023 adequate training is required before industrial or professional use". Furthermore, the supplier has to ensure the provision of training materials and courses for the recipient of the substance(s) or mixture(s).

The inclusion of this restriction into Annex XVII to the REACH Regulation has put in place minimum requirements concerning training courses that the employer must implement. Transfer into national law is not necessary for this because the provisions set out in EU regulations apply directly in the Member States. The training will not relieve the parties concerned of their obligation to comply with the legal stipulations that relate to the provision of information under Section 14 of the Hazardous Substances Ordinance (Gefahrstoffverordnung, GefStoffV).
The Committee on Hazardous Substances (Ausschuss für Gefahrstoffe, AGS) will, among other things, revise the Technical Rule for Hazardous Substances TRGS 430, "Isocyanates - Risk assessment and protective measures", in the light of the changes that have been introduced.

The member companies of the European Diisocyanate & Polyol Producers Association (ISPOA) and the European Aliphatic Isocyanates Producer Association (ALIPA) have committed to jointly draw up the training concept and training materials, and make the materials accessible on an Internet platform. The rollout and testing of the training concept are due to begin in selected Member States in 2021. The aim is for the training materials to become available in all the EU's official languages in 2022. Further information on the training materials and training courses are available on ISOPA and ALIPA's websites.

The Fachverband Schaumkunststoffe und Polyurethane e.V. (FSK) represents the users of diisocyanates in the foam plastics and plastics processing industry. The FSK will initially provide training materials for Germany, Switzerland and Austria, and conduct training courses (e-learning, face-to-face and hybrid courses). More information on the training offer can be found at the FSK website.

Note: Developing the training concept and training materials is the sole responsibility of the producers' associations.


Dr Andreas Lüdeke

Division 4 Hazardous Substances and Biological Agents

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