REACH Annex XVII - Restriction of octamethylcyclotetrasiloxane (D4), decamethylcyclopentasiloxane (D5) and dodecamethylcyclohexasiloxane (D6)

The COMMISSION REGULATION (EU) 2024/1328 has changed the entry 70 in Annex XVII of Regulation (EC) No 1907/2006 (“REACH” regulation). 

Let’s review what this news mean for you shall we? Here are three things we’ll look and will help you move forward easily:  

• Which substances this affects 

• What are the restrictions you need to know about 
  
  
• How you can prepare for these changes.  

Now, let’s look first which substances are affected by these regulations. 
 
We’re talking about three of them. I’ve listed them here, including their CAS number, to make it easier for you: 

• Octamethylcyclotetrasiloxane (D4) (CAS No 556-67-2, EC No 209-136-7) 

• Decamethylcyclopentasiloxane (D5) (CAS No 541-02-6 EC No 208-764-9) 

• Dodecamethylcyclohexasiloxane (D6) (CAS No 540-97-6 EC No 208-762-8) 
   

Now, let’s look at the restriction for placing these substances on the market and use of them.  Here are restrictions imposed: 

1. Shall not be placed on the market 

(a) as a substance on its own; 

(b) as a constituent of other substances; or 

(c) in mixtures; 
in a concentration equal to or greater than 0,1 % by weight of the respective substance after 6 June 2026.

    2. Shall not be used as a solvent for the dry cleaning of textiles, leather and fur after 6 June 2026.

However, as is it the case with many REACH restrictions, they also offer plenty of derogations. You can find them all in the text of the Regulation. 
 
Now that we have gone through the restrictions, let’s see how you can best prepare for these changes. 
 
Firstly, you need to identify if the concerned substances are present in your products. If you are a distributer, you should get this information from higher up the supply chain. 
 
Secondly, check if your products fall under derogation with later deadlines than 6 June 2026, or if they are exempted altogether. 
 
Thirdly, if your products fall under the derogation, then you can follow the derogation. 
 
If no derogation can be applied to your products, then you may not use them or place them on the market anymore after 6 June 2026, as specified in the restriction. 
 
A final thought for you. 

If you feel you'd be better off with people who understand chemical regulatory and its realities than people who tell you how creative they are, why not drop me a line at luka.rifelj@bens-consulting.eu.