Isocyanaten restriction

Diisocyanates: what are they?

Diisocyanates, commonly referred to as isocyanates, are a group of chemicals extensively used in urethane chemistry due to their high reactivity.

They are often used in the form of two-component systems, which are mixed together during application and readily react to achieve the desired results, such as foams, coatings, etc. The use of these isocyanates is widespread in both professional and consumer applications, including products like (PUR) foam, coatings, adhesives, sealants, and more.

Commonly used diisocyanates include: methylene diphenyl diisocyanate (MDI); toluene diisocyanate (TDI); hexamethylene diisocyanate (HDI); methylene dicyclohexyl diisocyanate or hydrogenated MDI (HMDI); and isophorone diisocyanate (IPDI).

What are the hazards?

Isocyanates pose the risk of sensitization through inhalation. If someone is exposed to a dose that is sufficiently high (the level of dose often varies from person to person), they may develop an allergy. Once the allergy develops, even exposure to very low concentrations of the substance can lead to asthmatic symptoms.

The restriction

The restriction included in ANNEX XVII of REACH consists of two parts:

Diisocyanates..."Shall not be used as substances on their own, as constituents of other substances, or in mixtures for industrial and professional uses after 24 August 2023, unless:

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

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

Diisocyanates..."Shall not be placed on the market as substances on their own, as constituents of other substances, or in mixtures for industrial and professional uses after 24 February 2022, unless:

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

b) the supplier ensures that the recipient of the substance(s) or mixture(s) is provided with information on the requirements referred to in point 1(b), and that on the packaging, clearly distinguishable from the other information on the label, the following text is displayed: "Adequate training must have been completed for industrial or professional use by 24 August 2023."

The training

In addition to the ban, the restriction also specifies the situations where the training requirement applies and the criteria the training must meet. It includes an extensive list of topics that must be covered in the training and requires certification with a renewal of at least every 5 years.

The training or training materials must be provided by the supplier of the product in the official language of the country where the product is delivered.

But how?

Since the restriction (and even before), the industry has been trying to make working with isocyanates safer. A dedicated website has been set up for this purpose, and the development of training programs is being jointly set up by ISOPA (European trade association for producers of aromatic diisocyanates and polyols) and ALIPA (European Aliphatic Isocyanates Producers Association).

It is still more than a year until August 2023 when the training should be available, and professional and industrial users must be educated. The development and implementation of the training programs are well underway and are likely to be completed before that time.

However, February 2022 is rapidly approaching, and before that, labels will need to be adjusted to ensure compliance with REACH legislation. It may only be one sentence, but it must also be in every language of all the countries where the product is sold. This means that this one sentence can take up a lot of space of the product label.

The restriction: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R1149

Sector website: http://www.safeusediisocyanates.eu