On 8 August 2025, the European Commission adopted an extension to the existing CMR (Carcinogens, Mutagens, Reprotoxicants) restriction under REACH Annex XVII, entries 28–30. (annex below). This update adds a number of newly classified CMR category 1B substances to Appendices 2, 4, and 6 of Annex XVII.

Effective date:
The new restrictions will apply from 1 September 2025.

The mechanism is the same as the one behind the CMR textile and footwear restriction you are already familiar with (the “33 CMR” list under Article 68(2)). This means:

• Articles, including textiles, footwear, and sports goods, must not be placed on the market for the general public if they contain these substances above the specified concentration limits (generally 0.1% w/w).

• The update covers substances used in printing inks, coatings, adhesives, plastics, synthetic leathers, rubber parts, and electronics potentially in sports equipment.

Examples of new substances potentially relevant to our sector include:

• Tetrabromobisphenol A (TBBPA) – flame retardant in electronics, epoxy resins.
• Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide (TPO) – UV photoinitiator in inks/adhesives.
• N,N-dimethyl-p-toluidine (DMpT) – curing accelerator in acrylic adhesives.
• 4-Methylimidazole – catalyst in PU foams and epoxy systems.
• Dibutyltin compounds – stabilisers in PVC and synthetic leather.
• Bisphenol AF (BPAF) and related phosphonium salts – specialty resins/electronics.
• Diuron – biocide in certain coatings.

FESI recommands members to :

1. Review the attached list of substances and assess if they are present in their finished articles.
2. Review supply chains for potential use of these substances in articles, mixtures, or processing chemicals.
3. Request updated declarations/SDS from suppliers to confirm compliance with Annex XVII.
4. Identify high-risk areas:

• Printing/decoration (UV inks, coatings)
• Adhesives & composites (epoxy, PU)
• PVC & coated fabrics (organotin stabilisers)
• Rubber components (antioxidants)
• Electronics in gear/wearables (TBBPA, BPAF)

5. Recommended to plan substitutions if any of the listed substances are present above 0.1% w/w.
6. Keep records to demonstrate due diligence in case of market surveillance.

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