Quick answer. Since 24 August 2023, EU REACH restriction entry 74 (Commission Regulation (EU) 2020/1149) bans the industrial and professional use of diisocyanates above 0.1% w/w unless the worker has completed mandatory training. For exporters shipping polyol systems, prepolymers, or isocyanate-containing products into the EU, this means your Safety Data Sheet (SDS) must carry the statutory training statement, your label must show the correct hazard and supplemental EUH statements, and your customer must be able to prove training before use. Non-compliant shipments risk customs holds and rejected consignments.
What the EU diisocyanate restriction actually requires
The restriction was introduced through ECHA's diisocyanates restriction and added as entry 74 of Annex XVII to REACH. It is not a ban on the substances themselves — it is a use condition tied to worker training. The trigger is a total monomeric diisocyanate concentration greater than 0.1% by weight (individually or combined). Above that threshold, three obligations apply along the supply chain:
- Training obligation: anyone using the product industrially or professionally must have successfully completed training on the safe use of diisocyanates, refreshed at least every five years.
- Supplier obligation: the supplier placing the product on the EU market must ensure the recipient is provided with training information and that the required statement appears on packaging.
- Documentation obligation: proof of training must be available and traceable.
For a manufacturer exporting MDI- or TDI-based polyol systems, prepolymers, adhesives, or two-component foam kits, this is a downstream duty that lands on your paperwork long before your goods reach the customer's shop floor.
Which products fall inside the 0.1% threshold
The practical question for procurement teams is simple: is my product in scope? The table below shows how common polyurethane raw materials typically map against the restriction. Confirm every case against your own batch analysis.
| Product type | Free monomeric diisocyanate | In scope of entry 74? | Statutory statement on label/SDS |
|---|---|---|---|
| Polyether/polyester polyol (pure) | None | No | Not required |
| Amine / tin catalyst | None | No | Not required |
| Silicone surfactant | None | No | Not required |
| Formulated ISO / B-side (MDI blend) | > 0.1% w/w | Yes | Required |
| TDI / MDI prepolymer | Usually > 0.1% w/w | Yes (verify) | Required |
| Low-monomer prepolymer | < 0.1% w/w | No | Not required |
Note the asymmetry: the polyol side of a two-component system is often out of scope, while the isocyanate side is almost always in scope. If you ship both components as a kit, the isocyanate component drives the labelling requirement for the whole consignment. Our polyol systems and catalysts are supplied with component-specific SDS documentation so buyers can classify each stream correctly rather than over-labelling the entire kit.
The mandatory statement on packaging and SDS
Entry 74 prescribes an exact wording that must appear on the packaging of any in-scope product: "As from 24 August 2023 adequate training is required before industrial or professional use." This is a legally required verbatim statement, not a paraphrase. It must be distinguishable from other label information.
On the SDS side, the training obligation and safe-use conditions need to be reflected in the relevant sections (notably Section 1 identified uses, Section 8 exposure controls, and Section 15 regulatory information). The SDS structure itself follows REACH Annex II, and hazard classification follows the CLP Regulation. Diisocyanates are respiratory sensitisers and skin sensitisers, so the correct supplemental hazard statements — EUH204 ("Contains isocyanates. May produce an allergic reaction") among them — must be carried through. Occupational health authorities such as OSHA and NIOSH (CDC) document isocyanate-induced occupational asthma as the primary driver behind these controls, which is why regulators treat the training requirement as non-negotiable rather than advisory.
Export compliance workflow: from factory to EU customs
A robust exporter checklist keeps consignments moving. We recommend building the following gate into your order process for any EU-bound shipment:
- Step 1 — Classify. Run free-monomer analysis on the actual batch. Record whether the product exceeds 0.1% w/w total diisocyanate.
- Step 2 — Author the SDS. Issue an EU-format, language-localised SDS (the destination country's official language) with correct CLP classification, EUH statements, and the training clause.
- Step 3 — Label. Print the verbatim training statement on primary packaging plus the CLP pictograms, signal word, and UN transport marks.
- Step 4 — Inform the customer. Provide training access information and confirm the buyer can evidence completed training before use.
- Step 5 — Assemble the export file. Commercial invoice, packing list, SDS, and — where dangerous-goods rules apply — the correct transport documentation.
Missing any of these is the most common reason polyurethane shipments are held at EU entry points. The restriction sits alongside — not instead of — REACH registration, CLP classification, and dangerous-goods transport rules, so treat it as one layer in a stack rather than a standalone task.
REACH registration versus the diisocyanate restriction
These are frequently confused. REACH registration concerns whether the substance is legally allowed on the EU market at all, and for non-EU manufacturers is handled through an EU-based importer or an Only Representative. The diisocyanate restriction (entry 74) is a separate, additional condition of use. A substance can be fully registered and still be unlawfully used if the training and labelling conditions are ignored. Exporters need both boxes ticked.
Why a direct manufacturer relationship reduces your compliance risk
Compliance quality is only as good as the data behind it. Trading intermediaries often re-label drums with generic SDS copies that do not match the actual batch chemistry — a real audit liability. As a direct manufacturer of polyol systems, catalysts, surfactants, and flame retardants, we control the compliance chain end to end:
- Batch-matched SDS. Each shipment ships with an SDS reflecting the real formulation and free-monomer level, localised to the destination language.
- Custom formulation. Where a buyer needs to stay below the 0.1% threshold, we can engineer low-monomer or diisocyanate-free alternatives to remove the training obligation entirely.
- Traceable certification. ISO-aligned quality documentation and third-party test reports are available for buyer and customs audits. Standards bodies such as ISO and ASTM underpin the test methods we cite in those reports.
- Direct supply pricing. No intermediary markup, and a single technical contact who can answer classification questions before you place the order.
For buyers whose priority is avoiding entry-74 altogether, the fastest route is often reformulation rather than paperwork. Talk to our technical team about custom low-monomer systems matched to your application and target market.
FAQ
Q: When did the EU diisocyanate training requirement take effect?
The training obligation under REACH Annex XVII entry 74 became mandatory from 24 August 2023. Since that date, industrial and professional users may not use in-scope diisocyanate products unless training has been successfully completed, with refresher training at least every five years.
Q: Does the restriction apply to pure polyols or catalysts?
No. Pure polyols, amine/tin catalysts, and silicone surfactants contain no free monomeric diisocyanate and fall outside the 0.1% w/w threshold. The obligation attaches to the isocyanate component. In a two-component kit, the isocyanate side triggers the labelling requirement.
Q: What exact statement must appear on the packaging?
The verbatim wording is: "As from 24 August 2023 adequate training is required before industrial or professional use." It must be legible and distinguishable, and the SDS must reflect the training and safe-use conditions in the relevant sections.
Q: As a non-EU exporter, who is responsible for the training?
The end user must complete the training, but the supplier placing the product on the EU market must ensure training information is provided and the statutory statement appears on packaging. In practice, exporters supply compliant SDS and labelling and direct customers to accredited training resources before use.
Q: How can I avoid the training requirement entirely?
Keep total free monomeric diisocyanate below 0.1% w/w. This can be achieved with low-monomer prepolymers or reformulated systems. As a manufacturer we can develop custom low-monomer or alternative-chemistry systems so your EU customers avoid the entry-74 obligation.
Q: Is the diisocyanate restriction the same as REACH registration?
No. Registration governs whether a substance may be on the EU market at all; the restriction is an additional condition of use. Both must be satisfied — a registered substance can still be used unlawfully if training and labelling conditions are not met.
