By Abhishek Shetty | Mon Jun 16 2025 | 2 min read

Table of Contents

Your SDS says DMAC is “safe under control.” The EU just said otherwise.

On 2 June 2025, the European Commission adopted Regulation (EU) 2025/1090, adding two widely used solvents — DMAC and NEP — to REACH Annex XVII. These restrictions include strict concentration thresholds and legally binding occupational exposure limits (DNELs), with compliance deadlines starting December 2026.

This means:

  • They are now restricted substances.
  • Concentration limits apply at 0.3% w/w.
  • Use is allowed only if worker exposure stays below legally defined DNELs.

And enforcement begins soon.

Why DMAC and NEP restricted under REACH?

These two dipolar aprotic solvents are widely used across:

  • Electronics manufacturing
  • Coatings and paints
  • Chemical processing
  • Fibre and polymer production
  • Cleaning agents

But they’re also classified as toxic to reproduction (Category 1B) and were shown to pose long-term systemic risks to workers. That’s why ECHA moved in — and REACH followed with enforceable restrictions.

What REACH Regulation (EU) 2025/1090 Requires

From 23 December 2026, products containing ≥ 0.3% DMAC or NEP can only be sold or used if:

  • Worker exposure is below REACH-defined DNELs
  • Updated chemical safety reports and SDSs include those DNELs
  • Risk management measures and operational conditions are documented

Keeping up with new restriction updates requires proactive REACH compliance management so regulatory changes are reflected quickly across products and suppliers.

DNEL Thresholds You Must Meet:

DNELs – Legally Binding Worker Exposure Limits.PNG

> Extended deadline for DMAC in man-made fibre production: 23 June 2029

What You Need to Do Now

  1. Audit your BOMs – Trace every instance of DMAC and NEP
  2. Update SDSs and CSRs – Ensure all exposure levels and DNELs are covered
  3. Review supplier data – Ask the right questions and collect fresh declarations
  4. Implement controls – Validate and document exposure mitigation protocols
  5. Prepare for enforcement – Get inspection-ready by Q4 2026

Why This Isn’t Just About Two Chemicals

REACH is no longer just a labeling game. With 2025/1090, occupational exposure is now a measurable compliance obligation.

> This is the first restriction where DNELs are directly enforceable — turning “safe use” into “prove it with data.”

Regilient Helps You Go From “At Risk” to “Audit-Ready”

We help manufacturers, suppliers, and global compliance teams:

  • Identify DMAC and NEP across all SKUs
  • Validate DNEL thresholds via structured data
  • Automate SDS updates + supplier tracking
  • Stay ahead of enforcement deadlines

The December 2026 REACH deadline for DMAC and NEP is closer than it looks once SDS updates, supplier outreach, and exposure documentation are factored in. Book a Regilient demo to see how Regilient identifies your exposure and gets you audit-ready before enforcement begins.

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REACH

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REACH Regulation Restriction update Under Annex XVII

What does EU Regulation 2025/1090 restrict under REACH Annex XVII?
Regulation (EU) 2025/1090, adopted by the European Commission on 2 June 2025, adds two widely used dipolar aprotic solvents to REACH Annex XVII: DMAC (dimethylacetamide) and NEP (N-ethyl-2-pyrrolidone). From 23 December 2026, products containing 0.3% w/w or more of either substance may only be placed on the market or used if worker exposure is demonstrably kept below legally defined derived no-effect levels (DNELs). Updated chemical safety reports and safety data sheets must reflect these DNELs and document the risk management measures in place.
Are DMAC and NEP banned under REACH or just restricted?
Neither DMAC nor NEP is outright banned. Both are restricted under REACH Annex XVII, meaning their use remains lawful provided specific conditions are met. The key condition is that worker exposure must stay below the DNEL thresholds defined in the regulation. If exposure cannot be demonstrated to be below these levels, the substance cannot be used above 0.3% w/w. This makes REACH 2025/1090 distinct from a prohibition: it is a use-conditional restriction backed by enforceable occupational exposure limits, not a blanket ban.
Why were DMAC and NEP added to REACH Annex XVII?
Both substances are classified as toxic to reproduction Category 1B and were assessed by ECHA as presenting long-term systemic risks to workers. They are widely used as solvents across electronics manufacturing, coatings and paints, chemical processing, fibre and polymer production, and industrial cleaning agents. ECHA's risk assessment concluded that existing voluntary controls were insufficient to protect workers from chronic reproductive toxicity, triggering the enforceable restriction under REACH Annex XVII.
What is the compliance deadline for REACH Regulation 2025/1090 and are there any extensions?
The general compliance deadline is 23 December 2026, by which point any product containing 0.3% w/w or more of DMAC or NEP must be accompanied by documentation demonstrating worker exposure is below the applicable DNELs. One sector-specific extension applies: manufacturers using DMAC in man-made fibre production have until 23 June 2029 to meet the same requirements. All other sectors, including electronics, coatings, and chemical processing, must be compliant by the December 2026 deadline.
What documentation changes does REACH 2025/1090 require for DMAC and NEP?
Three documentation updates are required. First, chemical safety reports (CSRs) must be updated to include DMAC and NEP-specific DNEL values and demonstrate that risk management measures bring worker exposure below those levels. Second, safety data sheets (SDSs) for products containing these substances must be revised to reflect the new DNELs and the documented operational conditions. Third, risk management measures and exposure controls must be formally documented and available for inspection. Suppliers of DMAC or NEP-containing products must cascade these updated documents through their supply chains before the December 2026 deadline.
How does Regilient help manufacturers meet the REACH 2025/1090 DMAC and NEP compliance deadline?
Regilient's agentic sustainability platform identifies DMAC and NEP across all SKUs and BOM entries, flags components where concentrations meet or exceed the 0.3% w/w threshold, and triggers structured supplier data collection to validate DNEL compliance. It automates SDS and CSR update tracking to ensure documentation reflects the new occupational exposure requirements, and provides enforcement deadline monitoring so compliance teams have a clear view of outstanding actions against the December 2026 deadline. For fibre sector manufacturers using the extended June 2029 deadline, the platform tracks both timelines simultaneously within a single compliance programme.