By Abhishek ShettyPublished: 2 min read

Table of Contents

A substance appearing on the REACH Restriction Roadmap does not automatically mean that a restriction has been adopted or that companies must immediately stop using the substance.

The roadmap helps identify substances that may require regulatory action because of potential risks to human health or the environment. For manufacturers, importers and downstream users, monitoring the roadmap can provide an opportunity to understand potential changes early and prepare before a restriction becomes legally applicable.

For the broader REACH framework, see our REACH compliance guide.

What Is the REACH Restriction Roadmap?

The REACH Restriction Roadmap is used to identify substances that may require further regulatory assessment and possible restriction under REACH.

It is part of the broader process through which substances can move from regulatory concern toward potential risk-management action.

However, appearing on a roadmap should not be interpreted as confirmation that a restriction will definitely be adopted.

The regulatory process still requires assessment, consultation and the appropriate decision-making steps before a restriction becomes legally applicable.

Does the Restriction Roadmap Mean a Substance Will Be Restricted?

No.

This is one of the most important distinctions for companies monitoring REACH.

A simplified lifecycle is:

Regulatory concern

→ Potential restriction consideration

→ Assessment and preparation

→ Restriction proposal

→ Scientific and stakeholder review

→ Adoption, if justified

→ Legal restriction under REACH

A substance can therefore appear in an early regulatory planning process without becoming subject to an immediate restriction.

Companies should use the roadmap as a forward-looking monitoring signal, rather than treating it as an existing legal restriction.

Why Should Companies Monitor the Roadmap?

Restrictions can affect:

  • Substances used in manufacturing
  • Raw materials
  • Components
  • Materials
  • Formulations
  • Finished products
  • Specific uses or applications

The impact can also extend across the supply chain.

Early monitoring gives companies more time to:

  • Identify affected products
  • Review current uses
  • Understand supplier dependencies
  • Collect substance and material information
  • Evaluate alternatives
  • Discuss potential changes with suppliers
  • Assess possible commercial impact

This is particularly important for products with long development or qualification cycles.

How Can a Company Determine Whether It Is Affected?

Start with the substance rather than the product name.

1. Identify the substance

Use reliable identifiers such as:

  • CAS number
  • EC number
  • Substance name
  • Supplier substance information

2. Map the substance to your products

Trace:

Substance → Material → Component → Product

This helps determine where the substance is actually used.

If you manage large BOMs or need to identify substances across many products, see our REACH SVHC screening tools guide.

3. Understand the proposed concern or use

A potential restriction may relate to a specific substance, concentration, product category or use.

Therefore, finding the substance in your product does not automatically mean that the entire product will be affected.

The actual scope of the proposed regulatory measure needs to be assessed.

4. Review supplier information

Determine:

  • Where the substance originates
  • Which suppliers provide it
  • Whether the information is current
  • Whether alternative materials are already available

If your supplier information is incomplete, our guide on validating REACH SVHC supplier declarations explains how to assess the reliability of supplier evidence.

What Should Companies Do Before a Restriction Is Adopted?

Being proactive does not necessarily mean immediately replacing a substance.

Instead, companies should build a fact base.

Assess current use

Document:

  • Products affected
  • Applications
  • Quantities
  • Concentrations
  • Suppliers
  • Manufacturing locations
  • Customer requirements

Identify alternatives

Determine whether:

  • A substitute already exists
  • A reformulation is possible
  • Qualification would be required
  • A replacement would affect product performance

Monitor the regulatory process

Track changes from:

Roadmap → restriction proposal → consultation → final decision

Do not rely on the original roadmap entry as the final scope.

Prepare stakeholders

Potential restrictions can affect:

  • Procurement
  • Engineering
  • Product development
  • Quality
  • Regulatory compliance
  • Suppliers
  • Customers

Early communication can reduce the risk of discovering a regulatory dependency only after a restriction has been adopted.

Restriction Roadmap vs Annex XVII

These two concepts should not be confused.

Restriction Roadmap

A forward-looking regulatory planning mechanism that helps identify substances being considered for potential restriction.

REACH Annex XVII

The legally established list of restrictions under REACH.

If a substance is already subject to a restriction, the applicable Annex XVII entry and its conditions determine what companies must comply with.

See our REACH Annex XVII restriction guide for the requirements that apply once a restriction is established.

What Happens After a Restriction Proposal?

Once a formal restriction process advances, companies need to look beyond the substance name.

The important questions become:

  1. What products or uses are covered?
  2. What concentration limits apply?
  3. Are there exemptions?
  4. When would the restriction apply?
  5. Are transitional provisions provided?
  6. Which products and suppliers are affected?
  7. What evidence is needed to demonstrate compliance?

The final legal text—not an early roadmap entry—determines the enforceable requirements.

REACH Restriction Monitoring Checklist

If a substance relevant to your business appears on the restriction roadmap:

  • ☐ Confirm the substance identity
  • ☐ Identify where it occurs in your products
  • ☐ Map affected materials and components
  • ☐ Identify relevant suppliers
  • ☐ Understand the proposed regulatory concern
  • ☐ Determine whether your specific use may be affected
  • ☐ Review possible alternatives
  • ☐ Monitor the regulatory process
  • ☐ Track proposals and consultations
  • ☐ Reassess when the final restriction is published
  • ☐ Document your assessment and decisions

Stay Ahead of REACH Restrictions

Monitoring potential restrictions early gives companies time to understand their exposure, engage suppliers and evaluate alternatives before regulatory changes become operational problems.

Regilient helps compliance teams connect regulatory requirements with products, materials, suppliers and compliance evidence so regulatory changes can be assessed systematically.

Request a Demo →

Topics

European Union RegulationsREACH

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EU REACH Restrictions Roadmap Updated: Rolling List of (groups of) substances for restriction

What is the REACH Rolling List for restrictions in the EU?
The Rolling List is a dynamic part of the EU’s REACH Restrictions Roadmap, identifying groups of chemicals under assessment for potential regulatory action, helping companies prepare for upcoming restrictions.
Which chemicals are included in the Rolling List update as of July 2024?
The July 1, 2024 update added groups like PVC additives, ortho‑phthalates, organophosphate flame retardants, bisphenols, flame retardants, hydrocarbyl siloxanes, and formaldehyde.
How often is the Rolling List updated under REACH?
It's reviewed periodically, typically annually—during CARACAL meetings, with the latest update at the end of June 2025
Why should companies in Europe pay attention to the REACH restriction roadmap?
Because the roadmap provides transparency and advance notice so manufacturers and suppliers can plan substitutions and compliance strategies ahead of formal restrictions.
What are Pool 0 and Pool 1 substances in the Rolling List?
Pool 0: Substances already in the “Registry of Intention” or with submitted restriction dossiers. Pool 1: Chemicals under assessment as potential candidates for future restrictions or classification updates.
Which regulatory bodies oversee the update process for the REACH Rolling List?
The European Commission, ECHA , and EU Member States work together through CARACAL to assess and categorize chemicals for inclusion.
When might a group of substances from the Rolling List face formal restrictions?
Timing depends on regulatory progress, after assessment, the Commission or ECHA may propose a restriction dossier; formal restrictions follow dossier submission and risk management evaluation.
What is the REACH Restrictions Roadmap?
It's a planning tool published by the European Commission under the EU Chemicals Strategy for Sustainability, giving industry visibility into which substances are being assessed for future REACH restrictions and where each one sits in that process.
Does the Restrictions Roadmap have legal force?
No. The rolling list itself doesn't restrict or prohibit any substance. It's an early-warning tool; only a formal REACH restriction, once adopted, carries legal obligations.
When was the Restrictions Roadmap last updated?
Commission published a revised rolling list on 2 July 2026, following an earlier update at the end of June 2025. The roadmap was first introduced in April 2022.
How many REACH restrictions have been adopted since the roadmap launched?
According to the Commission, 11 REACH restrictions covering hundreds of hazardous substances have been adopted since 2022, with 6 more in the final stages of evaluation as of the July 2026 update.
Which substances are currently a priority under the roadmap?
The Commission's July 2026 update specifically names PFAS, hexavalent chromium substances, and octocrylene as active priorities, alongside other persistent, bioaccumulative, toxic, and endocrine-disrupting substances.
What's the difference between the Restrictions Roadmap and the REACH Candidate List?
The Candidate List identifies Substances of Very High Concern (SVHCs) and triggers immediate disclosure obligations under Article 33. The Restrictions Roadmap is a separate, earlier-stage tool tracking substances being considered for restriction under Annex XVII, which is a different regulatory mechanism with its own process.
How often is the Restrictions Roadmap rolling list updated?
It's intended to be reviewed periodically at CARACAL meetings and updated roughly once a year, though actual timing has varied. Confirmed updates so far: April 2022 (launch), June 2025, and July 2026.