The EU REACH PHT restriction proposes to add hydrogenated terphenyl (PHT, CAS 61788-32-7) to Annex XVII of Regulation (EC) No 1907/2006, prohibiting its placing on the market and use at concentrations of 0.1% w/w or greater in substances, mixtures, and articles. The proposal follows PHT's existing status as a Substance of Very High Concern (SVHC) and introduces binding obligations well beyond current communication duties. For manufacturers and importers serving the EU, the practical work of identifying PHT across bills of materials should begin now, before the expected Q4 2026 adoption.
If you need to understand your exposure quickly, you can book a compliance risk assessment to map where PHT and other restricted substances sit across your products and supply chain.
Key Takeaways
📌 The REACH PHT restriction would ban hydrogenated terphenyl (CAS 61788-32-7) at 0.1% w/w or above in substances, mixtures, and articles across the EU and EEA.
⏳ The WTO comment period closed on 7 July 2026, with European Commission adoption expected in Q4 2026 and full application roughly 18 months after entry into force, around the first half of 2028.
⚠️ PHT is already a listed SVHC due to its very persistent, very bioaccumulative (vPvB) properties, so Article 33 communication and SCIP notification duties apply today, independent of the new restriction.
🏭 Heat transfer fluid use (250–350°C under Strictly Controlled Closed System conditions), defence applications, and civil aviation (a 10-year extended timeline) carry derogations or longer transition windows.
🔗 Roughly 90% of PHT volume is used as a heat transfer fluid; the remainder appears in plastics, adhesives, sealants, and coatings, creating hidden exposure deep in multi-tier supply chains.
📊 Compliance depends on substance-level visibility across the BOM, updated supplier declarations, and the ability to prove due diligence during a regulatory inspection.
🤖 AI-native compliance automation shortens the path from a new Annex XVII entry to a validated, audit-ready position across the product portfolio.
What Is the EU REACH PHT Restriction?
The REACH PHT restriction is a draft Commission Regulation that would add Terphenyl, hydrogenated (PHT), to Annex XVII of the EU REACH Regulation. Once in force, it would prohibit placing PHT on the market and using it, whether on its own or present at 0.1% w/w or above in other substances, mixtures, or articles. This converts a communication-based obligation into a hard market-access restriction. Manufacturers relying on REACH compliance management should treat this as a portfolio-wide screening exercise rather than a single-substance question, because PHT appears in unexpected downstream applications.
The restriction sits alongside a growing list of Annex XVII entries. Tracking each new entry against your product data is exactly the kind of regulatory intelligence and horizon scanning work that proactive compliance risk management is designed to support.
Why PHT Is Being Restricted Under Annex XVII
PHT is an Unknown or Variable composition, Complex reaction product, or Biological material (UVCB) substance. It is already on the REACH Candidate List of SVHCs because it meets the criteria for being very persistent and very bioaccumulative (vPvB), as documented on the official ECHA substance information page. Substances with vPvB properties resist environmental breakdown and accumulate in living organisms, which is why regulators move them from communication-only status toward outright restriction.
For compliance teams, the SVHC-to-Annex-XVII progression is a familiar pattern. It mirrors the trajectory of other restricted substances and reinforces why SVHC and Annex XVII change tracking must be continuous rather than periodic. Waiting for adoption before acting leaves too little time to reformulate or requalify suppliers.
Scope, Threshold, and Compliance Obligations
The proposed entry restricts PHT as a substance and in mixtures and articles at or above the 0.1% w/w threshold. This is the same reference concentration used across many REACH obligations, which helps standardize screening logic across your chemical and hazmat compliance program.
The 0.1% w/w Threshold Explained
The 0.1% w/w limit applies to the substance content of the article or mixture. Reliable threshold management depends on accurate composition data at the component level, which is why BOM substance and threshold management is the operational core of any restricted-substance response. Screening a finished product without component-level data produces false confidence.
Existing SVHC Obligations Still Apply
Independent of the new restriction, PHT's SVHC status already triggers duties today:
✓ Article 33 communication to recipients and, on request, to consumers when articles contain PHT above 0.1% w/w.
✓ SCIP database notification to ECHA for articles containing Candidate List substances above the threshold.
✓ Supplier disclosure through Full Material Declarations (FMDs) and substance declarations.
Managing these overlapping duties is far simpler when supplier data flows into a centralized compliance data backbone rather than living in disconnected spreadsheets. That single source of truth also underpins efficient SCIP submissions and consistent Article 33 responses.
EU REACH PHT restriction Annex XVII compliance overview for manufacturers
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Derogations and Extended Timelines
The proposal recognizes that PHT has technically demanding uses without ready substitutes. The following derogations and extended windows apply based on currently available regulatory guidance:
Application | Treatment |
|---|---|
🏭 Industrial heat transfer fluids (250–350°C) | Derogated where Strictly Controlled Closed System (SCCS) conditions are met |
🛡️ Defence applications | Fully exempted |
✈️ Civil aviation | Restriction applies 10 years after entry into force (extended timeline) |
📦 Legacy stock | Mixtures and articles placed on the market before the applicability date may continue to be used |
Because roughly 90% of PHT volume is used as a heat transfer fluid, the SCCS condition is the single most important derogation to evaluate. Aerospace and defence organizations should confirm eligibility early and document the basis for it. Managing use-specific derogations, sunset dates, and conditions across a portfolio is where audit-ready documentation across frameworks proves its value, particularly for aerospace and defence supply chains.
Implementation Timeline and Current Status
The verifiable milestones, current as of July 2026:
✅ Early 2026: Draft forwarded to the REACH Committee (reflected in the Commission's Comitology Register).
✅ 8 May 2026: WTO TBT notification issued (G/TBT/N/EU/1205).
✅ 7 July 2026: WTO member comment period closed.
⏳ Q4 2026: European Commission adoption expected.
⏳ Entry into force: 20 days after publication in the Official Journal of the European Union (OJEU).
⏳ ~H1 2028: Full application, 18 months after entry into force.
The proposal has not yet been adopted or published in the OJEU. Teams should monitor EUR-Lex and ECHA for the final text. This kind of continuous monitoring is precisely what CORA-powered regulatory intelligence automates, so a change in status reaches the right owner without manual tracking.
REACH PHT restriction compliance timeline and deadlines for EU manufacturers
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Industries Affected
The restriction reaches well beyond chemical producers. Based on the substance's known uses, the most exposed sectors include:
🏭 Chemical manufacturing and formulators of heat transfer fluids
⚙️ Industrial heat transfer and process-heating systems
✈️ Aerospace, defence, automotive, and rail
🧪 Plastics, polymers, adhesives, sealants, coatings, and construction materials
🚢 Importers and suppliers placing affected articles on the EU market
The common thread is that PHT often enters a product through a purchased component or additive rather than a deliberate formulation choice. That makes multi-tier supply chain transparency and supplier data collection the decisive capability, especially for firms importing finished articles.
Compliance Risks and Enforcement Exposure
REACH restrictions are enforced by national market surveillance authorities across EU member states, supported by ECHA's Enforcement Forum. Non-compliance with an Annex XVII entry can lead to market withdrawal, sales prohibitions, penalties set at member-state level, and reputational damage with OEM customers.
The more immediate commercial risk is customer-driven. OEMs increasingly require documented confirmation that purchased parts are free of newly restricted substances before they will accept them. A missing or unreliable declaration can stall a purchase order. Supplier risk scoring and due diligence helps prioritize which suppliers to engage first, so the highest-exposure parts are cleared before they disrupt production. For chemical questions generally, a structured chemicals and PFAS risk management approach reduces these surprises.
📌 Struggling to confirm which products contain a restricted substance? Request a compliance review to see how substance-level screening works across your portfolio.
PHT Restriction Compliance Checklist
Practical steps compliance, procurement, and quality teams can start now:
Screen the portfolio. Identify products, mixtures, and articles that may contain PHT at or above 0.1% w/w.
Maintain existing SVHC duties. Continue Article 33 communication and SCIP notification for PHT-containing articles.
Refresh supplier data. Request updated FMDs and substance declarations covering PHT specifically.
Assess derogation eligibility. Confirm whether heat-transfer, defence, or aviation provisions apply, and document the basis.
Evaluate alternatives. Begin substitution assessments for non-derogated uses well before the applicability date.
Validate certificates. Check supplier declarations for authenticity, completeness, and threshold accuracy.
Monitor adoption. Track EUR-Lex and ECHA for the final regulation and confirmed dates.
Teams that want a structured self-check can use a Customer Audit Readiness Scorecard to gauge documentation completeness across REACH, RoHS, PFAS, and related frameworks before an OEM or regulator asks.
Managing the Restriction with AI-Native Compliance
The hard part of any new Annex XVII entry is not understanding the rule. It is answering, quickly and defensibly, "which of our products are affected, and can we prove it?" That answer depends on connecting regulatory changes to component-level product data.
Certivo functions as the system of record for product compliance, linking supplier declarations to the BOM so that a new restriction can be screened across the entire portfolio at once. AI document parsing and certificate validation extracts substance data from incoming declarations and flags gaps or inconsistencies, reducing the manual review burden that makes restricted-substance work so slow. CORA compliance intelligence monitors REACH developments and maps them to affected parts, moving teams from reactive scrambles toward continuous readiness. Certivo does not replace regulatory judgment; it removes the data-wrangling that consumes it, so engineers spend time on decisions rather than spreadsheets. Explore how this works on the Certivo platform and across supplier and contractor management.
Audit Readiness for Restricted-Substance Compliance
Restricted-substance obligations are tested through four audit types, and each needs different evidence:
📄 Internal audits confirm that screening logic and thresholds are applied consistently.
🤝 Customer audits (OEM-driven) require part-level declarations on demand, often through a customer trust center model used by large buyers.
🏛️ Regulatory inspections (ECHA-supported market surveillance) test whether due diligence was genuine and documented.
✅ Certification audits (for example ISO 14001) check that compliance processes are governed and repeatable.
The recurring difficulty is historic state tracking. When an auditor asks what you knew and declared at a specific point in time, you need immutable audit logs, time-stamped declarations, and point-in-time retrieval, not a current snapshot. Evidence chain integrity matters just as much: who submitted a declaration, when, and on what authority. No platform can make an organization "audit-proof," and none should claim to. The realistic and valuable goal is audit-ready: fewer surprises and a much shorter response time when a request arrives. Continuous audit-ready documentation is what makes that possible.
Executive Conclusion
The REACH PHT restriction is a clear signal of REACH's direction: substances that progress from SVHC status to Annex XVII will keep arriving, and each one forces the same portfolio-wide question about exposure and evidence. With adoption expected in Q4 2026 and full application around H1 2028, the organizations that fare best will be those that can screen products against a new entry in hours, not weeks, and prove their position on demand. That capability comes from connecting regulatory change to component-level data and maintaining continuous, audit-ready documentation. To understand your current exposure and readiness, speak with a compliance specialist.
Lavanya
Lavanya is an accomplished Product Compliance Engineer with over four years of expertise in global environmental and regulatory frameworks, including REACH, RoHS, Proposition 65, POPs, TSCA, PFAS, CMRT, FMD, and IMDS. A graduate in Chemical Engineering from the KLE Institute, she combines strong technical knowledge with practical compliance management skills across diverse and complex product portfolios.
She has extensive experience in product compliance engineering, ensuring that materials, components, and finished goods consistently meet evolving international regulatory requirements. Her expertise spans BOM analysis, material risk assessments, supplier declaration management, and test report validation to guarantee conformity. Lavanya also plays a key role in design-for-compliance initiatives, guiding engineering teams on regulatory considerations early in the product lifecycle to reduce risks and streamline market access.