Issue date: September 1, 2025

Here is what changed in EU chemical regulation, why it matters, and how to respond with confidence.

1) REACH SVHC: Sweden proposes DBDPE for the Candidate List

What changed
Sweden has submitted an Annex XV dossier to identify DBDPE
(1,1'‑(ethane‑1,2‑diyl)bis[pentabromobenzene], CAS 84852‑53‑9) as an SVHC due to very persistent and very bioaccumulative properties under Article 57(e). ECHA ran an ad hoc public consultation that closed August 11, 2025. If adopted, this would add DBDPE to the Candidate List, which currently contains 250 entries after ECHA’s June update.

Where DBDPE shows up
Brominated flame retardant used in electronics and electrical components, wire and cable insulation, engineering plastics, building foams, adhesives and sealants. Expect presence in connectors, enclosures and some PCB-related materials.

Who is impacted
Electronics and electrical equipment, automotive, aerospace, building and construction, consumer goods and toys, textiles, and packaging that use flame‑retarded plastics and foams.

What happens if DBDPE becomes an SVHC
Article suppliers with DBDPE above 0.1 percent w/w would inherit communication duties and other Candidate List obligations. Monitor ECHA’s SVHC process page for the formal outcome.

Official source
SVHC intentions registry and the Annex XV proposal for DBDPE are available via ECHA.

2) REACH Annex XVII: CMR list updates apply from September 1, 2025

What changed
The Commission published Regulation (EU) 2025/1731 to align Annex XVII Appendices 2, 4 and 6 with newly classified Category 1B CMR substances under CLP. This affects supply to the general public of mixtures containing these CMRs at or above specific or generic concentration limits. The measure applies from September 1, 2025.

Key additions relevant to electronics and industrial chemicals

• TBBPA added to Appendix 2 as Carc. 1B

• N,N‑dimethyl‑p‑toluidine added to Appendix 2 as Carc. 1B

• TPO photoinitiator [diphenyl(2,4,6‑trimethylbenzoyl)phosphine oxide] added to Appendix 6 as Repr. 1B

• BPAF and several BPAF‑salt complexes added to Appendix 6 as Repr. 1B

• Dibutyltin maleate and dibutyltin oxide added to Appendix 6 as Repr. 1B
  These changes sit alongside other new entries and a targeted derogation for cumene in aviation fuels.

Concentration limits to watch
Generic limits for supply to the public remain 0.1 percent for Carc. 1A/1B, 0.1 percent for Muta. 1A/1B, and 0.3 percent for Repr. 1A/1B when no specific limit is set.

Who is impacted
Electrical and electronics, inks and coatings, 3D printing and UV‑cure systems, plastics and rubber, automotive and aerospace, consumer DIY products, and distribution channels that sell mixtures to the general public.

Official sources

• Official Journal entry for Regulation (EU) 2025/1731, including the updated appendices

• ECHA overview of Annex XVII restrictions for additional context.

Quick action checklist

For the SVHC proposal on DBDPE

• Identify where DBDPE appears in your BOMs, formulations and purchased components.

• Prepare for Candidate List duties if the listing is confirmed, including supplier outreach and customer communication at the article level.

For the Annex XVII CMR update

• Audit SDSs and label claims for TBBPA, BPAF, TPO, DBT compounds and N,N‑dimethyl‑p‑toluidine in any consumer‑available mixtures.

• If thresholds are met, restrict supply to the general public or reclassify to professional‑only channels with compliant labeling and distribution controls.

How Certivo helps you move fast

• CORA monitors these regulatory changes and flags impacted parts, mixtures and markets in real time.

• Automated supplier outreach requests updated SDSs, composition and substitution options.

• Predictive risk highlights where DBDPE or newly listed CMRs are most likely in your portfolio based on materials and processes.

• Audit‑ready documentation centralizes evidence for Article 33 communications and Annex XVII decision logs.

Useful links for teams

• DBDPE SVHC proposal and consultation details.

• ECHA news confirming the Candidate List stands at 250 entries after June 2025 additions.

• Official Journal: Regulation (EU) 2025/1731 with the updated Annex XVII appendices effective September 1, 2025.

• ECHA page on restrictions under REACH for ongoing reference.

Plan your next steps
Open your dashboard in Certivo to run the Annex XVII and SVHC checks across active products, then auto‑generate your action plan with CORA.