Four New Substances Recommended for REACH Authorisation – What Companies Need to Know

  • November 19, 2025
  • Tero Koski, Head of Impact Assessments

ECHA has published a new recommendation proposing that the European Commission add four substances – including melamine – to the REACH Authorisation List (Annex XIV). Once listed, companies will need to apply for authorisation to continue using these substances for non-exempt uses.

Substances proposed for inclusion:

  • Barium diboron tetraoxide
  • S-(tricyclo[5.2.1.0 2,6]deca-3-en-8(or 9)-yl) O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate
  • Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide
  • Melamine

ECHA selected these substances as highest priority based on the agreed prioritisation approach.

Melamine included despite extensive comments
Melamine’s inclusion follows significant industry feedback during the 2024 consultation. While most melamine uses fall under the “intermediate” exemption, meaning authorisation would not apply, remaining uses may still require applications.

What happens next?
ECHA’s recommendation will now move to the European Commission, which will decide:

  • whether the substances will be added to Annex XIV,
  • under what conditions (sunset dates, latest application dates, exemptions).

Authorisation aims to drive substitution when alternatives are viable, and until then, ensure strict risk control for human health and the environment.

What this means for companies
This development underscores the need for forward-looking portfolio management. Substances moving from the Candidate List to the Authorisation List can trigger:

  • business continuity risks,
  • supply chain disruptions,
  • new reporting and data requirements, and
  • strategic decisions about substitution or authorisation.

At REACHLaw, our Compliance Foresight approach helps companies stay ahead of these developments. Through our Regulatory Audit, we review your portfolio against upcoming trends in candidate listing, authorisation, and restrictions, helping you prepare proactively.

✅ Identify substances at risk of future authorisation
✅ Understand impacts on your EU/EEA supply chain
✅ Assess substitution needs and regulatory timelines
✅ Prepare early for potential authorisation requirements

If you use or rely on any of these substances – or others moving through the REACH pipeline – now is the right time to act.

Get in touch with us at case@reachlaw.fi to discuss how our Compliance Foresight and Regulatory Audit can support your business.

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