EU Recommends Melamine and Three Other Hazardous Substances for REACH Authorisation List

EU Recommends Melamine and Three Other Hazardous Substances for REACH Authorisation List

Emilia Jackson 21-Nov-2025

The European Chemicals Agency has advised the European Commission to require special authorisation for four priority substances, including melamine, to continue their use in the EU market.

The European Chemicals Agency (ECHA) has formally recommended that the European Commission add four new substances to the REACH Authorisation List. In an announcement made on November 18, 2025, the agency identified these chemicals as substances of very high concern (SVHC), necessitating stricter regulatory oversight to protect human health and the environment.

Among the four substances prioritized for inclusion is melamine, a widely used chemical that has been the subject of intense scrutiny and industry debate. The full list of substances recommended for authorisation includes:

  • 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 specific substances from the Candidate List based on an agreed prioritization approach, determining that they represent the highest priority for regulatory action at this time.

The inclusion of melamine in this recommendation is particularly significant. During the consultation period in 2024, the proposal to list melamine received comprehensive feedback from various industrial sectors. The decision to proceed with the recommendation was made after a careful review of these comments and the potential economic impacts.

Ofelia Bercaru, Director for Prioritisation and Integration at ECHA, highlighted the complexity of the decision. She noted that while the agency must assess the consequences of listing a substance, the scope of the legal requirement is nuanced.

"In most of its applications, melamine appears to be used as an intermediate, which does not require authorisation under REACH," Bercaru stated. However, she warned that applications for authorisation for the remaining non-intermediate uses could create a "significant workload" for both companies and regulatory authorities. ECHA has acknowledged these challenges, stating that balancing the risks of melamine against its continued utility requires a high-level policy decision by the European Commission and EU Member States.

If the European Commission adopts ECHA’s recommendation, the regulatory landscape for companies using these substances will shift dramatically. Once a substance is added to the Authorisation List, it cannot be placed on the market or used in the European Economic Area (EEA) after a specific "sunset date" unless an authorisation is granted for a specific use.

To obtain this authorisation, companies must demonstrate that the risks associated with the substance are adequately controlled or that the socio-economic benefits of its use outweigh the risks and no suitable alternatives exist. This process is designed to pressure industries into innovation.

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