EU REACH Restricts Hydrogenated Terphenyl (PHT): From SVHC to Annex XVII—What Exporters Must Know

On 16 April 2026, the European Commission submitted a draft regulation to amend Annex XVII of REACH (EC) No 1907/2006, proposing a formal restriction on hydrogenated terphenyl (PHT, CAS: 61788-32-7, EC: 262-967-7). On 8 May 2026, the WTO issued a TBT notification (G/TBT/N/EU/1205), opening a 60‑day public consultation until 7 July 2026. The regulation is expected to be adopted in Q4 2026, entering into force 20 days after publication in the Official Journal. This marks a critical regulatory escalation: PHT moves from the SVHC Candidate List (since June 2018) to a legally binding ban under Annex XVIIECHA. For exporters in thermal fluids, plastics, coatings, electronics, cables and aerospace, compliance windows are now open.

What Is PHT & Why It Matters

Hydrogenated terphenyl (PHT) is a vPvB (very persistent, very bioaccumulative) UVCB substance. It resists degradation in the environment, accumulates in organisms, and poses long‑term risks to human health and ecosystems.

Core Specifications

• CAS: 61788-32-7
• EC: 262-967-7

Main Industrial Uses

• High‑temperature heat transfer fluids (250–350°C)
• Plasticisers for plastics, cables & electronic parts
• Additives in coatings, adhesives & sealants
• Electrical insulating fluids & aerospace components

Core Restriction Rules: 0.1% w/w General Ban

The draft imposes a general prohibition: 18 months after entry into force, PHT is banned from placing on the market or use—whether as a standalone substance, component in other substances, mixtures or articles—at ≥0.1% by weight.

Transitional Arrangements

1. Grandfather clause: Mixtures and articles already placed on the market before entry into force may continue to circulate and be used (non‑retroactive).
2. Civil aerospace derogation: The restriction applies 10 years after entry into force; aircraft placed on the market within this grace period may remain in service.

Two Statutory Exemptions

1. Industrial heat transfer fluids: Allowed only for 250–350°C operations in Strictly Controlled Closed Systems (SCCS) at industrial sites, designed to prevent leakage/emissions.
2. Defence applications: Full SCCS waiver, subject to:
   • Leak‑proof, recyclable systems with continuous monitoring & maintenance
   • Technical safeguards (design, filling, operation, emission monitoring, waste disposal)
   • Organisational safeguards (staff training, regular internal/external audits)
   • End‑user written compliance confirmation to authorities.

Timeline Milestones

• 16 Apr 2026: EC submits draft regulation
• 8 May 2026: WTO TBT notification released
• 7 Jul 2026: Public consultation closes
• Q4 2026: Expected adoption & publication
• 20 days post‑publication: Regulation enters into force
• +18 months after entry into force: General 0.1% restriction takes effect
• +10 years after entry into force: Civil aerospace restriction applies

Industry Impacts & Supply Chain Risks

PHT is ubiquitous across industrial sectors. Non‑compliance may lead to market exclusion, product recalls, border rejection and trade barriers.

Affected Stakeholders

• Raw material: Thermal fluid, chemical additive & plasticiser suppliers
• Manufacturing: Plastics, cables, electronics, coatings & composite producers
• Exporters: Any finished goods, components or mixtures sold into the EU

Strategic Compliance Actions

1. Inventory screening: Map PHT presence across raw materials, formulations & finished articles.
2. Testing & verification: Conduct quantitative analysis to confirm <0.1% w/w.
3. Substitute development: Evaluate alternative heat transfer fluids, plasticisers & additives.
4. Documentation: Build a compliance dossier including test reports, SDS, supply chain declarations & exemption justifications (if applicable).
5. Supply chain communication: Mandate suppliers to provide PHT‑free declarations.

Conclusion: Balancing Risk & Industrial Needs

This Annex XVII update reflects the EU’s consistent approach: protect human health and the environment while preserving critical industrial functionality. It provides clear boundaries, targeted exemptions and long transition periods. For companies exporting to the EU, proactive assessment, substitution planning and robust evidence chains are essential to avoid disruptions and secure market access.

Key Takeaway

Now is the time to act: The consultation period ends 7 July 2026, and enforcement is less than two years away.