With only four months remaining until June 6, 2026, the date when the EU REACH Regulation (EU) 2024/1328 fully restricts certain substances, a compliance storm targeting cyclic volatile methylsiloxanes (cVMS) is sweeping across Chinese exporters.
The new rule clearly states: starting from that date, any substance, mixture, or article placed on the EU market containing D4 (octamethylcyclotetrasiloxane) or D5 (decamethylcyclopentasiloxane) at concentrations ≥ 0.1% (w/w) will be banned from sale—regardless of cosmetic use.
Many companies mistakenly believe, “We don’t use D4 as a raw material, so we’re safe,” but they overlook the critical risk: industrial-grade silicone oils can retain D4/D5 as by-products if the devolatilization process is incomplete.
Recent return-to-sender cases show:
A batch of silicone oil used in electronic potting compounds was detained by Dutch customs because the D4 content reached 0.12%, according to REACH Annex XVII, Entry 70;
An industrial mold release agent exported to Europe was rejected by the customer due to lack of SVHC declaration.
Confirm Product Type
Linear polydimethylsiloxane (PDMS) is compliant, but crude products often contain cyclic impurities.
Request GC-MS Test Reports
Ask suppliers for third-party proof that D4 + D5 total < 1000 ppm (0.1%).
Check Usage Scenarios
If the product is used in leave-on cosmetics, textile treatment, or industrial cleaning agents, regulatory scrutiny is stricter.
High-purity linear silicone oils produced by deep devolatilization can keep D4/D5 below 50 ppm;
Phenyl or vinyl modifications can enhance performance without relying on cyclic structures;
Choose suppliers that have passed REACH SVHC screening and support SCIP database reporting.
“There is still time to test and adjust formulations,” says an SGS compliance consultant.
“But if violations are discovered after June, products may be removed from the market, and companies could face fines up to 4% of sales.”
For exporters, a single GC-MS test costs less than a thousand yuan but can prevent losses of tens of thousands.
With global environmental regulations tightening, “invisible molecules” are becoming visible trade barriers.
In 2026, compliance is no longer optional—it’s a survival threshold.
