Material Insights · Understanding the Material World

Silicones: Regulation

Why Europe is restricting D4, D5 and D6

What this tab covers How it is regulated and what could disrupt supply: hazard classification, rules in the EU, US and India, anti-dumping duties and other trade measures, and supply-risk notes.

Hazards

ClassificationUN numberKey risks
PDMS polymers generally not classified; D4 is reproductive toxicity category 2; chlorosilanes are flammable, water-reactive and corrosiveUN1162 (dimethyldichlorosilane, intermediate)Chlorosilane releases form HCl clouds; D4, D5 and D6 are persistent and bioaccumulative in the environment.

Main rules

WhereRuleEffect
EUREACH restriction on D4, D5 and D6 (Regulation (EU) 2024/1328), extending the 2020 wash-off cosmetics limit of 0.1% to leave-on cosmetics and other consumer and professional products from 2026-2027 (indicative dates)Forces reformulation in personal care and cleaning products
EUD4, D5 and D6 listed as substances of very high concern (2018, indicative)Disclosure obligations
USEPA TSCA risk evaluation of D4 (requested by manufacturers, indicative)Possible future limits
GlobalMedical device and food-contact approvals (FDA, EU MDR)Qualification barriers that protect incumbents

India

RuleEffect
BIS cosmetics standards and CDSCO cosmetics rules (2020)Indian cosmetics may follow EU limits on cyclosiloxanes over time (indicative)
MSIHC Rules 1989Covers chlorosilanes if handled
Solar and EV PLI schemesRaise domestic demand for silicone encapsulants and sealants

Trade measures

  • US anti-dumping and countervailing duties on silicon metal and ferrosilicon from several countries (silicon tile)
  • No current Indian silicone trade remedy confirmed in sources reached

Supply risk

High concentration: China makes most silicon metal and siloxane. The EU lists silicon metal as a critical and strategic raw material (Critical Raw Materials Act, 2024). Western upstream capacity is shrinking.