Repr. 1B and H360D appear on a 2-ethylhexanoic acid safety data sheet, and a distributor’s replacement-acid pitch usually arrives the same week. Only one of those two events is an obligation.
The adopted EU instruments on this substance carry three different application dates and three different jobs. For an industrial buyer they bind two product channels and no others.
One is placing a mixture at or above the generic 0.3% limit on the market for supply to the general public. The other is use in cosmetic products.
Everywhere else the Repr. 1B group entry changes the label, the safety data sheet and the questionnaire answer, not the permission to sell.
How 2-Ethylhexanoic Acid and Its Salts Came to Carry Repr. 1B
Commission Delegated Regulation (EU) 2022/692, the 18th adaptation of CLP to technical progress, replaced the Annex VI entry for 2-ethylhexanoic acid and its salts with Repr. 1B and H360D. Article 2 of that regulation states that it shall apply from 23 November 2023.
The specific concentration limit that had applied to the acid and its salts, 4.5%, gave way to the generic limit for Repr. 1B of 0.3%. That fifteen-fold tightening pulls a mixture at 3% of a metal 2-ethylhexanoate into H360D and the signal word Danger.
Perstorp announced in April 2018 that a study run at ECHA’s request found “no adverse effects regarding reproduction at the highest dose tested”, and that the CoRAP listing had been removed.
ECHA’s Committee for Risk Assessment opined on the acid and its salts on 11 June 2020 anyway, and Regulation (EU) 2022/692 records that contesting information “was not found sufficient to cast doubts”.
A producer’s press release is not a legal status. The entry is.
What REACH and CLP Actually Restrict for 2-Ethylhexanoic Acid
REACH restricts a single channel at the acid level, and CLP restricts none at all: it fixes the classification, the label and the safety data sheet that travel with the material.
Annex XVII entry 30 bars placing the acid and its salts on the market, or using them, “for supply to the general public” at or above the concentration limit.
| Instrument | What it binds | Applies from |
|---|---|---|
| CLP Annex VI entry 607-230-00-6 (Reg (EU) 2023/1435) | Classification, label, SDS: Repr. 1B, H360D, notes A, X, 12 | 1 February 2025 |
| REACH Annex XVII entry 30 Appendix 6 (Reg (EU) 2023/1132) | Supply to the general public at or above 0.3% | 1 December 2023 |
| Cosmetics Regulation Annex II entry 1024 (Reg (EU) 2023/1490) | Use in cosmetic products, no threshold | 1 December 2023 |
| REACH Candidate List, Annex XIV | Not among the contexts ECHA’s record lists | n/a |
That last line is negative evidence, not an ECHA statement: the agency’s record enumerates the contexts this substance appears in, and neither list is there.
The 0.3% is not written into the entry. Entry 30 falls back to the CLP generic limit wherever Annex VI sets no specific one, and 607-230-00-6 sets none.
Note 12 makes the classification test additive. A formulation at 0.15% free acid plus 0.2% metal 2-ethylhexanoate stands at 0.35% and classifies, though neither component reaches 0.3% alone.
Umicore’s octoate-replacement page tells buyers that “strict restrictions have been imposed on its usage in consumer and professional applications”. Entry 30 restricts supply to the general public, and the packaging marking it mandates reads “Restricted to professional users”.
Professional use is precisely the half the restriction preserves.
The channel a finished material ships into settles the answer. An engine coolant concentrate on a retail shelf crosses into supply to the general public; paint driers, polyurethane catalysts and PVC heat stabilisers sold into industry do not.
Worker protection and downstream communication duties follow the Repr. 1B classification regardless of sales channel.
Does the 2-Ethylhexanoic Acid Entry Travel to Its Salts?
The classification reaches every 2-ethylhexanoate a plant makes, because the Annex VI entry covers “2-ethylhexanoic acid and its salts, with the exception of those specified elsewhere in this Annex”. The only exit is a salt with its own entry.
Note X, added by Regulation (EU) 2023/1434, explains why it travels. The group classification rests only on the properties common to every member of the entry, which here is the 2-ethylhexanoate moiety.
The metal is the non-common part, which note X requires to be assessed separately for a higher category or broader scope.
Testing a salt takes one lookup in Annex VI Part 3: a salt with its own index number is governed by that entry, one without by the acid’s.
Dibutyltin bis(2-ethylhexanoate) is the worked case, with its own index 050-032-00-4 and CAS 2781-10-4. Regulation (EU) 2023/1132 listed it in Appendix 6 separately, on account of the tin.
Cobalt bis(2-ethylhexanoate), CAS 136-52-7, is not among those separately named salts, which points back to the group entry. A producer of metal octoates should also read note A, which requires the correct name on the label.
Which Uses of 2-Ethylhexanoic Acid Are Genuinely Constrained
Cosmetics and cobalt driers are the two uses where the pressure is real, and only cosmetics removes the choice. Regulation (EU) 2023/1490 extended entry 1024 of the Cosmetics Regulation prohibited list to cover the salts from 1 December 2023.
No threshold applies and no derogation exists.
For driers, the pressure comes from the acid rather than the metal.
| Cobalt carboxylate | CAS | Harmonised classification |
|---|---|---|
| Cobalt bis(2-ethylhexanoate) | 136-52-7 | Repr. 1B, H360D |
| Neodecanoic acid, cobalt salt | 27253-31-2 | none |
| Stearic acid, cobalt salt | 13586-84-0 | none |
| Cobalt(2+) propionate | 1560-69-6 | none |
Moving a cobalt drier from 2-ethylhexanoate to neodecanoate removes a harmonised classification from the finished product. That gain is real and decided at the acid, though the neodecanoate ships self-classified STOT RE 1; H372.
The restriction most often cited as forcing that change was closed years ago. The European Commission’s records show the process on cobalt sulphate, dichloride, dinitrate, carbonate and di(acetate) terminated by decision of 8 April 2022. None of those five is a drier.
Umicore, which sells the replacements, calls them “not straightforward drop-in replacements” because longer chains carry less metal per kilo of salt. Ask a 2-ethylhexanoic acid supplier for registration status and the assay basis in writing before re-qualifying anything.
How to Judge the Next Substitution Claim
Put three questions to the next substitution claim that reaches you. Who published it, and what do they sell?
Which channel does the instrument they cite actually reach, and from what date does it apply?
Two claims in circulation survive those three questions. Cosmetics is an absolute prohibition with no threshold, and a cobalt drier rebuilt on neodecanoic acid sheds a harmonised classification.
Everything else adopted on this substance changes the label, the safety data sheet and the questionnaire answer, not the two product channels a buyer may sell into.
Re-qualify a substitute when the finished product travels through one of them. Name the instrument, name the date, then ask what it binds.