Rulebook on Restrictions and Prohibitions of Chemicals (90/25): Key deadlines in 2026

The Rulebook on Restrictions and Prohibitions of the Manufacture, Placing on the Market and Use of Chemicals (“Official Gazette of RS”, Nos. 90/2013, 25/2015, 2/2016, 44/2017, 36/2018, 9/2020, 57/2022, 29/2024 and 90/2025) is the Serbian equivalent of the EU REACH Annex XVII list.

The list contains more than 3100 substances and more than 80 hazard classes and categories with restrictions and prohibitions for substances, mixtures and articles, with the aim of protecting human health and the environment.

2026 brings important changes – 5 entries with new deadlines or obligations that require preparation:

Entry No. 78 – Microplastics: Reporting obligation (2027) but tracking starts in 2026
Entry No. 77 – Formaldehyde: Furniture and road vehicles
Entry No. 76 – N,N-dimethylformamide: Textile industry
Entry No. 68 – PFAS (C9-C14): Photolithography and firefighting foams
Entry No. 51 – Phthalates: Expiry of exemptions

Below we give an overview of each restriction, the industries affected and concrete action items.

Entry No. 78 – MICROPLASTICS

Reporting obligation starts in 2027 – Tracking MUST start NOW

What are synthetic polymer microparticles?

Microplastics = solid synthetic polymers in the form of particles or fibres of a certain size (0.1 μm – 5 mm), intentionally added to products to achieve desired properties.

Key deadline: March 31, 2027 – First reporting deadline

Critical: Tracking of quantities must start during 2026!

Under points 11 and 12 of the Rulebook, certain categories of manufacturers and suppliers are required to submit an annual report to the competent authority by March 31 of the current year for the previous calendar year.

March 31, 2027 = report data for 2026

Who has to report?

Point 12 – From 2027:

Suppliers of products containing microplastics that are placed on the market for the first time for professional users and general use must submit:

a) A description of the end use of the products placed on the market in the previous year
b) Generic information on the identity of the polymer
c) An estimate of the quantities of microplastics released into the environment (including emissions during transport)
d) A reference to the applicable derogation (if any)

Point 11 – From 2028:

Manufacturers and professional users of microparticles in the form of pellets, flakes and powders (raw materials for plastics production) must submit:

a) A description of the use in the previous year
b) General information on the identity of the polymer
c) An estimate of the quantities released into the environment (including transport)
d) A reference to the derogation (if point 4a is used)

From 2029 – extension to other manufacturers and professional users of microplastics.

What exactly has to be reported?

Key information for the report:

Quantities: How much microplastic was placed on the market/used (in kg or tonnes)
Polymer identity: Generic information on the type of polymer
Emission estimate: How much microplastic was released into the environment
- During product use
- During transport
End use: For what purposes the products are used
Derogations: If you rely on an exemption under point 4 or 5

National database (point 13)

All submitted data become an integral part of the national database on microplastics.

The competent authority will monitor:

Total quantities of microplastics on the market
Sectors with the highest emissions
Trends over the years

Additional information obligations (points 14, 15)

At the request of the competent authority, manufacturers, importers and industrial users are required to submit:

Detailed data on the identity of the polymer in products
The function of the polymer in the product
Evidence of degradability/solubility (if they claim the polymer is not a microplastic)

Response deadlines:

Industrial user requests data from the supplier: 7 days
Supplier submits the data: 30 days

Industries affected (for reporting in 2027):

Manufacturers of cosmetics and detergents
Chemical industry (formulators)
Agricultural industry
Manufacturers of sports surfaces
Distributors and retailers who are the first to place products on the market in Serbia

Important: The reporting obligation lies with whoever first places the product on the market in Serbia – often these are not manufacturers but importers/distributors!

Action plan for 2026:

✅ Identify whether your products contain synthetic polymer microparticles
✅ Check whether they fall under the exemptions (point 17 – natural, degradable, soluble polymers)
✅ Set up a system for tracking quantities placed on the market
✅ Prepare documentation on the identity of the polymer (PE, PP, PVC, etc.)
✅ Estimate emissions into the environment:

How much microplastic is released during use?
How much during transport/handling?

✅ If you claim degradability/solubility – prepare test data (point 15)
✅ Document everything already during 2026 – the reporting deadline is 31.3.2027!

Note: We wrote in more detail about the definition, exemptions and bans on adding microplastics in previous articles:

Entry No. 77 – FORMALDEHYDE

Furniture, wood-based products and road vehicles

What is changing?

Point 1: Ban on placing on the market wood-based articles and furniture if formaldehyde emissions exceed the limit values.

Key deadlines:

August 6, 2026 – Furniture and wood-based articles
August 6, 2027 – Road vehicles

Emission limit values:

Measured according to the methods in Table 13 of the Rulebook:

0.062 mg/m³ – for furniture and wood-based articles
0.080 mg/m³ – for articles other than furniture made from wood-based products
0.062 mg/m³ – formaldehyde concentration in the interior of road vehicles

Industries affected:

Furniture manufacturers (kitchens, office furniture, bedrooms)
Wood processing industry (boards, laminates, flooring)
Importers of furniture and wood products
Automotive industry (vehicle interior equipment)
Distributors and retailers

Exemptions from point 1 – WHAT IS NOT covered:

❌ Articles where formaldehyde is naturally present in the materials
❌ Articles exclusively for outdoor use
❌ Construction materials used outside the building envelope and vapour barrier (do not emit into indoor air)
❌ Articles exclusively for industrial/professional use (unless they expose the public)
❌ Articles already covered by entry No. 72 of the Rulebook
❌ Biocidal products
❌ Medical devices
❌ Personal protective equipment
❌ Food contact articles
❌ Articles for reuse (second-hand goods)

Exemptions for road vehicles (point 2):

❌ Vehicles exclusively for industrial/professional use (without exposure of the public)
❌ Used vehicles

Action plan for 2026:

✅ Test formaldehyde emissions from your products (NOW!)
✅ Check whether you fall under one of the exemptions
✅ If you exceed the limits – adjust formulations/the production process
✅ Prepare documentation
✅ For vehicles: Test indoor air according to Table 13

Key point: Testing takes time – don’t wait until July 2026!

Entry No. 76 – N,N-DIMETHYLFORMAMIDE (DMF)

Textile and Paper Industry

What is DMF?

N,N-dimethylformamide (CAS 68-12-2) – a solvent used in:

Processes of direct/transfer polyurethane coating of textiles and paper
Dry and wet spinning of synthetic fibres
Production of polyurethane membranes

Key deadlines:

December 12, 2025 – Polyurethane coating (textiles, paper, membranes) – already in force!
December 12, 2026 – Dry and wet spinning of synthetic fibres

Restrictions under points 1 and 2:

Placing on the market, manufacture and use of DMF is prohibited:

As a substance
In mixtures
At a concentration ≥ 0.3%

UNLESS:

Manufacturers and downstream users ensure:

DNEL limits in the chemical safety report and SDS:
- 6 mg/m³ for workers’ inhalation exposure
- 1.1 mg/kg/day for workers’ dermal exposure
Appropriate risk management measures
Appropriate operational conditions

Goal: Worker exposure must be BELOW the DNEL values!

Industries affected:

Textile industry (fibre spinning)
Polyurethane manufacturers (coatings, membranes)
Paper industry (PU coating)
Chemical industry (formulators of mixtures containing DMF)

Action plan for 2026:

✅ Check the DMF concentration in processes and mixtures
✅ Implement worker protection measures (ventilation, protective equipment)
✅ Update the SDS – add DNEL values
✅ Update chemical safety reports
✅ Document operational conditions and control measures

Entry No. 68 – PERFLUOROCARBOXYLIC ACIDS (C9-C14 PFCA)

PFAS in Photolithography and Firefighting Foams (450 words)

What are C9-C14 PFCAs?

Linear and branched perfluorocarboxylic acids where n = 8-13, including:

Salts and combinations
Related substances (which can degrade into PFCAs)

This is a subclass of PFAS (“forever chemicals”).

Key deadline: November 4, 2026

End of the transitional period for the exemptions under point 4:

Photolithography/etching processes in the semiconductor industry
Photographic coatings on films
Invasive and implantable medical devices
Firefighting foams in already installed systems

Note: The main ban has already been in force since June 25, 2024!

Concentration limits (point 2):

25 ppb – for the sum of C9-C14 PFCAs and their salts
260 ppb – for the sum of related substances
Special limits for fluoroplastics and PTFE micropowders (points 9, 10)

Conditions for firefighting foams (point 4g):

❌ Use for training is prohibited
❌ Testing is prohibited unless all releases are contained
✅ Use only at sites where releases can be prevented
✅ Storage and use under the conditions for PFOA (Annex 2 of the Rulebook)

After November 4, 2026 – foams can no longer be used unless VERY strict conditions are met!

Industries affected:

Semiconductor industry (photolithography, etching)
Fire protection (airport foams, industrial foams)
Photography (coatings)
Medical industry (invasive devices)

Very niche, but if you are in these sectors – CRITICAL!

Action plan:

✅ Identify the use of C9-C14 PFCAs in your processes
✅ For firefighting foams: Plan the switch to fluorine-free foams
✅ Provide emission containment systems if you continue to use PFAS foams
✅ Document compliance with the conditions of point 4g
✅ Check the concentration limits (25/260 ppb)

Entry No. 51 – PHTHALATES

Expiry of exemptions for aircraft and vehicles

Context

A ban on placing on the market articles containing phthalates (DEHP, DBP, BBP, DIBP) has already existed since July 7, 2023 (point 3).

2026 is NOT a new ban – only the exemptions expire!

Key deadline: January 7, 2026

Points 4(b) and (c) – Exemptions end for:

Aircraft placed on the market AFTER January 7, 2026
Motor vehicles placed on the market AFTER January 7, 2026
Products for maintenance/repair of those vehicles

What does this mean?

If the aircraft/vehicle was placed on the market BEFORE January 7, 2026:

✅ It may still contain phthalates in plasticised materials
✅ Spare parts for those vehicles – OK

If it was placed on the market AFTER January 7, 2026:

❌ It must be phthalate-free (or below 0.1% of the plasticised material)

Who is affected?

Aviation industry (aircraft manufacturing and maintenance)
Automotive industry (new vehicle models)
Manufacturers of spare parts for vehicles
Importers of vehicles and aircraft

Note: This is a very niche change. Most companies are not directly affected.

What are “plasticised materials”?

According to the Rulebook (entry 51):

PVC, PVDC, PVA
Polyurethanes
Other polymers (except silicone and natural latex)
Surface coatings, adhesives, sealants, paints

Activities:

✅ Document the date the vehicle/aircraft was placed on the market
✅ Prepare evidence for applying the exemption (if before 7.1.2026)
✅ For new models after 7.1.2026 – ensure compliance (phthalate-free or <0.1%)

Reality: This matters less for most Serbian companies. Phthalates have largely already been phased out of production.

CONCLUSION – TIMELINE AND PRIORITIES

Summary of deadlines:

Date	Entry	Restriction	Priority
January 7, 2026	51	Phthalates – expiry of exemption	ℹ️ Low
August 6, 2026	77	Formaldehyde – furniture/wood	🔥 High
November 4, 2026	68	PFAS C9-C14	⚠️ Medium (niche)
December 12, 2026	76	DMF – fibre spinning	⚠️ Medium
March 31, 2027	78	Microplastics – FIRST REPORT	🔥 Critical
August 6, 2027	77	Formaldehyde – vehicles	🔥 High

Prioritisation by impact:

🔥 CRITICAL – Microplastics (Entry No. 78)

Broadest impact – cosmetics, detergents, agriculture, sports surfaces
Most complex preparation – tracking system, emission estimates, reporting
Start NOW – tracking during 2026 is required for the 31.3.2027 deadline.

🔥 HIGH – Formaldehyde (Entry No. 77)

Furniture and wood processing industry (broad impact in Serbia)
Testing takes time – don’t wait until August!

⚠️ MEDIUM – DMF and PFAS

Textile industry (DMF)
Semiconductors/fire protection (PFAS)
More niche sectors, but critical for the companies affected

ℹ️ LOW – Phthalates (Entry No. 51)

Only an exemption expires
Most of the industry is already compliant

What to do NOW?

1. Identify whether you are affected:

Check your products/processes
Compare them with the restrictions in the Rulebook
Check whether you fall under the exemptions

2. Set up a compliance system:

Microplastics: Tracking quantities during 2026
Formaldehyde: Emission testing
DMF: Updating SDSs/chemical safety reports
PFAS: A plan for switching to alternatives

3. Document everything:

Test results
Processes and control measures
Evidence of compliance

How can Chemplora help?

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Upload a formulation → check all lists (SKS, GVI, List of restrictions and prohibitions, SKIZ, etc.)
Identify whether substances fall under entries 51, 68, 76, 77 or 78
Display the relevant restrictions and prohibitions
System alerts for new deadlines

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Want help with compliance?

VETREN Chemical Management Solutions offers:

Assessment of the compliance status of your products
Consultations on the Lists of restrictions and prohibitions
Preparation for reporting obligations (microplastics)
Testing and documentation

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This blog post is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed chemical adviser or a lawyer specialising in chemical regulation.