CAS 108-95-2 · REACH · European Union

Phenol under REACH

C6H5OH · 苯酚

Status: Registered. Phenol is fully registered under REACH at the highest tonnage band (>1,000,000 tonnes/year) with multi-registrant consortium-supported registration. **Phenol is the most hazardous substance in this regulatory dataset**: harmonised CLP classification carries Skin Corr. 1B (H314), Acute Tox. 3 (oral / dermal / inhalation, H301 / H311 / H331), Mut. 2 (H341), and STOT RE 2 (H373). Phenol is NOT currently on the SVHC candidate list, but the dominant downstream product bisphenol A (BPA, CAS 80-05-7) IS on the SVHC list (endocrine disruptor classification 2017), creating downstream cascading regulatory pressure on phenol demand.

Phenol is the most hazardous substance in this regulatory dataset (Skin Corr. 1B + Acute Tox. 3 oral/dermal/inhalation + Mut. 2 + STOT RE 2). The dominant operational complexity is workplace exposure control and engineered-handling infrastructure (closed-system loading, automated tank discharge, eye-wash and emergency-shower facilities) which is materially different from the trivial-hazard substances (MEG, PTA, AS, urea, DAP) that dominate the rest of the dataset. The downstream BPA cascade is the dominant medium-term demand-side regulatory uncertainty: BPA is ~50% of phenol demand and is on the SVHC list with ongoing review. Acetone co-product market volatility (1.6:1 fixed ratio) creates phenol pricing volatility independent of phenol demand. China is largest global producer (~45% capacity) led by Sinopec, Yangzi-BASF, Hangzhou Nanhua, Shanghai Sinopec, Wanhua Chemical, Bluestar Chemical, Jiangsu Lihuayi; supplies 40-50% of EU phenol imports. NOT in CBAM Phase 1 scope; potential Phase 2 candidate post-2026 review.

Listing and threshold

Substance Phenol (CAS 108-95-2), C6H5OH
Regime EU Regulation (EC) No 1907/2006: Registration, Evaluation, Authorisation and Restriction of Chemicals
Jurisdiction European Union (EU-27 plus EEA: Iceland, Liechtenstein, Norway)
Status Registered
Tonnage threshold Registration required for any importer or manufacturer placing >1 t/year on the EU market

Classifications under this regime

  • Harmonised CLP classification: Skin Corr. 1B (H314, "causes severe skin burns and eye damage"), Acute Tox. 3 oral / dermal / inhalation (H301 / H311 / H331, "toxic if swallowed / in contact with skin / if inhaled")
  • Harmonised CLP also: Mut. 2 (H341, "suspected of causing genetic defects"), STOT RE 2 (H373, "may cause damage to organs through prolonged or repeated exposure")
  • Signal word: DANGER
  • GHS pictograms: GHS05 (corrosion), GHS06 (skull and crossbones), GHS08 (health hazard)
  • IARC: phenol classified Group 3 (not classifiable as to its carcinogenicity to humans), IARC Monograph Vol 71 (1999) reaffirmed in Vol 117 (2019) (verify against https://monographs.iarc.who.int/list-of-classifications)
  • NOT classified as carcinogen Cat 1 or 2 (Mut. 2 is mutagenicity, distinct from carcinogenicity)
  • NOT classified as reproductive toxicant
  • NOT classified as hazardous to the aquatic environment at standard CLP cutoffs (some self-classifications include Aquatic Chronic 2 / 3)

Restrictions and conditions of use

  • NOT currently on SVHC candidate list (downstream BPA IS on SVHC list since 2017)
  • NOT on REACH Annex XIV (Authorisation list); ECHA continues to monitor phenol pending BPA cascade and consortium registrant updates
  • NOT scheduled under EU Drug Precursors Regulation
  • NOT scheduled under EU Explosives Precursors Regulation
  • NOT subject to any Annex XVII restriction directly applicable to bulk phenol
  • Annex XVII restriction on phenol in retail mixtures (verify current entry number and concentration threshold against https://reachonline.eu/reach/en/annex-xvii.html before relying on the specific Restriction 3 / >2.7% figures cited in earlier dataset drafts)
  • Carbon Border Adjustment Mechanism (CBAM): phenol is NOT in CBAM Phase 1 scope (cement, iron and steel, aluminium, fertilisers, hydrogen, electricity (Phase 1 scope verified at https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en, definitive period from 1 January 2026)); potential CBAM Phase 2 candidate post-2026 EU review
  • EU Cosmetic Products Regulation (EC) No 1223/2009 Annex II: phenol prohibited in cosmetic products
  • EU food-contact applications via Regulation 10/2011: phenol monomer residue in phenolic-resin-coated food-contact materials regulated at 3 mg/kg specific migration limit

Importer obligations

A non-EU producer cannot register directly under REACH. The EU importer of record must hold a registration or rely on an Only Representative (OR). Phenol is a high-volume substance with multi-registrant consortium-supported registration; registration costs are amortised across many importers. The dominant practitioner-facing complexity is **occupational health and workplace exposure controls** (Skin Corr. 1B + Acute Tox. 3 hazard profile drives mandatory engineered-controls, PPE, eye-wash and emergency-shower availability at handling sites) and the **downstream BPA cascade** (EU restrictions on BPA in food-contact since 2018, ongoing SVHC review may further restrict downstream BPA which is ~50% of phenol demand).

Required documents

  • REACH registration number on the EU side (registrant or OR-appointed)
  • Safety Data Sheet (SDS) compliant with REACH Annex II in destination Member State language(s) reflecting H301 / H311 / H314 / H331 / H341 / H373 classification
  • CLP-compliant labelling with GHS05 + GHS06 + GHS08 pictograms and DANGER signal word
  • Customs entry with HS code 29071100 (phenol)
  • Annex XVII Restriction 3 compliance for retail mixtures containing >2.7% phenol
  • Specific workplace handling training documentation (engineered-controls, PPE, eye-wash and emergency-shower facilities)

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

  • **Skin Corr. 1B + Acute Tox. 3 hazard profile is the dominant operational concern**. Phenol can cause severe skin burns from minor splashes, and acute systemic toxicity from skin absorption is a documented occupational-health risk. Engineered handling controls (closed-system loading, automated tank discharge, secondary containment), PPE (chemical-resistant gloves, face shields, splash goggles), and eye-wash + emergency-shower facilities at handling sites are mandatory under WHS / EU OSH frameworks
  • **Downstream BPA cascade**: bisphenol A is ~50% of phenol demand. EU restrictions on BPA in food-contact applications since 2018, ongoing SVHC review, and France's 2015 BPA-in-food-contact ban demonstrate regulatory pressure that will likely tighten further. Sustained BPA demand reduction would soften phenol demand structurally
  • NO active EU AD/CVD case on Chinese-origin phenol currently. EU MFN duty 5.5% (TARIC code 2907.11.00) applies. Periodic AD investigations may be initiated if Chinese export volumes rise materially
  • Acetone co-product market volatility: cumene-process phenol production yields fixed 1.6:1 phenol-to-acetone ratio; weak acetone markets compress integrated phenol+acetone plant economics, which shifts Chinese phenol export pricing 10-15% over a quarter
  • NOT in CBAM Phase 1 scope but EU revision may extend to organic chemicals; long-term watch-item for cumene-process embedded-emissions
  • EU is structurally short of phenol capacity for downstream BPA / polycarbonate / epoxy-resin demand; imports come primarily from China, Saudi Arabia (SABIC), and Korea
  • Mut. 2 classification is distinct from carcinogenicity but drives REACH dossier maintenance and potential future SVHC review

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for phenol, see the CAS 108-95-2 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the phenol cornerstone hub covers the full sourcing chain.

For the structure and history of REACH, see the REACH glossary entry.

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

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Cross-jurisdiction profile and sourcing references

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