PET Care Products: New REACH restrictions for cyclic silicones D4, D5, and D6 from June 6, 2026

Companies that produce, import, or market products intended for pet care and hygiene must now manage the entry into force of new European restrictions on cyclic silicones D4 (octamethylcyclotetrasiloxane), D5 (decamethylcyclopentasiloxane), and D6 (dodecamethylcyclohexasiloxane).

Regulation (EU) 2024/1328 has in fact amended entry 70 of Annex XVII of the REACH Regulation, introducing new limitations for the placing on the market of these substances.

What changes from June 6, 2026

From 6 June 2026 , the placing on the market of mixtures containing D4, D5 or D6 in concentrations equal to or greater than 0.1% by weight will not be permitted, except for specific derogations provided for by the legislation.

For products intended for pets, such as shampoos, conditioners, detangling sprays, grooming products and coat treatments, the general date of 6 June 2026 applies.

What is meant by "placing on the market"

Article 3, point 12, of the REACH Regulation defines placing on the market as:

"the supply or making available to third parties, whether for a fee or free of charge. Importation is considered placing on the market."

Therefore, before 6 June 2026, the following constitute placing on the market:

• the sale of products to distributors or resellers;

• the supply of products to professional users;

• the free transfer of samples or freebies;

• the import of products from third countries into the European Union.

Which operations will be prohibited from June 6, 2026?

From 6 June 2026, it will no longer be possible to place new products on the market that do not comply with the restriction.

In particular:

Operation	Status as of June 6, 2026
Importation of non-compliant products into the EU	Not allowed
First sale or supply of new non-compliant batches to distributors or professional customers	Not allowed
Free transfer of new non-compliant lots	Not allowed
First placing on the market of non-compliant products present at the manufacturer or importer	Not allowed

Inventory Management: Which Products Can Continue to Be Sold?

The restriction prohibits the placing on the market , not the possession or marketing of products that have already been lawfully placed on the market before the date of application.

Consequentially:

Case studies	Situation after June 6, 2026
Batch imported into the EU before 6 June 2026	Already on the market
Lot sold by the manufacturer to a distributor before June 6, 2026	Already on the market
Lot already present at wholesaler or distributor on June 6, 2026	It can continue to be marketed
Lot already present at a retailer on June 6, 2026	It can continue to be marketed
Sale by the retailer to the final consumer after 6 June 2026 of a product already placed on the market	Allowed
Running out of stocks already present in the distribution chain	Allowed

The deadline of June 6, 2026, therefore, represents the deadline by which the new placings on the market of the affected products must be completed, but does not prevent the exhaustion of stocks that have already been legitimately placed on the market before that date.

Recommended actions

PET Care companies should:

1. check the presence of D4, D5 and D6 in the formulations;

2. request updated information from suppliers on the composition of raw materials;

3. make any reformulations;

4. schedule the last imports and the last placings on the market before 6 June 2026;

5. identify the affected products and monitor stocks;

6. maintain suitable documentation to demonstrate the date of importation or first placing on the market of the products.

How we can support you

Our team can assist you in assessing the REACH compliance of your formulations, verifying applicable derogations, managing inventory, and planning the activities necessary to ensure the commercial continuity of your PET Care products.