The EU Amalgam Ban's Supply-Side Deadline Has Now Passed

The deadline you may have missed

On 1 July 2026, a second and less-discussed deadline in the EU's amalgam phase-out took effect. Under Article 10(7) of Regulation (EU) 2024/1849, the import and manufacturing of dental amalgam in the Union is now prohibited. This is separate from the use ban that started on 1 January 2025 — and if your practice wasn't tracking it separately, it's worth checking your position now that it has passed.

What the regulation actually says

Regulation (EU) 2024/1849 amends the EU Mercury Regulation (2017/852) and sets out three dates that matter for a dental practice:

• 1 January 2025 — dental amalgam may no longer be used for treatment, "except when deemed strictly necessary by the dental practitioner based on the specific medical needs of the patient" (Article 10(2a)).
• 1 January 2025 — export of dental amalgam out of the EU is also prohibited.
• 1 July 2026 — import and manufacturing of dental amalgam within the EU is prohibited (Article 10(7)).

The manufacturing and import ban carries its own exemption, worded to mirror the use exemption: import and manufacture "shall be allowed for specific medical needs" of a patient. In practice, that means a supplier can still legally bring amalgam capsules into the EU to fill a documented medical-necessity order — but not to restock general inventory.

Who still has a longer runway

Two carve-outs sit alongside the main timeline:

• Member States where dental amalgam was, before the regulation, the only material reimbursed at 90% or more by the public health system could keep using it until 30 June 2026 rather than 1 January 2025 — a grace period aimed at giving those systems time to fund alternatives for low-income patients.
• Northern Ireland has a separate, longer-dated arrangement under the Windsor Framework, permitting continued use into the 2030s under specific reporting conditions — worth checking directly with your competent authority if you operate there, since the detail sits outside the main EU regulation text.

What changes at chair level, Monday morning

The clinical decision about which material to place is yours and your dental team's — this isn't a materials-science article. But two operational things follow directly from the ban:

1. Ordering amalgam is no longer routine. If your practice still had amalgam capsules on order or on a standing purchase list, that line item needs a documented medical-necessity justification from here on, not a habit reorder.
2. Composite and glass-ionomer volume goes up, and so does curing light use. Every light-cured restoration means another cycle through the curing light, and a light that's cycling more often needs its barrier changed more often — worth revisiting your consumables forecast if amalgam made up a meaningful share of your restorative mix.

Existing amalgam restorations don't disappear on 1 July 2026 — patients with legacy fillings still come in for replacements, repairs, and general care, and those procedures still run through the same handpiece and syringe barrier protocol as before. The ban changes what goes into a new cavity prep; it doesn't change your infection-control routine around the equipment doing the prep.

What to check this week

• Confirm whether your country used the Article 10(2a) derogation, and if so, whether your practice is inside its scope (public reimbursement status, patient income criteria).
• If any amalgam is still coming into the practice, make sure there's a documented "specific medical need" behind the order — not just a supplier relationship.
• Re-check your curing light sleeve and tip cover stock against your current composite volume, not last year's mix.
• If you're in Northern Ireland, confirm your position directly with your competent authority rather than assuming the general EU dates apply.

"From 1 July 2026, the import and manufacturing of dental amalgam shall be prohibited." — Regulation (EU) 2024/1849, Article 10(7)

None of this requires a clinical decision from you today. It requires a five-minute check of your ordering and consumables lists against a deadline that, as of this week, has already passed.