Critical information for all users and distributors of MOCA in the EEA – Free Webinar

MOCA (2,2′-dichloro-4,4′-methylenedianiline) is covered by entry 27 of the REACH authorisation list and solely authorized uses are permitted in the EEA since 21.09.2017.

REACHLaw acting as only representative applicant for Suzhou  Xiangyuan  New  Materials  Co., Ltd. submitted an application for authorisation to cover use by all downstream users in the Suzhou supply chain before the latest application date. Your current use is covered by this application. The Commission has not yet taken a decision on the application and last year asked REACHLaw as applicant to submit a substitution plan with the application. In Q2-Q3 2020, REACHLaw ran information collection campaigns to collect the information need to prepare the report from the users. However only 24 companies replied and their use only accounts for ca. 40 % of the tonnage Suzhou supplies to the EEA.

Now in March 2021, the ECHA committee was very critical of the substitution plan report due to low response rate and in their draft Opinion, they concluded that the report was “not credible”.  This is likely to mean that the Commission must now refuse authorisation. A refused authorisation would mean that all supply and use in the EEA must cease with immediate effect once the decision is adopted.

REACHLaw is collecting information on the impact on the users of a refused authorisation to submit with their comments on the committee draft opinion. The deadline to submit comments is 16.04.2021 so there is very little time to collect this information.


We would like to invite all users and/or distributors of MOCA in the EEA market to join our webinar on the 31 March 2021. During our online event we will share information on new developments on the REACH Authorisation application that may have very negative consequences for your continued supply or use of MOCA.

In addition, we will give you details of how to participate in the survey and ensure you are listed as a current user of MOCA that will be impacted by a refused authorisation! 

You can find more information on the Substitution Plan requests made by the Commission on the ECHA webpage at

To take part in the event is free of charge and you can sign-up to the webinar via the following link: 

REACHLaw Speakers:

  • Dr. Bernadette Quinn, Head of Authorisation Practice
  • Eva Marcon, Senior Specialist, Analysis of Alternatives
Share this Post: