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

31 March, 2021. From 14:00 PM - 15:00 PM EEST

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

31st of March 2021
Are you a user or distributor of MOCA in the EEA?

If yes, please join our webinar to get information on new developments on the REACH Authorisation application that may have very negative consequences for your continued supply or use of MOCA.

Background: 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.

In the webinar, 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

REACHLaw Speakers:

  • Dr Bernadette Quinn, Head of Authorisation Practice
  • Eva Marcon, Senior Specialist, Analysis of Alternatives