MOCA Consortium – Newsletter
MOCA CONSORTIUM – NEWSLETTER
12 downstream users of 2,2′-dichloro-4,4′-methylenedianiline (MOCA) have formed a consortium to reapply for authorization to continue their use of MOCA as a chain extender in the production on polyurethanes.
MOCA is covered by entry 27 on the Authorization list and had a sunset date already in 22.11.2017.1 Polyurethanes produced using MOCA exhibit high durability, resilience, abrasion resistance, tensile strength, and impact strength and they are used in a wide variety of industries including offshore energy, mining and paper production.
The consortium members are currently covered by the Suzhou upstream application2 that has been pending a Commission decision for more than 2 years now. Like other upstream applications, the delay in decision- making is due to the concerns of some stakeholders that upstream applications are not fit for purpose in that there is too much uncertainty the representativeness of the exposure information submitted for all the sites covered.
The consortium has decided to prepare their own downstream application that will address the concerns of the ECHA Committees in their Opinions for the Suzhou application, in particular relating to the risk management measures in place at each of the sites where MOCA is used and the availability of alternatives for the products covered by the application.
The consortium of mostly SMEs is now working on preparing their application. The consortium manager Frederik Johanson outlined that they will take all the learnings from Suzhou and other upstream applications into account when preparing the reports. In particular, they will describe what product groups are covered and why alternatives to MOCA are not suitable for these groups.
Mr Johanson added the Consortium hopes that the Commission will give them enough time to prepare their downstream application, have it processed by the ECHA Committees and receive their decision before the end of the Suzhou authorization review period. For many of these companies, stopping use while waiting for a decision will mean a plant shut-down.
See the consortium webpage for more details; https://www.reachlaw.fi/moca/
1 https://echa.europa.eu/authorisation-list/-/dislist/details/0b0236e1807df666
2 https://echa.europa.eu/applications-for-authorisation-previous-consultations/-/substance-rev/15329/term