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FI-02600 Espoo, FINLAND
Tel: +358 (0) 9 412 3055
Fax: +358 (0) 9 412 3049
Email: sales@reachlaw.fi
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MOCA Authorisation Consortium


BACKGROUND

4,4′-methylenebis  [2-chloroaniline], MOCA, was added to the Authorisation list already in 2013 and had the sunset date 22nd of November 2017. Currently, all downstream users of MOCA in the EU are covered by a single authorisation application. The decision of this application has been pending for almost 2 years now and there are no timelines for the future.

Who can apply

Manufacturers and downstream users (end-users) of MOCA and importers can apply for authorisation. Distributors cannot apply for an authorisation unless they are also using MOCA according to the definitions of the REACH Regulation , e.g. repackaging is considered a use, but re-labelling is not. 

Consortium

The use of MOCA must be covered by a new authorisation beyond the end of the review period of the ongoing upstream application. Therefore, the MOCA  Authorisation Consortium was formed in summer 2019 to prepare a new application. The Consortium is addressing the concerns of the ECHA Committees in their Opinions for the current single upstream Authorisation, 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 members of the consortium include micro, small and medium-sized enterprises mostly and few big ones located in several European countries. MOCA is supplied from outside of the European Economic Area (EEA) and it plays a critical role as a curing agent in polyurethane production. 

Where are we now

The work was started in July 2019 and is currently in the Application for Authorisation (AfA) development phase with most information already collected from the Consortium Members. Once the included reports – Socio-Economic Analysis (SEA), Chemical Safety Report (CSR), Substitution Plan (SP) and the Analysis of Alternatives (AoA) – are finalized, the AfA dossier will be compiled and submitted to the ECHA.
 
As the Authorisation application work is already far ahead, new Consortium Members who would need to apply for an Authorisation for MOCA can no longer be accepted into the Consortium. This does not, however, apply to new Associate Members who can still apply for membership to the MOCA Authorisation Consortium.