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.
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.
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 REACH Authorisation Consortium was formed in summer 2019 to prepare a new application. The consortium will address 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.
The work has started with strategy planning. It is important to do the preparation properly starting with analysis of the required conditions, setting and effective timeline, and using the learnings from the past to build an application that is fit for purpose.