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Lupahakemuksia koskevat lausunnot ja aikaisemmat kuulemiset

Lupahakemuksia koskevat lausunnot ja aikaisemmat kuulemiset

This page provides further information on the applications for authorisation or review reports, which have undergone consultation. The applications for authorisation are in the opinion development phase until the final opinions of the Committees for Risk Assessment and Socio-economic Analysis have been adopted and sent to the European Commission. Its decision-making process can be followed through the comitology register, where further information is published about the REACH Committee's past and upcoming meetings.

On 1 February 2020, the United Kingdom (UK) withdrew from the EU. The transition period provided by the withdrawal agreement ended on 31 December 2020. As of 1 January 2021, an application for an authorisation submitted by a person established in the UK (except Northern Ireland) is no longer valid in the EU, unless that application has been transferred to a legal entity established in the EU or Northern Ireland before the end of the transition period. Therefore, authorisation applications and decisions in so far as these concern persons established in the UK (except Northern Ireland) are no longer considered valid. 


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Substance Details

2,2'-dichloro-4,4'-methylenedianiline (MOCA)
EC Number
CAS Number
Entry Nr in Annex XIV
Use name
Industrial use of MOCA as a curing agent/chain extender in cast polyurethane elastomer production
Broad information on use applied for (conditions of use and function)
Castable polyurethanes form a part of the overall polyurethane industry. They are prepared by mixing 3 main constituents: the polyol, the diisocyanate (which together form the prepolymer) and a curing agent/chain extender like MOCA (2,2’-dichloro-4,4’-methylenedianiline). Before mixing with the prepolymer MOCA is first melted at ca. 120°C. The resulting molten polyurethane is then moved to a moulding area and poured into the moulds. The moulding process can be performed either manually or in an automated system. Finally when the moulds are cast they are cured at 70-80 °C.

Polyurethanes, once cured, form zones with hard and soft segments. This provides the polyurethane a “memory” that allows the material to be stretched or compressed while returning to its original shape and it also contributes to the technical properties of the polyurethane. The structure of the MOCA moiety, facilitates the alignment of the polymer chains (soft segment).

After the polyurethane article has been cured completely, virtually no free MOCA exists in the article (significantly less than 0.1%).

According to the applicant, within its supply chain, MOCA is used at approximately 89 sites across the EU.

The products produced are used in a wide array of industries for many different applications. These include, but are not limited to, industries such as mining, minerals extraction and processing, paper and printing industry, packaging industry, fibre glass and glass manufacturing, steel and aluminium industries, oil and gas industry, textile and plastic industry, the wood and timber industry; in public transport, retail, motor vehicle manufacture, lifts and escalators, leisure industry, and marine transport. Also parts are used in aerospace, industrial vehicles, energy (including renewables) and defence sectors.

MOCA is used because it has several advantages (technical and financial) over other curing agents/chain extenders. Some of these advantages are that:

  • It imparts on the finished polyurethane elastomer better all-round technical performance e.g. abrasion and cut resistance; humidity, hydrolysis, heat, tear resistance; UV resistance; ozone resistance, and resistance to radiation and fire retardant properties compared to alternatives
  • It is comparatively cheap compared to alternatives
  • It is easy to process and provides sufficient pot-life for small, medium and large products to be cast
  • It is a robust reagent. Slight variations in ratios of reactants do not impact the characteristics of the final polyurethane significantly
Additional information on the process is given in the CSR pages 9-10 and 28-29

Additional information on essential criteria for substance function is given in the Analysis of Alternatives, pages 21-23

Annual tonnage used: 516 tonnes per year
Review period requested: 12 years
Use applied for number in application for authorisation
Broad information on use applied for (Use descriptor system)
Sector of end use (SU): 12
Environmental release category (ERC): 6d
Process category (PROC): 2, 4, 5, 8a
Product category (PC): 32
Technical Function: other: Curing agent/chain extender
Summary table of RMMs and OCs (non confidential)
Chemical Safety Report (original and updated, if available) (non confidential)
Analysis of Alternatives (non confidential report)
Substitution Plan (non confidential summary)

Analysis of alternatives addendum
Socio-Economic Analysis (non confidential report)
Joint Analysis of Alternatives and Socio-Economic Analysis (non confidential report)
Explanatory note
Additional information
REACHLaw Ltd in its legal capacity as Only Representative of Suzhou Xiangyuan Special Fine Chemical Co., Ltd
Application type
Opinions adopted
Other consultations on the same/ similar use
Comments submitted to date
Download comments
Response to comments by applicant
Responses to RAC and SEAC requests by Applicant(s) (non confidential)
Compiled RAC and SEAC opinions
Minority positions
Adopted commission decision (OJ summary)
Authorisation decision

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