REACH - Applications for authorisation AFA015-01 – MOCA

Closes 3 Nov 2022

Opened 8 Sep 2022

Overview

Public consultation on alternatives

Reference: AFA015-01

Applicant: Bonaprene Products Limited

Application type: Initial

Substance name:

2,2'-Dichloro-4,4'-methylenedianiline (MOCA, MbOCA)

EC Number: 202-918-9

CAS Number: 101-14-4

Annex 14 Entry Number: 27

Proposed use: MbOCA is used as a reactant in the manufacture of cast polyurethanes at an industrial site.

Broad information on use applied for (conditions of use and function): 

The Applicant uses MbOCA as a reactant in the manufacture of cast polyurethane elastomer products at an industrial site in North Wales. MbOCA is entirely consumed in the manufacturing process and the resulting polyurethanes products are MbOCA free.

The cast polyurethane products are supplied to different sectors e.g., offshore energy, industrial automation as components that are integrated into transport systems, industrial installations and machines (e.g., rollers, pads, wheels, anvil covers, power transmission belts). The cast polyurethanes need to fulfil strict technical requirements that are set by customers/or required by the end use.  

Key substance properties required for the technical function include: surfactant classification (non-ionic); Hydrophile-Lipophile Balance (HLB); surface tension; and cloud point. 

The Applicant has been actively reducing the use of Mboca as a curative in its polyurethane products for some time with Mboca usage declining from 97% of production in 2001 down to 6% in 2021. The remaining production volume that still uses the Mboca-TDI PU manufacturing process is restricted to ‘replacement parts’ on legacy products which require a product specification that cannot be achieved by alternative processes. No orders for new PU products using Mboca as a curing agent are being pursued. 

The Analysis of Alternatives and Substitution section of the Application for Authorisation details the available alternatives to MBoca currently available for substitution, the reasons why they are unsuitable for the PU products specifications / cost implications, and the likely timeframe for progressing a substitution plan when a suitable alternative curing agent becomes available.

List of descriptors:

  • Sector of end use (SU): 0
  • Environmental release category (ERC): 6d 
  • Process category (PROC): 1, 3, 4, 8b, 23, 28 
  • Product category (PC): 32 
  • Article category related to subsequent service life (AC): N/A 
  • Technical Function: Curing agent / Chain extender

Annual tonnage used: 

  • 3.2 tonne/year (declining)

Review period requested: 7 years

How to submit comments

Provide some basic information on possible alternative(s) in the online survey below but more detailed information should be provided in document(s) prepared using the commenting templates in the related section below. A “public version” should always be completed and will be published after the consultation has closed. If you want to include confidential information in your submission, please additionally complete a “confidential version” and submit both versions as attachments.

The consultation lasts for 8 weeks (unless otherwise specified) and closes at 23:59 London time (BST).

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Audiences

  • Applications for authorisation

Interests

  • Registration, Evaluation, Authorisation & restriction of CHemicals (REACH)