REACH – Applications for authorisation AFA016-01 – MOCA

Closes 20 Oct 2022

Opened 25 Aug 2022

Overview

Public consultation on alternatives

Reference: AFA016-01

Applicant: Custom Moulded Polyurethane Limited (CMP Ltd)

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: Industrial use of MbOCA as a curing agent/chain extender in hot cast polyurethane elastomer production.

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

Custom Moulded Polyurethane Ltd commenced manufacturing in 2004. As the company name suggests it specialises in the design and manufacture of bespoke hot cast polyurethane components. The business manufactures high tensile strength cast polyurethane components processed using TDI prepolymers cured with MbOCA. Example components manufactured include wheels, engine and gearbox mounts and rollers, plus a vast range of very tough diverse engineering components. Manufactured parts are used by a wide range of sectors some of which include water treatment, automotive industry, rail transport sector and lifesaving recovery vehicles.

The Applicant asserts that MbOCA-cured polyurethanes are tough, durable and they have better all-round technical performance than polyurethanes cured with alternatives. MbOCA cured components provide high load bearing capacity, good abrasion resistance, high tensile strength, compression set and rebound resilience. MbOCA is much easier to process than any alternative chain extender and is a lower cost raw material with lower manufacturing reject levels. In summary, there is no “drop in “ replacement for MbOCA.

The Applicant has actively pursued analysis of alternative curing agents to MbOCA with suppliers, testing a number of these candidate curing agents in trial component manufactured small batches to be tested by customers, but has been unsuccessful in identifying a suitable alternative that will meet the technical specification for the end user requirements. As a result, the applicant cannot conclude that a suitable alternative is currently commercially available that will perform as a technically viable replacement for TDI-MbOCA cast polyurethane components, so a substitution plan is not feasible at time of application.

The applicant has requested an 8 year review period to allow time for further analysis of alternative chain extenders as these become available for trial.

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 tonne/year

Review period requested: 8 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)