REACH – Applications for authorisation AFA019-02 – MOCA

Closed 3 Nov 2022

Opened 8 Sep 2022


Public consultation on alternatives

Reference: AFA019-02

Applicant: LUC (UK) Limited

Application type: Initial

Substance name: 2,2'-dichloro-4,4'-methylenedianiline (MOCA, MbOCA)

EC Number: 202-918-9

CAS Number: 101-14-4

Proposed use: Industrial use of 2,2'-Dichloro-4,4'-methylenedianiline (MOCA) in the manufacture of high-performance polyurethanes specifically for heavy-duty rollers, tensioner pads and spring blocks with high reliability requirements for offshore energy and renewables sectors.

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

This application covers the use of MOCA in the manufacture of high performance polyurethanes, specifically heavy-duty rollers, tensioner pads and spring blocks with high reliability requirements for offshore energy and renewables sectors. The polyurethanes are manufactured by machine casting in fully automated and semi-automated processes.

The material properties of polyurethanes depend on the reactants used in their manufacture and there are many different reactant systems available. Polyurethanes manufactured with a MOCA based system have properties suited to components used in harsh environments.

The polyurethane components for the offshore energy and renewables sectors need to have high durability, high reliability and excellent fatigue properties. Key material properties need to achieve these performance requirements include mechanical strength, dynamic load bearing capacity, deflective/compression behaviour, coefficient of friction and adhesion to the metal substrate (pads and rollers).

The polyurethane rollers, tensioner pads and spring blocks manufactured with alternatives to MOCA need to have equivalent high reliability and durability. They also need to be competitive in cost for customer acceptance.

To be considered suitable, an alternative curative for the same system or a different system would need to fulfil the following conditions:

  • Give polyurethanes with equivalent technical performance in the sectors of use
  • The time between the addition of the chain extender (last raw material component) and the increase of viscosity of the mixture to the extent that it can no longer be poured needs to be sufficient to cast the high volumes of polyurethane needed for the roller coverings
  • Be available in the quantities needed

Despite extensive R&D, the applicant has not yet identified an alternative curative/system that can be used to manufacture the high performance polyurethanes that are components in rollers, pads and blocks used in the offshore energy sector. Polyurethanes manufactured with alternatives need to be competitive with imported MOCA cured polyurethanes or there will be no market for them. The R&D plan outlines the substitution timeline for the requested review period of 12 years.

List of descriptors:

  • Sector of end use (SU): 0: Other
  • Environmental release category (ERC): 6a 
  • Process category (PROC): 1, 4, 5, 8b, 28 
  • Product category (PC): 32 
  • Article category related to subsequent service life (AC): N/A 
  • Technical Function: Curing agent/chain extender, intermediate

Annual tonnage used: 

  • 1.22

Review period requested: 12 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).


  • Applications for authorisation


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