The European Chemicals Agency (ECHA) is seeking evidence on unreacted 4,4’-diaminodiphenylmethane (MDA; CAS 101-77-9) and 2,2'-dichloro-4,4'-methylenedianiline (MOCA; CAS 101-14-4) in articles as it considers whether additional EU controls are needed.
The call, opened on 7 October 2026, focuses on articles containing more than 0.1% by weight (w/w) of unreacted MDA — including MDA resulting from the use of formaldehyde, oligomeric reaction products with aniline (Technical MDA; CAS 25214-70-4) — or MOCA. Comments and evidence are due by 18 November 2026.
ECHA is also seeking information on migration and releases of unreacted MDA and MOCA from polymer matrices and coatings, and resulting exposure of consumers, professional workers and industrial workers.
ECHA considers whether controls should extend to articles
MDA, Technical MDA, and MOCA are already subject to EU controls on their use. Their respective cutoff dates — 21 August 2014, 22 August 2017 and 22 November 2017 — have all passed. Companies generally cannot now use these substances in the EU or place the substances on the EU market for a use, without authorization unless an exemption applies.
ECHA is now examining whether unreacted MDA — including MDA resulting from the use of Technical MDA — and MOCA remain in articles above 0.1% w/w, and whether risks from those articles are adequately controlled. If ECHA identifies risks that are not adequately controlled, it will prepare an Annex XV proposal to restrict MDA and/or MOCA in articles under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation.
Any subsequent restriction proposal would undergo a separate public consultation before a restriction could be adopted.
Polyurethane, epoxy and coated articles may warrant attention
MDA and Technical MDA are associated with polyurethane production and epoxy systems, while Technical MDA has been used as an epoxy-resin hardener in applications such as rolls, pipes, molds, and adhesives. MOCA is used as a curing agent and chain extender in cast polyurethane production, with documented applications including industrial rollers, wheels, pads, power-transmission belts, engine and gearbox mounts, tensioner pads, and spring blocks.
Potentially relevant sectors include automotive, rail, industrial equipment, metals processing, and offshore energy.
ECHA also wants information on whether MDA, Technical MDA, or MOCA provides functions in article production other than as curing agents or hardeners, chain extenders, or cross-linkers, including in manufacturing outside the EU.
Companies should check uses and residual MDA or MOCA
Companies with potentially relevant polyurethane, epoxy, coated, or other articles should determine whether MDA, Technical MDA, or MOCA is used during production and whether unreacted MDA or MOCA remains above 0.1% w/w in the finished article. The call applies to the entire supply chain, including manufacturers and suppliers of potentially affected articles, substance manufacturers, importers, downstream users, recyclers, and waste operators. Companies with relevant information should also identify available data on migration, releases, and consumer, professional, or industrial-worker exposure.
Comments and evidence may be submitted confidentially and are due by 18 November 2026. The evidence will inform ECHA’s decision on whether to move forward with a proposal to restrict MDA and/or MOCA in articles under REACH.