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.
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.…