The call covers concentrations above 0.1% by weight in articles, the migration and release of the substances from polymer matrices and coatings, and the resulting exposure of consumers, professional workers and industrial workers. MDA and technical MDA are associated with polyurethane production and epoxy systems, including use as an epoxy hardener in rolls, pipes, moulds and adhesives. MOCA is used as a curing agent and chain extender in cast polyurethane, in articles such as industrial rollers, wheels, pads, power-transmission belts, and engine and gearbox mounts. Potentially relevant sectors include automotive, rail, industrial equipment, metals processing and offshore energy.

The sunset dates under REACH authorisation have all passed: 21 August 2014 for MDA, 22 August 2017 for technical MDA and 22 November 2017 for MOCA. Companies generally cannot use these substances or place them on the market for a use without authorisation unless an exemption applies. If ECHA finds that risks from articles are not adequately controlled, it will prepare an Annex XV proposal to restrict MDA and/or MOCA in articles, which would go through a separate public consultation. MOCA was already the subject of an earlier ECHA call for evidence in 2022.

The call addresses the whole supply chain, from substance manufacturers and importers to downstream users, article manufacturers, recyclers and waste operators. ECHA asks in particular for data on whether unreacted residues remain above the 0.1% threshold in finished articles, and on migration and exposure. Submissions can be made confidentially. Deadline for providing input is 18/11/2026.
 

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