ASD-Eurospace reinforces REACH exemption position for hydrazine and other liquid propellants

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The members of the Hydrazine REACH Authorisation Task Force (HTF) of the European Space Industry have elaborated a revision of their initial legal position concerning the exemption of propellant-related use of hydrazine from the authorisation requirement under EU Regulation (EC) No 1907/2006 (REACH).

In the opinion of the European Space Industry, all propellant-related use of hydrazine is exempted from REACH authorisation according to REACH Article 56(4)(d) 2nd alternative “use as fuels in closed systems”.

The revision maintains the assessment and conclusions of the initial ASD-Eurospace Position Paper dated 9 May 2012, while taking into account relevant updates of space applications, relevant EU legislation, European Chemicals Agency guidance and recent judgments of the Court of Justice of the European Union (CJEU), in particular the judgment of 10 September 2015 in case C-106/14. 

At the same time, the assessment and conclusions for hydrazine have been extended to a number of other liquid propellants: MonoMethyl Hydrazine (MMH); Dinitrogen Tetraoxide (NTO), as such and as part of MON-x (Mixed Oxides of Nitrogen) mixtures; and Unsymmetrical DiMethyl Hydrazine (UDMH).

The revision has been sent to the European Commission for its ongoing legal clarification.

Strategic importance of hydrazine and other liquid propellants for European space activities

Hydrazine (anhydrous) is a strategic component for satellite and launcher programmes. Due to its high purity quality required for space applications it is not comparable to other industrial uses and grades. In total, less than 20 tonnes per year of this “space-specified” hydrazine are currently being used within the European Union. Most space vehicles including telecommunication, Earth observation, navigation and scientific satellites as well as space launchers rely on hydrazine and/or hydrazine derivatives propellants. More specifically, major European programmes such as launchers (Soyuz, Vega), Galileo, GMES and other satellites produced for public agencies or for private operators use hydrazine.

MMH, UDMH and NTO/MON-x (oxidizer) are used as bi-propellants for space vehicles (satellite and launcher applications). MMH with NTO/MON-x are used basically for all bi-propellant orbital propulsion systems of commercial and institutional space vehicles. Current notable applications include, but are not limited to, telecommunication platforms, earth observation and scientific missions, ESA missions, “Heinrich-Hertz-Satellite” (a German institutional spacecraft funded through Germany’s national space programme). UDMH with NTO/MON-x is used as bi-propellant fuel for upper stage applications on launchers (only): VEGA AVUM and Soyuz-Fregat. The use is for space applications only (as fuel for rocket motors) by one European space company acting as downstream user. Less than 1 tonne per year of UDMH are currently used in the European Space Sector.

The Hydrazine Task Force

HTF is a splinter group of the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB). Industrial members include Airbus Defence and Space; ArianeGroup; Arianespace; AVIO Group; ELV SpA; GHC Gerling, Holz & Co. Handels GmbH; Nammo Westcott Ltd; OHB; Surrey Satellite Technology Ltd (SSTL); Thales Alenia Space (TAS). HTF is supported by the European Space Agency (ESA); Agenzia Spaziale Italiana (ASI); Centre National d’Etudes Spatiales (CNES); and Deutsches Zentrum für Luft- und Raumfahrt e.V. (DLR). ASD-Eurospace is acting as Secretariat and REACHLaw Ltd as Consultant.

References:

Contact:

  • Pierre Lionnet, Director of Research, ASD-Eurospace, +33-(0)1 44 42 00 70