DBMC targeted by REACH – Joint response by dedicated Space Energetic Materials Working Group

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On 5 August 2021, Denmark has submitted a proposal for inclusion of the substance 6,6′-di-tert-butyl-2,2′-methylenedi-p-cresol (DBMC) (CAS number 119-47-1) in the REACH Candidate List of Substances of Very High Concern (SVHC) for Authorisation maintained by the European Chemicals Agency (ECHA).

DBMC is used for space applications as an important anti-oxidizer in solid propellants, e.g. for the solid booster of the Ariane 5 and Ariane 6 launchers. There is an impact also for VEGA and VEGA C (first flight in 2022) propellants, interfaces (liners) and thermal protections. DBMC is one of only two anti-oxidizers on the world market today for space use.

Given the criticality of DBMC for the European Space Sector and absence of viable alternatives today, a joint contribution to the ECHA public consultation on the Danish Candidate List proposal has been prepared in the frame of the Space Energetic Materials Working Group (EMWG).

The contribution contains further details on the relevant uses of DBMC, volume information and substitution challenges. It concludes that it is premature to consider any general regulatory follow-up measures under the EU REACH Regulation at this point, given the absence of detailed assessments in this regard. If such measures should be justified beyond existing legislation and pursued for DBMC in the near future, they should be tailored with a suitable derogation for essential space applications.

The European Space Sector contribution for DBMC, which was submitted to ECHA today, is available here (PDF).

About the EMWG:

The EMWG was initiated in 2019 by the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB) in order to establish a broader regulatory monitoring and response frame and take the required actions to determine and mitigate possible regulatory obsolescence risks (mainly but not limited to EU REACH) for space propellants and explosives (energetic materials).

Current EMWG participants include from the space industry side ASD-EUROSPACE, AIRBUS DEFENCE AND SPACE, ARIANEGROUP, AVIO, RUAG and THALES ALENIA SPACE. In addition, key suppliers of energetic materials have joined the group in the beginning of 2021: DASSAULT AVIATION, EVONIK, JAKUSZ – SPACETECH, NAMMO and PYROALLIANCE. From agency side the EUROPEAN SPACE AGENCY (ESA), AGENZIA SPAZIALE ITALIANA (ASI), CENTRE NATIONAL D’ETUDES SPATIALES (CNES) and the GERMAN AEROSPACE CENTER (DLR) are part of the EMWG; the EUROPEAN DEFENCE AGENCY (EDA) attends as an observer. REACHLAW supports the group as a consultant.

Further information:

Contacts:

  • Secretariat: Pierre Lionnet, Research and Managing Director, ASD-EUROSPACE, pierre.lionnet@eurospace.org, +33-(0)1 44 42 00 70
  • Group coordinator and REACH expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143