Ethoxylates in Aerospace Authorisation Consortium (EAAC)

The Ethoxylates in Aerospace Authorisation Consortium (EAAC) was formed in 2018 by several companies in the aerospace1 and defence2 industry sectors to develop applications for authorisation (AfAs) for nonylphenol ethoxylates (NPEs) and octylphenol ethoxylates (OPEs).

More information

If your company or your supply chain uses two-part polysulfide sealants containing NPE or OPE covered by these AfAs to manufacture or repair aerospace1 and defence2 components in the EEA, you can contact EAAC with any questions you may have using the contacts listed below.

Erin Yaeger
EAAC Chair
T +1 (860) 557 1017
Contact Erin Yaeger

Helen Middleton
EAAC Deputy Chair
T +44 (0)1332 823892
Contact Helen Middleton

David A. Pinsky
EAAC Deputy Chair
T +1 (978) 858 9820
Contact David Pinsky
Sue Bullock

Sue Bullock

Health Sciences - Product safety & stewardship
T: +44 1132 457 552
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Dianne Green

Principal Consultant
T: +1 513 563 3542

The substances are listed in REACH Annex XIV because of “equivalent level of concern due to its degradation to a substance with endocrine disrupting properties”. They are constituents in certain two-part polysulfide sealants that are critical to the AD industry. Both substances have a Sunset Date3 of 4 January 2021.

EAAC, assisted by Ramboll, has prepared AfAs, requesting a 4-year review period, for the substances and uses described below:

Annex XIV Entry No. 42: 4-(1,1,3,3-tetramethyl butyl)phenol, ethoxylated (OPE)

  • Use 1: The formulation of a hardener component containing OPE within Aerospace and Defence (A&D) two-part polysulfide sealants. View AfA.
  • Use 2: Mixing, by Aerospace and Defence (A&D) Companies and their associated supply chains, including the Applicants, of base polysulfide sealant components with OPE-containing hardener, resulting in mixtures containing < 0.1% w/w of OPE for Aerospace and Defence (A&D) uses that are exempt from authorisation under REACH Art. 56(6)(a). View AfA.
  • EAAC Applicants: PPG, Boeing Distribution, Inc. (formerly Aviall Services Inc.), Wesco Aircraft

Annex XIV Entry No. 43: 4-Nonylphenol, branched and linear, ethoxylated (NPE)

  • Use 1: The formulation of a hardener component containing NPE in Aerospace two-part polysulfide sealants. View AfA.
  • Use 2: Mixing, by Aerospace Companies and their associated supply chains, including the Applicant, of base polysulfide sealant components with NPE-containing hardener, resulting in mixtures containing < 0.1% w/w of NPE for Aerospace uses that are exempt from authorisation under REACH Art. 56(6)(a). View AfA.
  • EAAC Applicant: Chemetall

EU REACH Status

The AfA were duly submitted to ECHA by EAAC applicants ahead of the Latest Application Date (LAD) of 4 July 2019.

Due to capacity constraints at ECHA and the European Commission, the processing of the EAAC AfAs was delayed andno final decision on the EAAC AfAs was made by the European Commission prior to the Sunset Date of 4 January 2021 for the above substances/uses/applicants.  

Pursuant to Article 58(1)(c)(ii) of the REACH Regulation, Downstream Users that are relying on the EAAC AfAs listed above may continue to use the referenced substances for the specific uses identified in the AfAs beyond the 4 January 2021 Sunset Date, at least until the European Commission has decided on the Authorisations .  However, Downstream Users will only be covered by the pending EAAC AfAs beyond this date if ALL of the following conditions are met: 

  1.  The substance (on its own or in a mixture ) is supplied by an applicant, or via a supply chain that purchased the substance from an applicant, for the EAAC AfAs as  listed above;
  2. Their use of the substance is consistent with the specific pending AfA; and
  3. Downstream Users apply the worker and environmental protection requirements set out in the latest version of the relevant Safety Data Sheets (SDS(s)).

Decisions regarding the Authorisations for OPE and NPE are still pending in the EU. We will keep this website updated with relevant information as the applications proceed.

UK REACH Status

Applications for Authorisation (AfAs) for the same uses of OPE and NPE were submitted ahead of the deadline for the simplified application process4 under UK REACH. UK REACH Authorisations have been granted for both OPE and NPE (See Table 1 for details). In both cases, the review period is set at 4 years such that it is possible to carry out operations in accordance with these Authorisations until 4 January 2025.

Please refer to EAAC OPE and NPE Applications for Authorisation – UK REACH Status News Bulletin Nos. 2021-02 and 2021-03 for more information.

Authorisation No. Authorisation holder Authorised use Additional Information
UKREACH/21/02/0 PPG Industries (UK) Ltd. The formulation of a hardener component containing 4-tert-OPnEO in aerospace and defence two-part polysulphide sealants (use 1). Date of Decision: 11 Aug 2021
Date Published: 20 Aug 2021
Link to Decision
UKREACH/21/02/1 Boeing Distribution (UK) Inc
UKREACH/21/02/2 Wesco Aircraft EMEA, LTD (UK)
UKREACH/21/02/3 PPG Industries (UK) Ltd. Mixing, by aerospace and defence companies, and their associated supply chains, including the Applicants, of base polysulfide sealant components with 4-ter-OPnEO-containing hardener, resulting in mixtures containing >0.1% w/w of 4-tert-OPnEO for aerospace and defence uses that are exempt from authorisation under Art. 56(6)(a) of EUR 2006/1907 (use 2).
UKREACH/21/02/4 Boeing Distribution (UK) Inc
UKREACH/21/02/5 Wesco Aircraft EMEA, LTD (UK)
UKREACH/21/03/0 Chemetall Limited Mixing, by aerospace companies, and their associated supply chains, including the Applicant, of base polysulfide sealant components with 4-NPnEO-containing hardener, resulting in mixtures containing less than 0.1% w/w of 4-NPnEO for aerospace uses that are exempt from authorisation under Art. 56(6)(a) of EUR 2006/1907. Date of Decision: 4 Nov 2021
Date Published: 16 Nov 2021
Link to Decision
1 Aerospace uses covered for both NPE- and OPE-containing 2-part polysulfide sealants
2 Defence uses covered only for OPE-containing 2-part polysulfide sealants
3 Annex XIV (i.e., the Authorisation List) specifies for each listed substance the “Sunset Date” from which the substance cannot be placed on the market for a use or used after this date, unless an Authorisation is granted for that use or an Application for Authorisation has been submitted for that use before the LAD.
4Under UK REACH, AfA for which ECHA Final Opinions had been finalized prior to the end of the Brexit Transition Period could be submitted according to the simplified process before 30 June 2021.

Ramboll Group A/S

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