June 29th, 2012

Based on the assessments carried out, the European space industry is of the opinion that all propellant-related use of hydrazine for space applications is exempted from REACH authorisation subject to the criteria given in the Position Paper: "Exemption of propellant-related use of hydrazine from REACH authorisation requirement.

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. 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, all major European programmes such as Ariane 5, Soyuz, Vega, Galileo, GMES and other satellites produced for public Agencies or for private operators use hydrazine. In total, less than 20 tonnes per year of this "space-specified" hydrazine are currently being used within the European Union for the mentioned missions.  Against this background timely preparation for the required formalities to comply with the REACH authorization process is imperative for conductance of current and future space operations. Therefore a task force, open to all users of hydrazine in the European space industry, was set up in October 2011 under co-­?ordination of the European Space Agency (ESA) with the aim of determining the route to follow: Authorization or exemption. In November 2011 a data evaluation questionnaire was circulated by Eurospace to all known EEA-­?based companies actually or potentially using hydrazine as well as to national space agencies (CNES in France and DLR in Germany), in order to obtain a complete understanding of the different handling steps and conditions of use, and allow an assessment of the applicability of REACH authorization exemption clauses. In parallel, an exemption feasibility study with similar scope was performed by one of the task force members, Astrium Satellites (UK), supported by all major European satellite integrators. Further, companies mapped their activities in the EEA supply chain for hydrazine step by step in process flows. During the assessment, the UK REACH and CLP helpdesk at HSE and the German REACH-CLP Helpdesk at the Federal Institute for Occupational Safety and Health (BAuA), commented on the case, and advised contacting European Commission and ECHA in order to obtain an authoritative clarification. 
The Eurospace Position Paper "Exemption of propellant-related use of hydrazine from REACH authorisation requirement", together with a ZIP file containing letters of support from the European Space Agency (ESA) and Centre National d'Etudes Spatiales (CNES) as well as other related documents referred at the end of the Position Paper, are available in the attachment. 

Related files: Hydrazine_REACH_Possition_paper_and_related_documents_073603.rar