U.S. TSCA Section 6 Carbon Tetrachloride (CTC) Risk Management Rule
ENFORCEMENT TIMELINE
Final rule published December 2024 (phased bans from 2025, with WCPP requirements mandatory through 2026)
Overview
This is EPA's final risk management rule, published under TSCA Section 6, substantially prohibiting and restricting the manufacture, processing, distribution, and commercial use of carbon tetrachloride (CTC, CAS RN: 56-23-5). CTC is primarily used in the manufacturing process for low-global-warming-potential (HFO) refrigerants, fluoropolymers, and adhesive/sealant intermediates, but has been identified as posing extremely serious health risks, including carcinogenicity and hepatotoxicity. The rule imposes a comprehensive manufacturing prohibition while also mandating a Workplace Chemical Protection Program (WCPP) requiring strict compliance with a worker exposure limit (ECEL: 0.03 ppm as an 8-hour time-weighted average) for exempted uses such as refrigerant manufacturing feedstock.
Enforcement Timeline
December 2024: EPA publishes the final risk management rule for carbon tetrachloride under TSCA Section 6
First half of 2025: The rule takes effect; phased prohibition begins for manufacturing, processing, and distribution in non-essential uses
2026: Full compliance with WCPP (ECEL 0.03 ppm) begins for feedstock uses and similar exempted applications, along with monitoring and respiratory protection requirements
From 2027 onward: Recordkeeping requirements (5-year retention) and downstream user notification obligations become fully established across the supply chain
Business Impact
Japanese chemical manufacturers with U.S. manufacturing facilities, or those exporting or supplying fluoropolymers, next-generation refrigerants, or chemical intermediates to the United States, must implement the capital investment, containment measures, and personal protective equipment (PPE) systems necessary to meet the extremely low permissible exposure limit (ECEL 0.03 ppm). Products and uses that rely on CTC as an industrial cleaning agent or solvent will be excluded from the market, requiring formulation changes to non-covered alternative chemicals. Violations of TSCA Section 6 carry serious risks, including detention of products at U.S. customs, substantial civil penalties (on the order of tens of thousands of dollars per day), and exclusion from U.S. supply chains.