U.S. PCE Regulation: Coordinated Deadline Extension Proposal with CTC and Strengthened EPA Enforcement Oversight Policy
Overview
This is EPA's final rule under TSCA Section 6 that phases in prohibitions and restrictions on the manufacture, processing, industrial use, and commercial sale of perchloroethylene (PCE/tetrachloroethylene), based on concerns over carcinogenicity and neurotoxicity to the human body. Prohibition is planned across many uses including industrial cleaning agents, degreasing agents, adhesives, and coatings, directly affecting U.S. exports and supply chains for products using or containing the substance.
In December 2024, EPA published final rules under TSCA Section 6 for both perchloroethylene (PCE) and carbon tetrachloride (CTC). On March 24, 2026, however, EPA proposed to extend the compliance deadlines for both final rules as part of a reconsideration of the rules' feasibility. Because PCE and CTC uses substantially overlap in industrial cleaning and degreasing applications, and compliance practices for the two are interconnected, both rules are under review simultaneously. In parallel, EPA's enforcement division (per an internal policy memorandum dated March 2026) introduced an operational policy requiring senior leadership pre-approval for enforcement actions (such as actions against non-compliant companies) related to rules under reconsideration. As a result, even before the deadline extension proposal is finalized, enforcement based on the current deadlines is effectively being restrained.
Enforcement Timeline
June 2023: EPA publishes the proposed PCE risk management rule under TSCA Section 6
December 2024: EPA publishes final rules for both PCE and carbon tetrachloride (CTC)
March 24, 2026: EPA proposes to extend the compliance deadlines for both PCE and CTC final rules (as part of a reconsideration of the rules' feasibility)
March 2026: EPA's enforcement division introduces an internal policy (memorandum) requiring senior leadership approval for enforcement actions related to rules under reconsideration
As of August 2026: The extension proposal remains unfinalized; the current deadlines remain legally in effect, but enforcement in practice continues to be applied in a restrained manner
Business Impact
Precision machinery, automotive, and electronics component manufacturers supplying products and components to the U.S. market must complete the discontinuation of PCE use in manufacturing processes (such as metal degreasing) and transition to alternative cleaning agents. If PCE is present as a product residue or process chemical, failure to confirm compliance carries the risk of detention or penalties at U.S. customs.
Even for uses where continued use is permitted, compliance with extremely strict exposure limits (ECEL) under the Workplace Chemical Protection Program (WCPP), monitoring, and protective equipment requirements are mandatory, causing a sharp increase in compliance costs.
Precision machinery, automotive, and electronics component manufacturers using PCE, CTC, or both retain a formal obligation to comply with the current legal deadlines; however, because EPA's enforcement posture is currently restrained, the near-term risk of enforcement action is considered relatively reduced. That said, this is not a permanent relaxation of the regulation and the situation could change depending on the outcome of the extension proposal, so companies should not abandon their transition plans to alternative cleaning agents. In particular, for products exported to the United States, the risk of customs detention exists independently of the rule's legal validity, and continued caution is warranted.