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U.S. TSCA Section 6 Existing Chemicals Risk Management Rules

ENFORCEMENT TIMELINE

Following the 2016 Lautenberg Amendment; final rules are being finalized and reviewed on an ongoing basis

Enforcement: Following the 2016 Lautenberg Amendment; final rules are being finalized and reviewed on an ongoing basis

Overview

Section 6 of the Toxic Substances Control Act (TSCA) grants EPA authority to regulate the manufacture, processing, distribution, use, and disposal of an existing chemical substance where EPA determines it presents an "unreasonable risk." Since the 2016 TSCA amendments (the Frank R. Lautenberg Chemical Safety for the 21st Century Act), EPA has progressively conducted risk evaluations of existing chemicals and finalized phased prohibition and restriction rules for substances of high concern.

Around 2024, EPA finalized risk management rules in succession for major substances including methylene chloride, N-methylpyrrolidone (NMP), trichloroethylene (TCE), perchloroethylene (PCE), and phenol, isopropylated phosphate (3:1) (PIP (3:1)). In addition, regulatory action under Section 6 is proceeding for carbon tetrachloride (CTC), 1,4-dioxane, and chrysotile asbestos. Under the Trump administration, these finalized rules are also undergoing substance-by-substance reconsideration—including compliance deadline extensions and relaxed enforcement posture—with the latest developments for each substance addressed in the Level 3 child cards below.

Enforcement Timeline

June 2016: The TSCA amendment (Lautenberg Act) is enacted, strengthening the framework for existing chemical risk evaluation and management under Section 6

2020–2024: Final risk management rules for major substances, including methylene chloride and PIP (3:1), are finalized in succession

2024–2025: Final rules for the remaining major substances, including NMP, TCE, and PCE, are also finalized

2025–2026: Under the Trump administration, substance-by-substance reconsideration of finalized rules—including compliance deadline extensions and relaxed enforcement—is underway

Related Regulations / Topics

U.S. TSCA PIP (3:1) 2024 Final Rule: Personal Protective Equipment (PPE) and WCPP Compliance Requirements

EPA's rule under TSCA Section 6 (a final rule addressing PBT chemicals) imposes an extremely stringent restriction that, in principle, prohibits the manufacture, processing, and commercial distribution of phenol, isopropylated phosphate (3:1)—commonly known as PIP (3:1)—a substance widely used as a flame retardant and plasticizer in components across electronics, automotive, aerospace, and general industrial machinery. Because the substance was pervasively used deep within supply chains, including in circuit boards, internal wire insulation, and plastic components, its restriction caused serious disruption across industry supply chains. In response, EPA has introduced sequential compliance extensions, transition deadline extensions, and use-specific revision programs to avoid practical disruption. EPA's amended final rule for PIP (3:1), published under TSCA Section 6 in November 2024, sets out detailed requirements for the Workplace Chemical Protection Program (WCPP) and personal protective equipment (PPE) obligations. During the transition period before manufacturing, processing, or use is prohibited, or for specifically exempted uses, the rule clearly establishes the specific safety standards companies must meet to prevent worker harm—including the wearing of impermeable gloves and respiratory protection, exposure monitoring, and recordkeeping.

U.S. Methylene Chloride Rule: Details of the WCPP Deadline Extension for Non-Federal Research Institutions (November 2025 Final Rule)

In May 2024, EPA published a final rule under TSCA Section 6 that phases in prohibitions on the manufacture, processing, commercial distribution, and many industrial and commercial uses of methylene chloride (dichloromethane). Methylene chloride has been extremely commonly used across a wide range of sectors, including electronics, automotive, and aerospace, as a precision metal cleaning agent, resin solvent, paint stripper, and general solvent. Under the rule, consumer uses are fully prohibited, and the large majority of industrial uses are phased out between 2024 and 2026. Even for extremely limited exempted uses (military, aerospace, refrigerant manufacturing, etc.), strict compliance with and monitoring of exposure limits under the Workplace Chemical Protection Program (WCPP) is mandatory. On May 20, 2025, EPA published a proposed rule to extend, by 18 months, the WCPP compliance deadline that the May 2024 methylene chloride final rule imposes on non-federal industrial and commercial research institutions (universities, private laboratories, etc.), aligning it with the deadline applicable to federal agencies and contractors. This followed numerous comments from research institutions using methylene chloride only in small, infrequent quantities, indicating that the originally short deadline would be difficult for hundreds of affected facilities to meet. EPA Administrator Lee Zeldin signed the final rule on November 7, 2025, and it was formally published on November 13, 2025. EPA has characterized this decision as supporting the Trump administration's regulatory burden reduction policy.

U.S. NMP Regulation: History Leading to Final Rule Publication and Multiple Delays

EPA has published a proposed rule under TSCA Section 6 imposing substantial restrictions on N-methylpyrrolidone (NMP), a major industrial solvent. NMP is an organic solvent extremely widely used in lithium-ion battery electrode manufacturing, semiconductor manufacturing, coatings, and cleaning agents, and the proposed restrictions are grounded in worker health risks including reproductive toxicity. The proposal calls for a full prohibition on certain uses, mandatory implementation of an inhalation and dermal exposure control program (ECEL/ECDL) for remaining major processes (battery, semiconductor manufacturing, etc.), and strict personal protective equipment (PPE) requirements. EPA published its proposed risk management rule for NMP under TSCA Section 6 in June 2024, originally anticipating final rule publication within 2025. However, as of August 24, 2026, the final rule remains unpublished. EPA's Unified Agenda, published July 3, 2026, sets a target of late July 2026 for final rule publication—though this target itself has been pushed back repeatedly, and review and coordination at the Office of Management and Budget (OMB) and elsewhere appears to be continuing even now. As with other TSCA Section 6 rules (methylene chloride, TCE, PCE, etc.), there are indications that the substantive content of the NMP final rule itself may be relaxed relative to the original proposal.

U.S. TCE Regulation: History of Deadline Extensions for Nuclear Fuel Manufacturing and Wastewater Treatment Uses

This is EPA's final rule under TSCA Section 6 requiring the in-principle full prohibition of trichloroethylene (TCE) manufacturing, processing, commercial distribution, and all industrial and consumer uses. TCE has been widely used as a degreasing agent for metal parts and as an intermediate in refrigerant manufacturing, but has been determined to pose extremely high carcinogenicity and acute/chronic toxicity risks. Manufacturing sectors including automotive, aerospace, and electronic components face strong pressure to find alternatives for both U.S.-bound export product manufacturing processes and cleaning processes at U.S. local plants, with the transition of cleaning agents used in precision metal processing and circuit board cleaning (to hydrocarbon-based, aqueous, or low-GWP fluorinated cleaners) becoming an essential response process. EPA published the TCE risk management final rule on December 17, 2024, setting a compliance deadline of September 15, 2025 for most industrial and commercial uses. However, in September of that year, following its acceptance of a citizen petition under TSCA Section 21 (concerning impacts on wastewater treatment), EPA began considering deadline extensions for certain uses. In particular, in light of newly submitted information raising national security and energy-related concerns, the compliance deadline for TCE use as a processing aid in nuclear fuel manufacturing was extended by three years, from the original September 15, 2025 to September 15, 2028. The deadline for wastewater treatment by TCE processors and industrial/commercial users utilizing TCE as a processing aid was also extended, from September 15, 2025 to December 18, 2026.

U.S. PCE Regulation: Coordinated Deadline Extension Proposal with CTC and Strengthened EPA Enforcement Oversight Policy

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.

U.S. TSCA Section 6 Carbon Tetrachloride (CTC) Risk Management Rule

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.

U.S. TSCA Section 6 1,4-Dioxane Risk Management Proposed Rule and Product Content Restrictions

EPA is advancing the development of a comprehensive risk management rule under TSCA Section 6 for 1,4-dioxane, a priority-assessed chemical substance. 1,4-Dioxane is widely used and present as a byproduct or solvent in surfactants, solvents, adhesives, polymer manufacturing, automotive care products, and industrial cleaning agents. EPA's risk evaluation determined that carcinogenicity risks to workers and consumers, along with aquatic environmental contamination risks, constitute an "unreasonable risk," and the proposal includes a prohibition on industrial manufacturing and processing, introduction of a permissible exposure limit (OEL) through a Workplace Chemical Protection Program (WCCP), and establishment of strict upper limits (in ppm) on the substance's content in products.

U.S. EPA TSCA Section 6 Chrysotile Asbestos (White Asbestos) Full Prohibition Rule

This is EPA's final rule under TSCA Section 6 fully prohibiting the manufacture, import, processing, sale, and use of chrysotile asbestos (white asbestos), the only form of asbestos still in commerce in the United States. Phased prohibitions apply to uses including diaphragms for chlor-alkali manufacturing, automotive brake pads, and gaskets.

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Business Impact

Companies manufacturing, processing, or using these chemicals in the United States must individually manage substance-specific compliance deadlines, exemption provisions, and Workplace Chemical Protection Program (WCPP) requirements, since these vary significantly by substance. Because the scope and nature of reconsideration under the Trump administration (deadline extensions, relaxed enforcement, etc.) differs substantially from one substance to the next, it is essential for companies to individually confirm the latest regulatory status for each substance they handle.