U.S. TCE Regulation: History of Deadline Extensions for Nuclear Fuel Manufacturing and Wastewater Treatment Uses
ENFORCEMENT TIMELINE
Compliance deadline extended from September 15, 2025 to September 15, 2028 for nuclear fuel manufacturing use, and to December 18, 2026 for wastewater treatment use
Overview
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.
Enforcement Timeline
October 2023: EPA publishes the proposed rule to prohibit all uses of TCE under TSCA Section 6
December 17, 2024: EPA publishes the TCE risk management final rule
September 15, 2025: Original compliance deadline for prohibition in most industrial and commercial uses
September 2025: EPA accepts a TSCA Section 21 petition (concerning impacts on wastewater treatment) and begins considering deadline extensions
December 18, 2026: Extended compliance deadline for wastewater treatment prohibition applicable to TCE processors and industrial/commercial users utilizing TCE as a processing aid (extended from the original September 15, 2025)
September 15, 2028: Extended compliance deadline for prohibition of TCE use as a processing aid in nuclear fuel manufacturing (extended from the original September 15, 2025; a three-year extension based on newly submitted information raising national security and energy-related concerns)
Business Impact
Companies using TCE within U.S. supply chains must transition to alternative organic solvents or aqueous cleaning systems in line with the phased prohibition, incurring substantial capital investment such as installing vacuum cleaning equipment. Cases in which major U.S. customers demand submission of "TCE non-use certificates" are rapidly increasing, and companies that fail to secure appropriate alternatives risk exclusion from U.S.-bound component supply networks or termination of business relationships.
Even for uses granted limited grace periods, compliance with the Workplace Chemical Protection Program (WCPP)—meeting extremely low permissible exposure limits, monitoring, and providing protective equipment—is required, resulting in an unavoidable substantial increase in management costs.
Nuclear fuel manufacturers and related suppliers have gained an extension period three years longer than originally anticipated for TCE use as a processing aid; however, this is an exceptional measure limited to a narrow use category (nuclear fuel manufacturing) and does not affect the prohibition schedule (compliance deadline of September 15, 2025) for general industrial uses such as metal parts degreasing agents. Because the wastewater treatment extension likewise applies to a limited scope, companies must precisely identify which use category applies to their operations. For the large majority of companies in the metalworking, automotive, aerospace, and electronics component industries, the transition to alternative solvents based on the September 15, 2025 deadline remains required.