Trichloroethylene ban in the US, with TCE dates and delays

The US trichloroethylene ban and what the EPA TCE rule covers

Yes, mostly. The US trichloroethylene ban covers all consumer uses and most industrial and commercial uses of TCE. EPA's December 17, 2024 final rule phased the main prohibitions in between March and September 2025, while listed industrial, defense, aerospace and laboratory uses keep later end dates, some as late as 2074. EPA has extended a few deadlines and proposed more, but it has not lifted the general ban.

What TCE is and what it was used for

Trichloroethylene, also called trichloroethene or trichlorethylene, is mostly a chemical intermediate. EPA estimates 84% of annual production volume goes into making the refrigerant HFC-134a.

The rest has gone into degreasing, cleaning and adhesives. EPA's risk evaluation lists these consumer products that contained TCE:

• brake and parts cleaner, aerosol and liquid degreasers (including electronic degreasers), gun scrubber
• spot removers, carpet cleaner, fabric spray, film cleaner, shoe polish, hoof polish
• solvent-based adhesives and sealants, mirror edge sealant, tire repair cement, tire cleaner
• mold release, tap and die fluid, penetrating lubricant, arts and crafts fixatives and finishing sprays, toner aid

On the industrial and commercial side, the same evaluation covers vapor degreasing and cold cleaning, aerosol degreasers, heat exchange fluid, solvent-based paints and coatings, spot removers, corrosion inhibitors and processing aids. If you are checking whether a "TCE cleaner" in your shop is affected, this is the list EPA worked from.

What the trichloroethylene ban covers

The rule is codified at 40 CFR part 751, subpart D (docket EPA-HQ-OPPT-2020-0642). It covers all consumer uses and all industrial and commercial uses. Under § 751.305, it prohibits manufacture (including import and manufacture for export), processing, distribution in commerce, industrial and commercial use, and disposal to wastewater treatment, except for listed uses.

The distribution prohibition applies to everyone. After June 16, 2025, all persons, including retailers, are prohibited from distributing TCE in commerce, including making it available, for any use. The listed uses with later dates in the table below keep their own dates. The rule also excludes products with less than 0.1% TCE by weight, but that threshold doesn't apply to wastewater. EPA's November 2025 status update says most uses "were prohibited by Sept. 15, 2025."

TCE ban dates

These are the dates in the current eCFR text of § 751.305 and § 751.307 as of October 2026. Proposed changes are not in the table. Later rows are the exceptions to the general dates.

The listed processing aids with the December 2026 date are battery manufacture, polymer fiber spinning, fluoroelastomer and Alcantara manufacture, caprolactam extraction, and use as a beta-cyclodextrin precipitant. That list is separate from the longer section 6(g) exemptions below.

Time-limited exemptions

Separate section 6(g) exemptions in § 751.325 run longer. Postponing the conditions on those exemptions does not move the end dates below:

• to December 18, 2031: closed-loop vapor degreasing for rocket engine cleaning by federal agencies and contractors, and vapor degreasing of essential aerospace parts and narrow tubing for medical devices
• to December 18, 2034: Armed Forces vessels (potting, sealing and bonding compounds plus listed cleaning and degreasing), and NASA emergency use, which needs notice to EPA within 15 working days
• to December 18, 2039: specialty polymeric microporous sheet manufacturing, only at facilities already using TCE for that use before February 18, 2025
• to December 18, 2044: lead-acid battery separator manufacturing, only at facilities already using TCE for that use before February 18, 2025
• to December 18, 2074: essential laboratory activities, and wastewater disposal from cleaning up TCE-contaminated water and groundwater

Workplace limits for uses that continue

Continuing uses subject to the Workplace Chemical Protection Program must meet the requirements in § 751.315. The interim existing chemical exposure limit (ECEL) is 0.2 ppm as an 8-hour time-weighted average, with an action level of 0.1 ppm. The program requires exposure monitoring, regulated areas, an exposure control plan, and respiratory and dermal protection where needed.

For non-federal employers, initial monitoring was due June 16, 2025, ECEL compliance September 15, 2025, and the exposure control plan December 18, 2025. Federal agencies and their contractors have later dates: June 21, September 20 and December 17, 2027.

Do not confuse EPA's 0.2 ppm ECEL with the separate limits in OSHA Table Z-2. Check which workplace requirements apply to your activity.

SDS and downstream notification

For covered supply activities, § 751.321 requires the rule's restriction statement in sections 1(c) and 15 of the Safety Data Sheet (SDS). If you are reviewing a TCE MSDS, check its restriction statement against the current rule and the intended use. Applicable records must be kept for at least 5 years under § 751.323.

Delays, court cases and proposed changes

EPA moved the rule's effective date from January 16 to March 21, 2025 under the regulatory freeze. That notice left the compliance dates alone, so the March, June and September 2025 bans were not pushed back.

Thirteen petitions for review were consolidated in the Third Circuit as USW v. EPA, No. 25-1055. A temporary stay from January 2025 was lifted on March 28, 2025 for everything except the section 6(g) exemption provisions. EPA then postponed the conditions on those exemptions five times, the last to May 18, 2026. A May 5, 2026 notice postponed them until judicial review ends.

That notice also sets out the court timeline. On May 27, 2025, EPA asked the court to pause the case so it could reconsider the rule. On February 11, 2026, the Third Circuit refused and lifted its partial stay. A new briefing schedule followed on April 13, 2026.

But those postponements touch only the conditions on the 6(g) exemptions. The bans themselves stand, and EPA's main TCE page says the interim workplace protections "continue to apply during this period." One final rule changed specific dates, and a later proposal would change more:

1. An interim final rule of September 17, 2025, citing "inadvertent oversights in the original rulemaking", moved TCE as a processing aid in nuclear fuel manufacture, including supporting manufacture, processing and distribution, to September 15, 2028. It also moved certain wastewater disposal by processors, and by processors and users of TCE as a processing aid, to December 18, 2026.
2. A proposed rule of October 14, 2026 (docket EPA-HQ-OPPT-2026-7327) would move the December 18, 2026 deadline for intermediate processing, processing-aid use and related wastewater disposal to December 31, 2027, and the first HFC-134a step-down to the same date. Comments are due November 13, 2026.

The October 2026 proposal is not final. Affected sites must still plan for December 18, 2026, even though that deadline may move. The same proposal says EPA has started a separate rulemaking to reconsider the whole 2024 rule, but no proposal has been published yet. Watch the court docket and EPA's TCE page for changes.

TCE exposure and health effects

EPA found in its 2020 risk evaluation, revised in January 2023, that TCE as a whole chemical presents unreasonable risk, driven by 52 of its 54 conditions of use. The final rule names the effects behind it: immunosuppression from short-term breathing or skin contact, fetal heart defects, autoimmunity, and cancer of the liver and kidney plus non-Hodgkin lymphoma from long-term exposure.

EPA's IRIS assessment calls TCE "carcinogenic to humans" by all routes of exposure. The National Toxicology Program lists it as known to be a human carcinogen, and IARC puts it in Group 1.

Some states acted earlier. In Minnesota, since June 1, 2022, a facility that needs a state air emissions permit may not use TCE, with exceptions for closed systems with no emissions, stock held for distribution and hospitals or academic medical facilities.

All dates in this article concern TCE. PCE (perchloroethylene) has its own 2024 rule.

You can ask RegAffairs AI the same questions and open the cited sources in its answer on the TCE ban.