Trichloroethylene Ban in the US
Is trichloroethylene banned in the US?
Mostly, but not completely. EPA's final rule under section 6 of the Toxic Substances Control Act (TSCA), published December 17, 2024, bans making and importing trichloroethylene (TCE), and bans most processing, distribution and use. Every consumer use is prohibited. But some industrial uses are being phased out on later dates, some time-limited exemptions run into the 2030s, and parts of the schedule have been postponed or are proposed for extension. So TCE is still legally used in the US for certain listed purposes.
The federal rule (40 CFR Part 751, Subpart D, 89 FR 102568)
- It took effect on January 16, 2025. It covers making, importing, processing, distributing, using and disposing of TCE (CAS 79-01-6). It does not apply to products containing less than 0.1% TCE by weight, except wastewater. (GovInfo PDF)
- The main prohibition dates in § 751.305(b), each with exceptions for the uses listed later in that section:
- Making and importing: prohibited after March 17, 2025.
- Processing and distribution: prohibited after June 16, 2025. Retailers are prohibited from selling or offering TCE for any use from that date.
- Industrial and commercial use, and disposal to wastewater treatment works: prohibited after September 15, 2025.
- Later phase-outs include:
- Batch vapor degreasing: December 18, 2025.
- Use as a reactant/intermediate and in listed processing-aid uses (battery manufacture, polymer fiber spinning, caprolactam manufacture, and others): December 18, 2026.
- Energized electrical cleaners: December 18, 2027.
- Aerospace adhesives and lithium battery separator manufacturing: December 18, 2029.
- Vapor degreasing of aerospace parts and medical-device narrow tubing: December 18, 2031.
- Intermediate for making HFC-134a: June 18, 2033.
- Certain asphalt testing, rocket booster nozzle and Armed Forces vessel uses: December 18, 2034.
- Where a use is allowed to continue for a while, workers are protected by an interim exposure limit of 0.2 ppm (8-hour average), with an action level of 0.1 ppm.
What has changed since the rule was published (from EPA's status update and TCE risk management page)
- Court stay: The Third Circuit stayed the rule in January 2025. It lifted the stay on March 28, 2025, except for the conditions attached to the time-limited exemptions for critical or essential uses (TSCA section 6(g)). EPA says most prohibitions took effect as scheduled.
- Exemption conditions: EPA postponed these conditions several times. In May 2026 it postponed them until the court case ends.
- September 2025 interim final rule: This extended the September 15, 2025 deadline for two uses: TCE as a processing aid in nuclear fuel manufacture, and wastewater disposal by processors and users. The EPA page does not give the new dates.
- October 2026 proposal (docket EPA-HQ-OPPT-2026-7327): EPA proposes moving the reactant/intermediate deadline from December 18, 2026 to December 31, 2027. The first step-down in the HFC-134a phase-out would also move, from June 7, 2027 to December 31, 2027. This is only a proposal; the dates already on the books still apply until a final rule changes them.
Other US rules
- Workplace limits: OSHA's legal limits remain 100 ppm (8-hour average) and 200 ppm ceiling, with a 300 ppm peak for up to 5 minutes in any 2 hours [1][2].
- Other federal laws: EPA's risk evaluation scope notes TCE is a hazardous air pollutant under the Clean Air Act, a regulated drinking water contaminant, and a toxic pollutant under the Clean Water Act [3].
- Significant New Use Rule: EPA lists one for TCE. It requires notice to EPA before making or processing it for cleaners and solvent degreasers, film cleaners, hoof polishes, lubricants, mirror edge sealants and pepper spray [4].
- Minnesota: Under Minn. Stat. § 116.385, since June 1, 2022, a facility that needs a state air emissions permit "may not use trichloroethylene" there. Exceptions cover closed systems with no emissions, holding stock for distribution, and hospitals and academic medical facilities.
- California: TCE is on the state's Candidate Chemicals List and Proposition 65. Those listings are hazard designations, not a ban [5].
Approach: I searched EPA's TSCA risk evaluation records, EPA ChemView, OSHA's limit tables and California's Candidate Chemicals List, then read the final rule on GovInfo, EPA's TCE pages and the Minnesota statute. The Federal Register and eCFR websites would not open, so I took the post-2024 amendments from EPA's own pages. I did not check other states.
Which products and uses are affected?
Essentially every use of TCE, and every product made with it, is affected. The rule (40 CFR Part 751, Subpart D) covers manufacturing (including import and manufacturing for export), processing, distribution in commerce, all industrial and commercial uses, all consumer uses, and disposal of TCE to wastewater treatment. Consumer products have no carve-out: after June 16, 2025, retailers "are prohibited from distributing in commerce (including making available) TCE for any use." What remains is a fixed list of industrial, defence, aerospace, laboratory and clean-up uses, each with its own end date (final rule, 89 FR 102568, § 751.305(a)–(b)).
What counts as a TCE product (§ 751.301)
- The rule does not apply to products containing less than 0.1% TCE by weight. That threshold does not apply to wastewater.
- It also excludes byproduct TCE processed within a site-limited, physically enclosed system that is part of the same manufacturing process. This exclusion does not allow TCE in any resulting product above the 0.1% threshold.
Product types that become illegal to sell or use EPA's TCE risk evaluation scope lists the industrial, commercial and consumer uses it covered. Unless a use appears in the exemptions further down, it is prohibited:
- Cleaning and degreasing: batch vapor degreasers (open-top and closed-loop), in-line and conveyorized degreasers, cold cleaners, aerosol spray degreasers and cleaners, mold release [6][7]
- Lubricants: tap and die fluid, penetrating lubricant [7]
- Adhesives and sealants: solvent-based adhesives and sealants, tire repair cement/sealer, mirror edge sealant [7]
- Functional fluids, coatings and chemicals: heat exchange fluid (closed systems), diluent in solvent-based paints and coatings, corrosion inhibitors and anti-scaling agents [7][8]
- Household and automotive products: carpet cleaner, cleaning wipes, spot remover, fixatives and finishing spray coatings, toner aid, brake and parts cleaner [8]
- Other: shoe polish, hoof polishes, pepper spray, lace wig and hair extension glues, gun scrubber, and other miscellaneous uses [9]
- Processing: formulation into cleaning solvents, adhesives, lubricants, paints and other mixtures; incorporation into articles; repackaging; recycling [6]
When each activity stops (§ 751.305(b))
| Activity | Prohibited after |
|---|---|
| Manufacture and import (general) | Mar 17, 2025 |
| Processing and distribution, including all retail sale | Jun 16, 2025 |
| All other industrial and commercial use; disposal to pre-treatment, treatment or publicly owned treatment works (POTWs) | Sep 15, 2025 |
| Batch vapor degreasing (open-top and closed-loop): manufacture / processing / use | Jun 16, 2025 / Sep 15, 2025 / Dec 18, 2025 |
| Reactant/intermediate (except HFC-134a) and processing aids (battery manufacture; polymer fiber spinning, fluoroelastomer and Alcantara manufacture; caprolactam extraction; beta-cyclodextrin precipitant): manufacture / processing and use | Jun 10, 2026 / Dec 18, 2026 |
| Energized electrical cleaners | Dec 18, 2027 |
| Adhesives and sealants for essential aerospace applications | Dec 18, 2029 |
| Lithium battery separator manufacturing (including wastewater disposal) | Dec 18, 2029 |
| Batch vapor degreasing for land-based DoD defense systems | Dec 18, 2029 |
| Asphalt testing using manual centrifuge processes | Dec 18, 2029 |
| Closed-loop vapor degreasing for rocket engine cleaning (Federal agencies and contractors) | Dec 18, 2031 |
| Vapor degreasing of essential aerospace parts and narrow tubing for medical devices | Dec 18, 2031 |
| Intermediate for HFC-134a | Jun 18, 2033 |
| All asphalt testing and recovery | Dec 18, 2034 |
| Rayon fabric scouring for rocket booster nozzles | Dec 18, 2029, or Dec 18, 2034 if records show a final pre-launch test was completed using an alternative to TCE |
| Armed Forces vessels: potting, sealing and bonding compounds, and listed cleaning and degreasing tasks | Dec 18, 2034 |
| NASA emergency use | Dec 18, 2034 |
| Specialty polymeric microporous sheet manufacturing | Dec 18, 2039 |
| Lead-acid battery separator manufacturing | Dec 18, 2044 |
| Essential laboratory activities; wastewater disposal from clean-up of TCE-contaminated water and groundwater | Dec 18, 2074 |
Notes on the later dates:
- HFC-134a: processing is capped at 75% of each manufacturer's baseline from June 7, 2027, 50% from June 18, 2029 and 25% from June 18, 2031 (§ 751.307).
- Conditions on the long-running uses: the lead-acid separator and microporous sheet uses are limited to facilities already using TCE for them before February 18, 2025. The NASA emergency exemption covers degreasing, cold cleaning, aerosols, lubricants, adhesives, heat exchange fluid, corrosion inhibitors and processing aids, and requires notice to EPA within 15 working days (§ 751.325(b)).
What the remaining users must do
- Workplace Chemical Protection Program (§ 751.315): applies to uses continuing beyond December 18, 2025. It requires exposure at or below 0.2 ppm (8-hour average) with a 0.1 ppm action level, exposure monitoring, regulated areas, an exposure control plan, and respirators and gloves where needed.
- Energized electrical cleaners (§ 751.317): prescribed respirators and gloves, or the full protection program instead.
- POTWs: must screen incoming industrial wastewater for TCE, or follow the full protection program (§ 751.319).
- Downstream notification: manufacturers from February 18, 2025, and processors and distributors from June 16, 2025, must put the rule's set restriction statement in sections 1(c) and 15 of the Safety Data Sheet (§ 751.321).
- Records: must be kept for at least 5 years (§ 751.323).
Changes since December 2024 (from the EPA pages cited in my previous answer):
- A September 2025 interim final rule extended the deadline for two uses: TCE as a processing aid in nuclear fuel manufacture, and wastewater disposal by processors and users. That use is not in the table above, which reflects the original rule.
- The conditions attached to the time-limited exemptions are postponed until the court case ends.
- An October 2026 proposal would move the reactant/intermediate deadline and the first HFC-134a step-down to December 31, 2027. Until a final rule is adopted, the table dates still apply.
Approach: I read EPA's TSCA risk evaluation scope for TCE, the source of the product-type list, and the regulatory text of the final rule on GovInfo. The scope document is from before the final risk evaluation, so I took every legal prohibition and date from the rule itself.
Have the phase-out dates been delayed?
Yes, but only in part. The main bans on manufacture, processing, distribution and most uses have not been moved. EPA has extended two specific deadlines by interim final rule, postponed the conditions attached to the time-limited exemptions, and proposed two more extensions in October 2026. Everything else in the 2024 rule keeps its original schedule.
Changes in force
| Action | What it changed |
|---|---|
| Delay of effective date, 90 FR 8254 (Jan 28, 2025) | Pushed the rule's effective date from January 16, 2025 to March 21, 2025, under the "Regulatory Freeze Pending Review" memorandum [10] |
| Court stay (Third Circuit) | On March 28, 2025 the court lifted its administrative stay for every part of the rule except the TSCA section 6(g) exemption provisions (EPA status update) |
| Exemption conditions postponed | EPA postponed the conditions attached to the 6(g) exemptions to June 20, 2025, then by another 60 days to August 19, 2025 (90 FR 26453) [11]. In May 2026 it postponed them "until judicial review concludes" (EPA TCE page) |
| Interim final rule, 90 FR 44772 (effective Sep 15, 2025) | Two uses would otherwise have been banned on September 15, 2025. Nuclear fuel processing aid: that use, and the manufacture, processing and distribution supporting it, is now prohibited from September 15, 2028. Wastewater disposal: disposal of TCE to wastewater by processors, and by processors and industrial/commercial users of TCE as a processing aid, is now prohibited from December 18, 2026. The downstream-notification and Safety Data Sheet deadlines were also changed to reflect the new nuclear fuel date [12] |
EPA said it made the September 2025 changes because of "inadvertent oversights in the original rulemaking" and "serious concerns that the facilities at issue will be unable to comply" by the original deadlines. It took comments until October 17, 2025, so the interim rule could still be amended [12].
Proposed, not yet final (October 14, 2026, docket EPA-HQ-OPPT-2026-7327)
- Processing as a reactant/intermediate, use as an industrial/commercial processing aid, and the related wastewater disposal would move from December 18, 2026 to December 31, 2027.
- The first step of the HFC-134a phase-out would move from June 7, 2027 to December 31, 2027.
- EPA describes the proposal as keeping the TCE ban in place (EPA TCE page).
- Until a final rule is published, the December 18, 2026 date still applies. That date is now under eight weeks away.
Not changed: I found no action moving the other dates in § 751.305. That covers the March 17, 2025 manufacture/import ban, the June 16, 2025 processing, distribution and retail ban, the September 15, 2025 ban on most other uses, and the later dates from 2027 to 2074.
Approach: I read the Federal Register documents for the TCE rule held in our EPA rules and notices records, plus EPA's TCE status and risk management pages. I couldn't confirm the May 2026 postponement in the Federal Register itself: the document number on EPA's page brings up an unrelated notice, and the Federal Register website would not open. That item rests on EPA's page alone.