RegAffairs Question
Is methylene chloride banned in the US?
No, methylene chloride is not banned outright in the US. Its uses are heavily restricted. EPA's May 2024 TSCA section 6 rule bans it for all consumer uses and most industrial and commercial uses, but EPA states that it "is not finalizing a complete ban on methylene chloride." Some uses continue under strict workplace controls. (89 FR 39254, May 8, 2024)
Approach: I searched EPA's TSCA risk evaluations, FDA's cosmetics regulations (21 CFR Part 700), California's consumer products rules, OSHA's PEL tables and CPSC's banned-substances list. The EPA rule itself (40 CFR Part 751) is not in the datasets, so I read it in the Federal Register on govinfo.gov and on EPA's website.
Federal rules under TSCA (EPA)
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Why EPA acted: The 2020 risk evaluation found unreasonable risk to health for many uses, including adhesives and sealants and consumer aerosol degreasers [1][2].
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What the 2024 rule does (effective July 8, 2024):
- It bans the manufacture (including import), processing and distribution of methylene chloride for all consumer use.
- It bans most industrial and commercial uses, with the ban delayed for two of them.
- 13 uses can continue under a Workplace Chemical Protection Program (WCPP). Workers' exposure must stay below 2 ppm as an 8-hour average.
- It includes a 10-year exemption for NASA, a de minimis threshold, and duties to keep records and notify customers downstream. (source)
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Uses that continue under the WCPP, according to EPA:
- chemical production, including HFC-32
- battery separators for electric vehicles
- processing aids in closed systems
- laboratories
- plastics and rubber manufacturing, including polycarbonate
- solvent welding
- specific uses by NASA, the Department of Defense and the FAA
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Pharmaceutical uses are not covered by TSCA, so the rule does not regulate them. EPA estimates they are about 35% of annual production volume.
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Earlier ban: a 2019 rule (84 FR 11420) already banned it in consumer paint and coating removers.
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When the bans apply: compliance dates for the bans "began as early as February 3, 2025" (90 FR 22214). EPA says most banned uses are fully phased out within 2 years of the April 2024 rule.
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Extension for laboratories: a final rule effective December 15, 2025 gave non-federal laboratories 18 more months to meet the WCPP:
- initial monitoring by November 9, 2026
- regulated areas and the exposure limit by February 8, 2027
- exposure control plan by May 10, 2027
Other US rules
- Cosmetics (FDA): "Any cosmetic product that contains methylene chloride as an ingredient is deemed adulterated" (21 CFR 700.19) [3]. That makes it effectively banned in cosmetics.
- California (CARB, 17 CCR 94509(m)): this separately bans it in many consumer product categories.
- Workplace (OSHA): OSHA regulates it through its own standard, 29 CFR 1910.1052 [8].
- CPSC: I found no methylene chloride entry in the CPSC banned hazardous substances list (16 CFR Part 1500).
Which workplace uses are still allowed?
Under EPA's 2024 TSCA rule (40 CFR Part 751, Subpart B), 13 workplace uses may continue indefinitely under the Workplace Chemical Protection Program (WCPP). Two more uses are allowed only until May 8, 2029, and NASA has an emergency-use exemption until May 8, 2034. Every other industrial and commercial use has been banned since April 28, 2026 (§ 751.107(b)(6)). (89 FR 39254)
Approach: I read the rule as published in the Federal Register on govinfo.gov, plus the November 2025 amendment for laboratories. 40 CFR Part 751 is not in the datasets I can search, and the eCFR consolidated text would not open this time.
1. Uses that continue under the WCPP (§ 751.109(a)) These apply "including manufacturing and processing for export":
- Manufacturing (domestic manufacture)
- Manufacturing (import)
- Processing as a reactant
- Processing: incorporation into a formulation, mixture or reaction product
- Processing: repackaging
- Processing: recycling
- Industrial and commercial use as a laboratory chemical
- Paint and coating removal from safety-critical, corrosion-sensitive components of aircraft and spacecraft
- Use as a bonding agent for solvent welding
- Use as a processing aid
- Use for plastic and rubber products manufacturing
- Use as a solvent that becomes part of a formulation or mixture used inside a manufacturing process, where the methylene chloride "will be reclaimed"
- Disposal
What the WCPP requires
- Exposure limits: no one may be exposed above 2 ppm as an 8-hour average (the ECEL), or above 16 ppm over 15 minutes (the EPA STEL). The action level is 1 ppm.
- Other duties: regulated areas, exposure monitoring, an exposure control plan that follows the hierarchy of controls, and supplied-air respirators where exposure is above the limits.
- Deadlines for most owners and operators:
- initial monitoring by May 5, 2025
- exposure limits and regulated areas after August 1, 2025
- controls and exposure control plan by October 30, 2025
- Deadlines for federal agencies and their contractors:
- initial monitoring by November 9, 2026
- exposure limits after February 8, 2027
- exposure control plan by May 10, 2027
- The Department of Defense can extend the controls deadline to May 7, 2029 if building work is needed.
- Laboratories: a rule effective December 15, 2025 moved non-federal laboratories onto the federal dates. Their initial monitoring is therefore due by November 9, 2026, about two weeks from now. The other uses keep the earlier dates. (90 FR, Nov 13, 2025)
2. Uses allowed only until May 8, 2029 (§ 751.107(b)(8)–(9))
- Refinishing wooden furniture, decorative pieces and architectural fixtures of artistic, cultural or historic significance (paint and coating removal). Interim conditions under § 751.117 have applied since July 8, 2024:
- a regulated area
- local exhaust ventilation
- at minimum an APF 50 supplied-air respirator or SCBA, or a respirator chosen from monitoring results
- a record of each refinishing job
- Adhesives and sealants in aircraft, space vehicle and turbine applications, for structural and safety-critical non-structural uses.
3. NASA emergency exemption, until May 8, 2034 (§ 751.115(b)) NASA and its contractors may use methylene chloride in an emergency for seven named uses:
- cold cleaning
- aerosol spray degreasers and cleaners
- adhesives, sealants and caulks
- adhesive and caulk removers
- metal non-aerosol degreasers
- non-aerosol degreasers and cleaners
- solvent that becomes part of a formulation or mixture
The conditions are:
- An emergency means immediate action is needed within 15 days or less.
- There must be no technically and economically feasible safer alternative.
- NASA must notify EPA within 15 working days.
- The WCPP applies "to the extent technically feasible".
Other rules that apply
- Small amounts: products containing less than 0.1% by weight are outside the restrictions (§ 751.101(b)). This threshold does not apply to the consumer paint-remover ban in § 751.105.
- Export only: making, processing or distributing methylene chloride solely for export, under the TSCA section 12(a)(1) conditions, is outside the § 751.107 bans.
- Retail: no methylene chloride or products containing it may go to retailers (after February 3, 2025), and retailers may not sell it for any use (after May 5, 2025). Permitted workplace users therefore have to buy it through non-retail distribution.
Is it banned in the UK too?
No. Methylene chloride (dichloromethane) is not banned in Great Britain, and GB has no equivalent of EPA's broad 2024 ban. The only GB restriction under UK REACH is Annex XVII entry 59, and it covers paint strippers only. It is also banned in cosmetics. Every other industrial use is controlled through workplace exposure limits, not banned.
Approach: I searched HSE's GB REACH lists (restrictions, the Candidate List and the Authorisation List), the UK REACH text as kept in GB law on legislation.gov.uk (version dated 1 April 2026), the GB Mandatory Classification and Labelling (MCL) list, HSE's EH40 exposure limits and the GB Cosmetics Regulation. These are all Great Britain sources; I did not check Northern Ireland.
1. UK REACH Annex XVII, entry 59 (paint strippers only) [9][10]
- Scope: paint strippers containing 0.1% or more by weight of dichloromethane. Products below 0.1% are outside the entry.
- The ban: such paint strippers "shall not be":
- placed on the market for the first time for the general public or professionals after 6 December 2010
- placed on the market for the general public or professionals after 6 December 2011
- used by professionals after 6 June 2012
- Who counts as a professional: someone stripping paint for work "outside an industrial installation". An industrial installation is "a facility used for paint stripping activities".
- Derogation: the competent authority "may" allow specially trained professionals to use these paint strippers for certain activities. The professional must hold a certificate or other evidence of training (risks, ventilation, PPE).
- Industrial installations: they "may" still use these paint strippers, but only if they meet minimum conditions [11]:
- local exhaust ventilation plus forced ventilation
- lidded strip tanks and wash tanks
- pumps and pipework for transferring the stripper
- PPE and, where needed, respiratory protection
- training for operators
- Label: the products must carry the wording "Restricted to industrial use and to approved professionals — verify where use is allowed."
2. Cosmetics: prohibited Dichloromethane is listed in Annex II (prohibited substances) of the GB Cosmetics Regulation, reference number 1389 [12].
3. No authorisation requirement When I searched the GB REACH lists by its CAS number (75-09-2), only the entry 59 restriction came up. It is not on the GB Candidate List or the GB Authorisation List, and I found no UK REACH authorisation decisions for it [9].
4. Classification (GB MCL list) Its legally binding classification is Carc. 2, H351, with pictogram GHS08 and the signal word "Warning" (index 602-004-00-3) [13].
5. Workplace exposure limits (HSE EH40) The GB limits are much higher than the US ones:
| GB limit (EH40) | US limit (EPA WCPP) | |
|---|---|---|
| 8-hour average | 100 ppm (353 mg/m³) | 2 ppm |
| 15-minute short-term | 200 ppm (706 mg/m³) | 16 ppm |
EH40 also flags dichloromethane with "Sk", a skin notation, and a biological monitoring guidance value (BMGV) [14].
What this means in practice: in GB you can still sell dichloromethane to the general public and use it at work for anything other than paint stripping and cosmetics, for example as a degreaser, adhesive, laboratory or process solvent. Those uses face no GB REACH restriction; they are managed through the workplace exposure limits above and GB CLP labelling. In the US, the same consumer uses are banned.