The Toxic Substances Control Act (TSCA) is a law in the United States, which regulates the presence of certain chemicals, including POP (3:1). The section 6 (h) specifically addresses the use of chemicals that are persistent, bioaccumulation, and toxic (PBT):
This chemical stands for phenol, isopropylated, phosphate (3:1). It has a multitude of functions and can be employed for different applications. Its versatile nature makes it one of the most important chemicals out of the five listed above. The table below illustrates some of the products containing PIP.
Type of Applications (Examples) |
Adhesive |
Epoxy resin |
Flame retardant |
Polyurethane Foam |
Lubricant |
Plasticizer |
PIP requires special regulation due to its hazardous nature. It represents a significant danger to the aquatic life:
Moreover, research shows that that PIP can have negative consequences on organs such as the liver and the lungs.
A series of restrictions have been announced by the United States Environmental Protection Agency (EPA) concerning the use of PIP:
The intention of these restrictions is to eventually end the manufacturing and distribution of articles with PIP (3:1).
On March 8, 2021, EPA explained its intention not to fully enforce the restrictions mentioned above for a period of 180 days, which ends on September 4, 2021. EPA will use this period to review its restrictions concerning the five PBT substances.
Despite the 180-day period, manufacturers and distributors of this chemical must make certain changes to comply with the final rule:
As of the 7th of July, 2021, the written notification can be completed in one of 2 ways:
Please note that medical devices, regulated under FDA, are excluded from the scope.
Enviropass suggests companies potentially affected by the new rule to use its EPEC form. This Enviropass Product Environmental Compliance (EPEC) form allows the collection of information needed to assess whether the articles handled contain PIP (3:1), and other restricted substances under RoHS, REACH-SVHC, California Prop. 65, and more!
Ask Enviropass for support!