TSCA RESTRICTIONS OF 5 PBT SUBSTANCES IN PRODUCTS

The US Toxic Susbtances Control Act (TSCA) addresses hazardous chemicals in liquids, mixtures, and articles/products. Here is the curent TSCA restrictions in products.

What Action is the EPA Taking?

The Frank R. Lautenberg Chemical Safety for the 21st Century Act has initiated the US Toxic Substances Control Act (TSCA) reform.

According to this reform, the federal Environmental Protection Agency (EPA) must take action on particular chemical substances identified as persistent, bioaccumulative, and toxic (PBT).

As a result, after thorough Federal TSCA Work Plan for Chemical Assessments, the EPA has decided to restrict the use of the following five substances in products (ref. 40 CFR Part 751):

PIP (3:1), or Phenol, Isopropylated Phosphate (3:1);
DecaBDE, or Decabromodiphenyl Ether. DecaBDE is also one of the PBDEs restricted under RoHS;
PCTP, or Pentachlorothiophenol;
2,4,6-TTBP, or 2,4,6-tris(tert-butyl)phenol;
HCBD, or Hexachlorobutadiene. The EU Persistent Organic Pollutants (POP) regulation also rules HCBD.

The TSCA Restrictions of Substances in Products

The following table portrays substances currently regulated by the US EPA, under the TSCA:

Substance Name (Short Form)	CAS_RN_#_	Where Used (Examples)	Restriction in Products (Simplified)	Effective Dates (Simplified)	Reference
PIP (3:1)	68937-41-7	Plasticizer and flame retardant in plastics (PVC and others), and resins In adhesives and sealants Functional fluids in aircraft and industrial machinery	Prohibition of the manufacture in products and articles (including import) and processing; Exemptions apply to the general prohibition. For example in some recycled plastics or some aerospace, automotive, or military applications; Obligation to inform customers via Safety Data Sheet (SDS) or labeling; Recordkeeping requirements.	Extension of the grace period until October 31, 2024. However, different compliance dates apply to exemptions.	Federal Register Vol. 86, No. 3, RIN 2070–AK58 Compliance Date Extension 6015.5-03-OCSPP
DecaBDE	1163-19-5	Flame retardant in: Wires, cables, and rubber casings Electronic equipment casings Building and construction materials	Prohibition of the manufacture in products and articles (including import) and processing; Some exemptions to the prohibition apply, for example to recycled plastics; Recordkeeping requirements.	March 8, 2021. However, different compliance dates apply to exemptions.	Federal Register Vol. 86, No. 3, RIN 2070–AK34
PCTP	133-49-3	Rubber products	Concentration limit of 1% w/w in articles; Recordkeeping of products and articles containing PCTP.	March 8, 2021	Federal Register Vol. 86, No. 3, RIN 2070–AK60
2,4,6-TTBP	732-26-3	Fuel, oil, and lubricant additive Fuel injector cleaner	Concentration limit of 0.3% w/w: in any containers below 35 gallons; as an oil or lubricant additive in any container size.	January 6, 2026	Federal Register Vol. 86, No. 3, RIN 2070–AK59
HCBD	87-68-3	Production of solvents	Prohibition of the manufacture in products and articles (including import) and processing; Possible exemptions to unintentional production of HCBD as a byproduct; Recordkeeping requirements.	March 8, 2021	Federal Register Vol. 86, No. 3, RIN 2070–AK61

Should you have any questions on the TSCA new PBT restrictions in products or need to assess products…

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