1 May 2021

Initially the Toxic Substances Control Act (TSCA) by Environmental Protection Agency (EPA) applied only to the production, importing, and processing of chemicals.

This new rule has added restrictions on the TSCA chemicals present in the article. It has created an impact on many manufacturers for the first time. It is time to reconsider your compliance status to address compliance risks because of these new additions.

As per Jan 6, 2021, 5 Persistent, Bioaccumulative and Toxic (PBT) substances are restricted under TSCA are:

  • PIP 3:1- Phenol, isopropylated phosphate
  • DecaBDE- Decabromodiphenyl ether
  • HCBD – Hexachlorobutadiene
  • PCTP – Pentachlorothiophenol
  • 2,4,6- TTBP – 2,4,6-tris(tert-butyl) phenol

Out of the above 5 chemicals, PIP 3:1 and DecaBDE, are commonly seen in electronic equipment.

  • pbt chemicals TSCA has provided the restriction threshold only for PCTP (1% at product or mixture level) and 2,4,6- TTBP (≤ 0.3% by weight in any container with a volume of less than 35 gallons), for all the other three substances are fully restricted.
  • PIP 3:1 is the chemical that is restricted on mass scale because of its wide range presence in electronic equipment. It’s used in Cables, all type of Controllers, Insulators, Connectors, Computers, Circulators, Fans, Batteries, Display, Liquid crystals, Cylinders, Gas Boxes, Magnets, Motors, and Oscillators.
    • The more restriction is on PIP 3:1, because its not restricted in any of the regulations before. Whereas, DecaBDE is already restricted under RoHS and listed in REACH SVHC.
    • The Deadline to remove PIP 3:1 from the products that are sold or manufactured in US is Sep 4, 2021.The deadline for DecaBDE removal from products , was March 8, 2021 and for the products that are exported to US is Jan 6, 2022.
  • 2,4,6- TTBP should be removed from the products and commercial distribution should be stopped after Jan 6, 2026. It is found in fuel, fuel related additives and cleaners.
  • Manufacturing, processing, and distribution of HCBD/HCBD containing products was prohibited from March 8, 2021. It’s used as a halogenated aliphatic hydrocarbon.
  • Manufacturing, processing PCTP/ PCTP containing products was prohibited from March 8, 2021 and commercial distribution should be stopped after Jan 6, 2022. Mainly industrial uses and no consumer uses.

Talk one of global compliance experts to know how the new additions to TSCA restricted PBTs and stay compliant.