OVERVIEW OF PERCHLOROETHYLENE (PERC)
REGION
EUROPEAN UNION
EUROPEAN UNION
In October 2014, the European Chemical Agency (ECHA), the main authority body for the REACH-Regulation, published a Substance Evaluation Report which concluded that with all available hazardous data received on perchloroethylene (PERC), there is no need for additional regulatory actions like a re-classification, restriction or authorization of PERC.
With its current Classification under the CLP-Regulation (Regulation with regards to Chemical Classification, Labelling and Packaging - Regulation (EC) No. 1272/2008)), PERC does not meet the criteria for a classification of Substance of Very High Concern (SVHC) under the REACH-Regulation.
Nevertheless, it needs to be mentioned that on April 20th 2023, the delegated CLP-Regulation officially entered into force. One of the main changes concerns the new hazard classes PMT and vPvM (Persistent, Mobile and Toxic and very Persistent & very Mobile), which are to be used in the future to classify substances that do not accumulate in the environment but are so mobile in soils that they could enter drinking water. Additionally, it is likely that these two new hazard classes will become criteria for the identification of SVHC under REACH.
In the future, PMT and vPvM will be used to classify substances that are either persistent, mobile and toxic or very persistent and very mobile. While for many substances there are no available data yet on mobility, this is not the case for PERC. Based on existing data, statements can already be made today as to whether PERC falls under these new hazard classes.
According to the definitions in the delegated CLP-Regulation, PERC fulfils the criteria for persistent and mobile, but not for toxic. PERC is not classified as carcinogenic category 1A or 1B.
PERC is therefore not expected to be classified as a PMT substance based on current data and classification criteria.
According to the definitions in the delegated CLP-Regulation, PERC meets the definition of vP but not vM.
PERC is therefore not expected to be classified as a vPvM substance based on current data and classification criteria.
In Europe, PERC remains a viable and effective option for metal cleaning.
Brief profile: Brief Profile - ECHA (europa.eu)
UNITED STATES
Over recent years, following the 2016 amendment of the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency (EPA) has reviewed the risks associated with the use of several chlorinated solvents, including perchloroethylene (PERC or PCE). As a result, the EPA proposed regulatory measures to manage and eliminate the risks posed by these substances.
On December 18, 2024, the EPA published the 2024 PERC Rule in the Federal Register. In summary, the rule permits the continued use of PERC for vapor degreasing only if a Workplace Chemical Protection Program (WCPP) is implemented and the Existing Chemical Exposure Limit (ECEL) of 0.14 ppm is met.
A link to the 2024 PERC Rule publication can be found here.
The Rule became effective on January 17, 2025. It requires a rapid phase down of the manufacturing, processing, and distribution of PERC for all consumer uses and for many industrial and commercial workplace applications. Most of these uses must be fully phased out within less than three years.
Certain uses are allowed to continue under strict conditions and only within highly sophisticated workplaces that are important for national security, aviation, or other critical infrastructure. These permitted uses include:
• Use as a vapor degreasing solvent
• Use in petrochemical manufacturing
• Use in agricultural chemical manufacturing (originally proposed for prohibition)
• Use for cold cleaning of tanker vessels (originally proposed for prohibition)
• Use as a maskant for chemical milling
• Use in adhesives and sealants
• Processing into formulations, mixtures, or reaction products
Operators or owners of vapor cleaning applications who wish to continue using PERC must comply with several obligations under the 2024 PERC Rule, each with defined deadlines. To better understand the requirements of the WCPP and the applicable timelines, SAFECHEM recommends reviewing the EPA’s Fact Sheet, available here.
In July 2026, the EPA finalized its decision to extend certain WCPP compliance deadlines. These revised deadlines are not reflected in the currently available Fact Sheet, and it is unclear whether an update will be issued. The new compliance deadlines are as follows:
• Conduct initial exposure monitoring by June 21, 2027
• Meet the ECEL, establish a regulated area, provide required respiratory PPE, and implement a respiratory PPE program by September 20, 2027
• Establish and implement an exposure control plan by December 20, 2027
A central element of the WCPP is compliance with the ECEL to protect potentially exposed individuals. For PERC, the WCPP specifies an ECEL of 0.14 ppm and an ECEL action level of 0.1 ppm. The ECEL represents the exposure level at or below which individuals are protected against unreasonable risk. If exposure exceeds the action level, additional control measures must be implemented, and exposure monitoring must be conducted more frequently until the action level of 0.1 ppm is achieved.
Unlike the Final Rule for trichloroethylene (TRIC), the 2024 PERC Rule was not affected by President Trump’s January 20, 2025, memorandum titled “Regulatory Freeze Pending Review.” Nevertheless, several plaintiffs, including chemical manufacturers, have filed legal challenges against the EPA’s new rules in federal circuit courts. These lawsuits argue that the rule exceeds the EPA’s statutory authority and are inconsistent with TSCA and the Administrative Procedure Act.
The federal Judicial Panel on Multidistrict Litigation (JPML) has consolidated these challenges and assigned them to the Fifth Circuit Court of Appeals. A revised Final Rule is anticipated in 2027.
SAFECHEM will closely monitor these developments and keep stakeholders informed. In the meantime, SAFECHEM strongly recommends becoming thoroughly familiar with the current PERC Final Rule and its requirements.
CHINA
China has filed a notice in relation to the so-called Blue Sky Plan in 2019, which aims to improve air quality in several big cities in China. This notice was the starting point for several legislative actions regulating and restricting air quality-affecting topics.
Under this plan a new Chinese standard was published in 2020 which regulates volatile organic compounds (VOC) in cleaning agents (GB 38508-2020). The regulation was released as a national standard in March 2020, followed by implementation on December 1st 2020.
The standard provides limit requirements for VOC, test methods and package marks of cleaning agents. This standard is applicable to cleaning agents containing VOC produced and used in industrial production and service activities. This standard is NOT applicable to cleaning agents used in aerospace, nuclear industry, military industry and semiconductor (including integrated circuit) manufacturing. These areas of industrial production are exempted.
Perchloroethylene (PERC) is listed in this standard and therefore falls under this restriction. According to the standard, cleaning agents with a content of ≥ 20% of PERC may for example not be used in industrial production and service activities. Cleaning agents with a VOC content of ≥ 900 g/L may not be used in industrial production and service activities. The standard also defines the limit of VOC content in a cleaning product and therefore alternative formulations are needed in order to meet the requirement.
PERC supplied by SAFECHEM in China can only be used in the industries exempted from the standard, which include aerospace, nuclear industry, military industry and semiconductor (including integrated circuit) manufacturing.
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