OVERVIEW OF TRICHLOROETHYLENE (TRIC)

UNITED STATES

Over recent years, following the 2016 amendments to the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency (EPA) has evaluated the risks associated with numerous chlorinated solvents, including trichloroethylene (TCE), and has introduced risk management measures aimed at eliminating unreasonable risks to human health and the environment. On December 17, 2024, EPA published the final risk management rule for TCE in the Federal Register. The rule generally prohibits the manufacture, processing, distribution, and use of TCE, including its use in vapor degreasing applications, while allowing certain critical uses to continue for a limited period under specific conditions. 

For the uses permitted to continue beyond the standard phase-out period, EPA established a Workplace Chemical Protection Program (WCPP). The WCPP is intended to protect potentially exposed workers through exposure monitoring and risk management measures. For TCE, the WCPP includes:

• An interim existing chemical exposure limit (interim ECEL) of 0.2 ppm (8-hour time-weighted average).
• An interim ECEL action level of 0.1 ppm.

The interim ECEL of 0.2 ppm represents the exposure level at or below which workers are expected to be protected from unreasonable risk. If exposure exceeds the action level, additional monitoring and risk reduction measures are required until exposures are consistently reduced below the action level.

Uses Eligible for Extended Phase-Out Periods

The following uses were granted extended phase-out periods under TSCA section 6(g) exemptions and are therefore subject to later prohibition dates:

For most exempted vapor degreasing applications and battery-separator manufacturing uses, EPA established a ten-year phase-out period ending on December 17, 2034. Several processing-aid and process-solvent applications are subject to a significantly shorter phase-out period and are currently scheduled for prohibition on December 18, 2026. EPA has proposed extending this deadline to December 31, 2027, but the proposal has not yet been finalized. Asphalt testing applications remain subject to phase-out dates in 2027 and 2029, respectively. 

Regulatory Developments Since Publication of the Final Rule

The Final Rule originally became effective on January 16, 2025. However, following the January 20, 2025 memorandum issued by President Trump regarding a regulatory freeze pending review, EPA delayed the effective date until March 21, 2025. 

On March 21, 2025, EPA further postponed the effectiveness of the requirements associated with the TSCA section 6(g) exemptions by 90 days pending judicial review. Additional extensions followed while litigation challenging the rule remained ongoing. 

Current Status of TSCA Section 6(g) Exemptions

In May 2026, EPA announced that the effectiveness of the conditions attached to the TSCA section 6(g) exemptions, including the WCPP requirements and associated exposure limits, would remain postponed until the completion of judicial review. Rather than issuing another fixed-duration extension, EPA tied the postponement directly to the conclusion of the litigation and stated that a new effective date would be established thereafter. 

As a result, the exempted uses listed above currently remain subject to the regulatory status that existed before the exemption conditions became effective. Companies relying on these exempted uses should nevertheless continue to monitor developments closely, as the outcome of the litigation may significantly affect future compliance obligations. 

September 2025 Compliance Date Extension

In September 2025, EPA published an interim final rule extending compliance deadlines for two specific uses that would otherwise have become prohibited on September 15, 2025. EPA concluded that additional transition time was necessary based on information received from affected stakeholders and government agencies. 

The revised compliance dates are:

• TCE used as a processing aid in the manufacture of nuclear fuel: prohibition date extended to September 15, 2028.
• Disposal of TCE to wastewater by processors of TCE and by processors and industrial/commercial users employing TCE as a processing aid: prohibition date extended to December 18, 2026. 

EPA emphasized that the underlying TCE ban remains in place and that the extensions merely provide additional time for affected industries to transition to alternatives. 

Proposed Compliance Date Extensions Published in October 2026

On October 14, 2026, EPA proposed further targeted extensions while maintaining the overall objective of phasing out TCE. The proposal would: 

• Extend the compliance date for processing TCE as a reactant or intermediate, industrial and commercial use of TCE as a processing aid, and associated wastewater disposal activities from December 18, 2026, to December 31, 2027.
• Extend the first phase-down milestone for TCE used as an intermediate in HFC‑134a manufacturing from June 7, 2027, to December 31, 2027. 

EPA stated that these proposed extensions are intended to provide reasonable transition periods for affected industries while preserving the long-term objective of eliminating unreasonable risks associated with TCE. Interim workplace protection requirements established under the 2024 rule would continue to apply during any extension period. regulations.gov

Overall Regulatory Outlook

The December 2024 TCE Final Rule continues to represent EPA's policy objective of eliminating nearly all uses of TCE in the United States. While the majority of uses are being phased out or prohibited, several critical applications have been granted longer transition periods due to national security, aerospace, medical device, battery manufacturing, and other strategic industrial considerations. Ongoing litigation and subsequent EPA actions have delayed implementation of certain exemption-related requirements, and additional compliance date extensions remain under consideration. Consequently, companies manufacturing, processing, or using TCE should continue to monitor EPA announcements, judicial decisions, and future rulemaking activities closely. epa.gov, federalregister.gov, regulations.gov

Please find the link to the exemptions listed under TSCA 6(g) and for which the effective date of all requirements were postponed here.

SAFECHEM will closely monitor the process and keep everyone informed about the future developments.

Additional Links: 

Please note that deadlines mentioned in the Final Rule, as well as the Fact Sheet and Compliance Guide (Links below) are now also effected by the latest developments and might not be correct anymore.

Final Interim Rule: Federal Register :: Trichloroethylene; Regulation Under the Toxic Substances Control Act (TSCA); Compliance Date Extension
Fact Sheet: Regulation of TCE Under TSCA: Fact Sheet for the 2024 Final Risk Management Rule for Trichlorethylene under TSCA
Compliance Guide: epa.gov/system/files/documents/2025-01/tce-compliance-guide.pdf