TCE Ban Update: EPA Postpones Deadlines Until August 2025

The Environmental Protection Agency (EPA) has once again extended the timeline for a portion of its final rule banning trichloroethylene (TCE). This latest update pushes the effective date of requirements related to TSCA Section 6(g) exemptions until August 19, 2025. While most of the TCE ban remains on track, these critical-use exemptions are receiving additional time to comply as legal proceedings continue.

Background: Why TCE Is Being Banned

TCE is a powerful solvent long used in degreasing, manufacturing, and cleaning operations, but it’s also a known toxicant, linked to cancer, reproductive harm, neurotoxicity, and organ damage. After years of scientific review, the EPA finalized a risk management rule in December 2024 under the Toxic Substances Control Act (TSCA), prohibiting nearly all uses of TCE. The rule was originally set to take effect in January 2025, with most commercial and consumer uses phased out by the end of the year.

Shortly after the final rule’s publication, several petitions for review were filed in federal court. This led to a temporary stay issued by the Fifth Circuit Court of Appeals in January 2025. The case was later transferred to the Third Circuit, where the court partially lifted the stay which allowed most of the rule to move forward. However, the Section 6(g) exemption provisions were temporarily put on hold.

In the meantime, the EPA (following the regulatory freeze memorandum issued by President Trump) postponed the effective date of the entire rule until March 21, 2025. It then issued another delay for the exemption-related requirements to June 20, 2025. As of June 2025, that deadline has now been pushed once again to August 19, 2025, to align with the ongoing judicial review.

A Closer Look at the Exemptions

One important detail that many businesses may overlook is that the EPA’s final rule does not apply equally to all uses of TCE. Section 751.325 of 40 CFR Part 751 outlines time-limited exemptions for certain critical operations where no feasible substitutes are currently available. These include activities such as:

• Cleaning parts in aviation and medical device manufacturing,
• Production of battery separators and refrigerants, and
• Other applications essential to national defense or infrastructure.

For businesses engaged in these operations, the EPA has granted compliance extensions ranging from seven to ten years. These extended timelines come with stricter exposure control measures and worker protection standards. However, these conditions are what the Judicial Court is reviewing, so they are not yet enforceable by the EPA. If/when the Section 6(g) exemptions are passed, companies must ensure they meet all conditions to maintain eligibility for their extensions, including proper documentation and adherence to updated exposure limits.

This is an important opportunity for industries that rely on TCE in specialized processes, but it’s one that must be approached carefully. The EPA has made it clear that these extensions are not permanent and are only meant to give critical sectors the time they need to identify and implement safer alternatives.

The Bottom Line

Despite legal delays for certain exemptions, the TCE ban is proceeding as planned for most businesses. Industrial and commercial uses are still expected to be prohibited by the end of 2025. Only those processes that fall under the Section 6(g) exemptions are affected by the August extension.

Whether your operations are covered by the main rule or an exemption, it’s time to prepare. Waiting until the final hour could leave your business exposed to compliance violations, supply chain disruptions, and employee safety concerns.

Need Help Navigating the TCE Ban?

Walden provides comprehensive support for facilities affected by the TCE risk management rule. Our team can assess whether your operations meet the criteria for a Section 6(g) exemption, assist in implementing viable chemical alternatives, and develop site-specific exposure control measures in alignment with EPA’s standards. We also offer regulatory monitoring and compliance planning services to ensure your facility remains aligned with evolving TSCA requirements and enforcement timelines.

Contact our EHS team today at 860-846-4069 for assistance.