Say Goodbye to Trichloroethylene in 2025

EPA Bans Trichloroethylene

Trichloroethylene (TCE) has various uses, but it is commonly utilized as a solvent for cleaning, adhesives, and paints, or for extracting fats and oils from materials. TCE was most commonly used throughout the mid-1900s and is favored in degreasing operations due to its high boiling point (it is able to remove contaminants that solvents with lower boiling points may not). Other preferred degreasing solvents included chlorofluorocarbons (CFCs) and trichloroethane (TCA), but both were phased out under the Clean Air Act in 1990 due to their ozone-depleting properties.

Towards the end of the 20^th century, the hazards of TCE became more widely known, reducing its popularity. However, many businesses still include it in their operations—but that is about to change.

In January 2023, the Environmental Protection Agency (EPA) released a final revised risk determination for TCE. This evaluation determined that TCE presents an unreasonable risk to human health, including developmental toxicity, reproductive toxicity, liver toxicity, kidney toxicity, immunotoxicity, neurotoxicity, and cancer from inhalation or dermal exposures to TCE (click here to read more).   

Following this risk assessment, in December 2024, the EPA published a final rule banning the manufacture, processing, use, and disposal of TCE (including the disposal of products containing TCE). This rule became effective on January 16, 2025, but there are still some upcoming deadlines, allowing businesses some time to complete their phaseout of the chemical and find a replacement.

Important dates include:

• Manufacturing TCE for consumer use is prohibited after March 17, 2025.
• Processing and distributing TCE for consumer use is not permitted after June 16, 2025.  
• Industrial and commercial uses of TCE are prohibited after September 15, 2025.

Exemptions

There are very few uses of TCE that are exempted from these deadlines (and thus that are allowed to be phased out over a longer period). The exemptions that do exist are accompanied by more stringent worker safety requirements. Some of the exempted uses include:

• Cleaning parts used in aircraft and medical devices
• Manufacturing battery separators
• Manufacturing refrigerants
• Cleaning parts used in other transportation, security, and defense systems

The exemptions associated with longer timeframes are necessary to avoid impacts on national security or critical infrastructure. Keep in mind that all uses of TCE will eventually be prohibited.

Summary and Resources

The EPA’s final rule will prevent serious illness associated with uncontrolled exposures to TCE by preventing consumer access to the chemical, restricting the industrial and commercial use of the chemical (while also allowing for a reasonable transition period), and providing time-limited exemptions for critical or essential uses of TCE for which no technically and economically feasible safer alternatives are available (https://www.federalregister.gov/documents/2024/12/17/2024-29274/trichloroethylene-tce-regulation-under-the-toxic-substances-control-act-tsca).

The final rule also imposed an updated inhalation exposure limit, which is estimated to reduce long-term workplace exposure by 97%.

The EPA has released multiple documents to help with this transition:

• A compliance guide for TCE, which includes specific details on the final rule, risk management procedures, recordkeeping requirements, frequently asked questions, and more.
• An EPA Fact Sheet for the Final Risk Management Rule for TCE.
• A Pollution Prevention Factsheet highlighting safer alternatives for solvent degreasing applications, which features TCE.

For more help interpreting the final rule and phasing out the use of TCE, contact Walden. Our staff have experience helping businesses understand and comply with regulatory actions that impact their operation. Call us at 516-559-6976 to speak with someone who can answer your questions.