📋 Policy Monitoring Daily Report
Date: June 4, 2026
Policy Area: US EPA TSCA (Toxic Substances Control Act)
Risk Level: High Risk ⚠️
I. Major Policy Changes
US Environmental Protection Agency (EPA) Formal Ban on Trichloroethylene (TCE)
- Issue Date: December 2024 (Final Rule)
- Effective Status: Final ban published, some compliance dates extended to 2026-2028
- Subject Chemical: Trichloroethylene (TCE) – known carcinogen
II. Policy Key Points
Prohibition Scope:
- Prohibit TCE manufacture
- Prohibit processing for most commercial and all consumer products
- 52/54 conditions of use determined to present unreasonable risk
Phased Phase-out (Longer Transition Period):
- Aircraft and medical device parts cleaning
- Battery separator manufacturing
- Refrigerant manufacturing (consistent with AIM Act)
- Other transportation, security and defense system parts cleaning
Worker Protection Requirements:
- Must implement Workplace Chemical Protection Plan
- Set inhalation exposure limit (estimated to reduce long-term workplace exposure by 97%)
- Equip with stringent engineering control measures
III. Impact Analysis
Impact on Chinese Export Enterprises:
- Supply Chain Restructuring: Enterprises using TCE as processing aid need to find alternative solvents
- Compliance Costs: Existing inventory needs to be cleaned or disposed before compliance dates
- Certification Requirements: Chemical products exported to the US need to provide TCE-free certification
- Time Window: Some uses compliance period extended to September 2028, with transition time available
IV. Action Recommendations
Immediate Actions (0-30 days):
- 📋 Screen product lines and supply chains for TCE use
- 📋 Contact US importers to confirm their compliance requirements
- 📋 Evaluate feasibility and cost of alternative solvents (e.g., hydrocarbons, ketones, esters)
Short-term Planning (1-6 months):
- 🔬 Collaborate with third-party testing agencies to establish TCE-free certification capability
- 🔬 Adjust process formulations, conduct pilot tests with alternative solvents
- 🔬 Update SDS (Safety Data Sheets) and labels, remove TCE-related statements
Medium-term Planning (6-18 months):
- 🏭 Complete production process upgrades, ensure compliance with disposal requirements before December 18, 2026
- 🏭 If involved in special uses such as nuclear fuel processing, apply for exemptions and develop worker protection plans
V. Information Sources
- EPA Official Website: TCE Risk Management
- Federal Register: 2024-29274 Final Rule
- Compliance Guide: TCE Compliance Guide (PDF)
Monitoring Conclusion: The EPA’s ban on TCE is one of the most important risk management actions since the TSCA reform. Chinese export enterprises should attach high importance and immediately initiate supply chain screening and alternative solution evaluation.
Next Monitoring Date: June 5, 2026
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