The U.S. Environmental Protection Agency (EPA) has proposed extending several upcoming compliance dates under its 2024 trichloroethylene (TCE) rule issued under the Toxic Substances Control Act (TSCA). The proposed rule, published in the Federal Register on October 14, 2026 (91 FR 65148), would move a prohibition currently set for December 18, 2026 to December 31, 2027 for certain chemical processors, and would delay the first step of a TCE feedstock phasedown for refrigerant manufacturers.
EPA is accepting comments through November 13, 2026. Because the proposal is not yet final, the December 18, 2026 date remains in effect for now.
Background: The 2024 TCE Rule
TCE is an industrial solvent used in degreasing, chemical manufacturing, and as a feedstock for the refrigerant HFC-134a. In December 2024, EPA finalized a rule prohibiting the manufacture (including import), processing, and distribution of TCE for nearly all uses, with longer phaseout periods and interim worker protections for certain uses. Most prohibitions took effect June 16, 2025.
EPA has since adjusted the rule more than once. A September 2025 interim final rule extended the deadline for TCE used as a processing aid in nuclear fuel manufacturing to September 15, 2028, and aligned certain wastewater disposal deadlines with the December 18, 2026 processing prohibition. Separately, EPA has announced it is reconsidering broader elements of the 2024 rule, which is also being challenged in the U.S. Court of Appeals for the Third Circuit.
What EPA Is Proposing
The proposal targets three areas: certain chemical processing uses, HFC-134a production, and the required supply chain notifications that describe the restrictions.
| Requirement | Current Compliance Date | Proposed Compliance Date |
| Processing TCE as a reactant/intermediate | December 18, 2026 | December 31, 2027 |
| Processing for, and industrial/commercial use of, TCE as a processing aid in the listed chemical manufacturing uses | December 18, 2026 | December 31, 2027 |
| Disposal of TCE to industrial pre-treatment, industrial treatment, or publicly owned treatment works from those processing activities | December 18, 2026 | December 31, 2027 |
| HFC-134a manufacturers: first phasedown step (TCE feedstock capped at 75% of baseline) | June 7, 2027 | December 31, 2027 |
| Downstream notification and updated Safety Data Sheet (SDS) text | Already passed (2025) | 30 days after the final rule publishes |
The processing aid uses covered by the extension are process solvents used in battery manufacture, polymer fiber spinning, fluoroelastomer manufacture, and Alcantara manufacture; extraction solvent used in caprolactam manufacture; and precipitant used in beta-cyclodextrin manufacture.
Why EPA Is Changing Course
Byproduct TCE moving between facilities. After the 2024 rule was finalized, chemical manufacturers told EPA that TCE is often created as an unintended byproduct when making other chlorinated solvents, including perchloroethylene, carbon tetrachloride, methylene chloride, and 1,2-dichloroethane. Feedstock streams containing that byproduct TCE are regularly shipped by railcar between sites, usually between facilities owned by the same company, for further processing. Under the current deadline, that processing would be prohibited after December 18, 2026, and the byproduct TCE would have to be incinerated instead. Industry warned this could exceed permit limits, force facility closures, and disrupt domestic chlorinated solvent supply.
Continued demand for HFC-134a. A refrigerant producer informed EPA that demand for HFC-134a in military, industrial, and medical applications is expected to remain significant into the early 2030s, and that it has received more production allowances under the American Innovation and Manufacturing (AIM) Act than originally expected. Without the extension, manufacturers would need to start cutting production in June 2027, before that demand eases.
EPA estimates the changes would mainly delay when existing costs and benefits begin, with modest overall cost savings.
What EPA Wants to Hear
In addition to general comments, EPA is specifically asking for input on:
- A longer extension. An industry stakeholder asked for a December 18, 2028 deadline instead of December 31, 2027. EPA is asking whether that longer date could be justified.
- A fast effective date. Because the December 18, 2026 deadline is close, EPA is considering making the final rule effective immediately or within about 14 days of publication.
- Reliance interests. Whether any company has made plans or investments based on the current dates that the change would affect.
What This Means for Importers
Under TSCA, “manufacture” includes importing. That means importers of TCE are treated as manufacturers and are subject to the same restrictions once the chemical enters U.S. customs territory. The rule also reaches products that contain TCE, not just the pure chemical.
For importers of chemicals and EPA regulated products, the practical impacts include:
- TSCA import certification. Shipments of TCE or TCE-containing products must still comply with the TSCA rule as it currently stands at the time of entry. Importers should confirm their TSCA certifications reflect the uses that remain permitted and the dates that apply to them.
- Safety Data Sheets and customer notices. If finalized, companies that import, process, or distribute TCE would need to update the required SDS language and downstream notifications within 30 days of the final rule, even though many updated these documents in 2025.
- Supply planning for downstream products. Companies sourcing chlorinated solvents or HFC-134a, or products made with them, may see more stable supply if the extension is finalized, since it avoids a near-term disruption at U.S. production sites.
Industries EPA identifies as potentially affected include wood window and door manufacturing, inorganic and miscellaneous chemical manufacturing, medicinal and botanical manufacturing, rubber and plastics hose and belting manufacturing, mechanical rubber goods, and storage battery manufacturing.
Key Dates
- October 14, 2026: Proposed rule published
- November 13, 2026: Comment deadline
- December 18, 2026: Current prohibition date for the affected processing uses and wastewater disposal (remains in effect unless a final rule is issued first)
- December 31, 2027: Proposed new compliance date
Recommended Action Items
- Determine whether any imported chemicals, mixtures, or articles contain TCE, including byproduct TCE in feedstock streams.
- Confirm which TCE uses and compliance dates apply to your products and customers.
- Review TSCA import certification practices for TCE and TCE-containing shipments.
- Prepare to update SDS language and downstream notifications if the rule is finalized.
- Plan for the December 18, 2026 date as a fallback until EPA issues a final rule.
- Submit comments by November 13, 2026 through Regulations.gov under docket EPA-HQ-OPPT-2026-7327 if your operations are affected.
ASK Alba™
Questions about TSCA import certification or how changing TCE deadlines affect your chemical imports? Alba’s trade compliance team can help. Contact us.
References
- EPA, Trichloroethylene (TCE); Regulation Under TSCA; Compliance Date Extensions (Proposed Rule), 91 FR 65148, October 14, 2026
- Regulations.gov Docket EPA-HQ-OPPT-2026-7327
- EPA, Trichloroethylene; Regulation Under TSCA (Final Rule), 89 FR 102568, December 17, 2024
- EPA, Trichloroethylene; Regulation Under TSCA; Compliance Date Extension (Interim Final Rule), 90 FR 44772, September 17, 2025
- J. J. Keller Compliance Network, EPA Proposes Additional TCE Compliance Delays
