Table of Contents
What Is PIP 3:1?
Phenol, isopropylated phosphate (3:1), commonly referred to as PIP 3:1, is a plasticizer and flame retardant widely used in the electronics industry. Its CAS number is 68937-41-7. You’ll typically find it in:
- Wire and cable insulation
- Printed circuit board coatings
- Molded plastic connectors and housings
PIP 3:1 was added to the TSCA Section 6(h) list in January 2021 due to its persistent, bioaccumulative, and toxic (PBT) properties. As a result, it’s subject to specific restrictions by the U.S. Environmental Protection Agency (EPA).
Why Electronics Manufacturers Should Care
Even if you're not directly manufacturing chemicals, your components and assemblies may contain PIP 3:1—especially if they involve plastic, insulation, or circuit boards. If you import, process, or distribute these articles in the U.S., you're legally responsible for ensuring compliance.
Common places PIP 3:1 shows up:
- Plastic jackets around power cords
- Circuit board varnishes
- Insulated wire inside assemblies
- Injection-molded plastic parts with flame retardant properties
Ignoring PIP 3:1 can result in:
- Product holds at U.S. customs
- EPA enforcement action and fines (up to $50,000/day)
- Risk of losing OEM contracts or federal sales opportunities
What the TSCA Section 6(h) Rule Says
In January 2021, the EPA finalized rules restricting five PBT chemicals, including PIP 3:1. The rule generally prohibits the processing and distribution of PIP 3:1 and related articles in commerce—unless specific exemptions apply.
TSCA PBT Section 6(h) Timeline Updates (PIP 3:1 TSCA Compliance Deadlines)
- October 2024 Final Rule Highlights
In October 2024, the EPA issued a revised final rule (FRL–10771–52–OCSPP) to provide flexibility for industries using PIP 3:1 while enhancing workplace safety and environmental protections.
- Key changes include:
- Workplace exposure protections: Now mandatory for continued use
- Labeling and Safety Data Sheet (SDS) updates required
- Water release restrictions added
- Sunset dates confirmed for specific uses without alternatives
These updates were a result of public comments from manufacturers, OEMs, and industry coalitions concerned about supply chain feasibility and safe transitions.
Key Compliance Actions
To meet TSCA Section 6(h) obligations around PIP 3:1, you should:
- Screen BOMs and parts lists for CAS 68937-41-7
- Send supplier declaration requests: Ask for presence, purpose, and exemption status
- Document exemptions clearly: Include concentration levels and use case
- Phase out or substitute if no exemption applies
- Maintain internal files for audit defense
Use IPC-1752A or choose Acquis Compliance Tool to gather consistent data from suppliers.
Common Mistakes to Avoid
- Assuming suppliers are compliant — Always verify with documentation.
- Not tracking EPA deadline updates — Missing an extension date can lead to costly disruptions.
- Failing to document exemptions — EPA expects proof, not just assumptions.
How to Simplify TSCA Compliance
TSCA 6(h) isn’t just a checkbox—it’s an ongoing program. Here’s how to make it easier:
- Use tools like Acquis to automate supplier declarations and screen BOMs
- Centralize all CAS screening and documentation in a compliance dashboard
- Set up alert systems to track EPA rule amendments and upcoming deadlines
If you're managing complex electronics supply chains, automation is essential to scale compliance.
If you need help complying with TSCA Section 6(h) requirements Let our team show you how to automate compliance, reduce supplier friction, and avoid regulatory surprises.
Contact Acquis Compliance Solutions to get started.