TSCA Compliance How the EPA’s Latest Restrictions on TCE, PCE & PBT Chemicals Impact Electronics

If your company manufactures, imports, or sells electronic products in the U.S., recent EPA regulations under the Toxic Substances Control Act (TSCA) could impact your supply chain, product formulations, and compliance obligations.

In December 2024, the Environmental Protection Agency (EPA) finalized new TSCA rules under Section 6(a), restricting or phasing out trichloroethylene (TCE), perchloroethylene (PCE), and carbon tetrachloride (CTC). These solvents are widely used in electronics cleaning, PCB manufacturing, and semiconductor processing, and their phase-out will require companies to evaluate alternatives and strengthen compliance programs.

Additionally, several persistent, bioaccumulative, and toxic (PBT) substances regulated under TSCA Section 6(h)—including PIP 3:1, DecaBDE, 2,4,6-TTBP, HCBD, and PCTP—remain subject to strict use limitations, making compliance a critical challenge for the electronics industry.

Key TSCA Regulations & Impact on Electronics Manufacturing

The EPA’s regulatory actions under TSCA Sections 6(a) and 6(h) have direct implications for electronics manufacturers, PCB suppliers, and semiconductor fabs. Here’s what businesses need to know:

TCE (Trichloroethylene) – TSCA Section 6(a) Restrictions

• Use Case in Electronics: Historically used as a cleaning solvent for degreasing circuit boards and removing flux residues.
• TSCA Section 6(a) Final Rule Impact:
  • Most commercial and industrial uses of TCE will be prohibited within one year.
  • Electronics manufacturers must transition to alternative degreasing solutions to comply.
  • Limited-use exemptions exist but require strict workplace exposure controls.

PCE (Perchloroethylene) – TSCA Section 6(a) Phase-Out

• Use Case in Electronics: Solvent-based cleaning agent in semiconductor manufacturing and PCB assembly.
• TSCA Section 6(a) Compliance Deadlines:
  • The EPA’s new rule phases out most uses of PCE within three years.
  • Semiconductor fabs and PCB assembly lines must adopt PCE-free cleaning alternatives.
  • Any continued use will require airborne exposure limits (AELs), fume extraction, and OSHA-compliant safeguards.

CTC (Carbon Tetrachloride) – TSCA Section 6(a) Workplace Controls

• Use Case in Electronics: Industrial applications in chemical processing and legacy uses in PCB cleaning.
• TSCA Section 6(a) Compliance Mandates:
  • Banned in consumer products decades ago, but remains in some industrial settings.
  • The new TSCA rule mandates enhanced worker protections for remaining industrial uses.
  • Companies must implement engineering controls, exposure monitoring, and compliance reporting within three years.

PBT Chemicals Under TSCA Section 6(h): Challenges for Electronics Manufacturers

In addition to TCE, PCE, and CTC, the EPA’s TSCA Section 6(h) rule restricts several PBT chemicals commonly found in electronic components:

PIP 3:1 (Phenol, Isopropylated Phosphate) – High-Impact Electronics Ban

• Use Case in Electronics:
  • Found in wire insulation, electronic connectors, plastic circuit board casings, and flame retardants.
• TSCA Section 6(h) Compliance Requirements:
  • Strict restrictions on processing, distribution, and commercial use of PIP 3:1-containing components.
  • Temporary exemptions granted for critical supply chains but require detailed reporting and transition plans.

DecaBDE (Decabromodiphenyl Ether) – Flame Retardant Ban

• Use Case in Electronics:
  • Used in plastics for electrical enclosures, PCB housings, power cords, and consumer electronics casings.
• TSCA Section 6(h) Compliance Mandates:
  • Banned from new electronics; existing products must phase out DecaBDE-containing materials.
  • Companies must replace DecaBDE with TSCA-compliant, non-halogenated flame retardants.

2,4,6-TTBP (2,4,6-Tris(tert-butyl)phenol) – Lubricant Additive Restriction

• Use Case in Electronics:
  • Used as an additive in lubricants and fuel treatments for high-performance electronic manufacturing.
• TSCA Section 6(h) Compliance Mandates:
  • Restricted in consumer applications but limited industrial use still permitted.
  • Manufacturers must evaluate alternatives and ensure supply chain compliance.

HCBD & PCTP – Banned Industrial Chemicals

• Use Case in Electronics:
  • Legacy uses in semiconductor processing and plastic modification for specialized applications.
• TSCA Section 6(h) Compliance Impact:
  • Banned in most new industrial applications; existing uses must be carefully documented.

How Electronics Manufacturers Can Ensure TSCA Compliance

With TSCA Section 6(a) and 6(h) regulations tightening, companies must take proactive steps to ensure compliance:

Assess Components & Materials Now

• Conduct a supply chain audit to identify TSCA-restricted substances in PCB designs, wire coatings, and plastic enclosures.

Update Material Declarations & Compliance Reports

• Maintain accurate Material Safety Data Sheets (MSDS), supplier certifications, and chemical disclosures.

Engage with Suppliers & Distributors

• Notify PCB suppliers, semiconductor fabs, and component manufacturers about upcoming TSCA restrictions.

Redesign Products with TSCA-Free Materials

• Work with engineering teams to test alternative flame retardants, wire coatings, and cleaning solutions.

Leverage Compliance Software & Data Tools

• Implement Acquis compliance software to monitor restricted substances, generate compliance reports, and ensure supplier transparency.

Looking Ahead: The Future of TSCA Compliance for Electronics

More Chemicals Under Review: The EPA continues evaluating high-priority substances, meaning additional bans and phase-outs are expected.

Increased TSCA Enforcement: Non-compliance penalties are rising, and supply chain transparency is more critical than ever.

Supply Chain Adjustments Will Be Ongoing: Companies must track restricted substances across global supply chains and modify designs to ensure long-term compliance.

Final Takeaway: Stay Ahead of TSCA Compliance Risks

Electronics manufacturers must act now to adapt to TSCA Section 6(a) and 6(h) regulations. By proactively phasing out restricted substances, redesigning components, and strengthening supply chain compliance, businesses can:

• Avoid regulatory penalties and market disruptions.
• Ensure long-term access to U.S. markets.
• Maintain safe, compliant, and future-proof product designs.

Are your electronic components TSCA-compliant? Audit your supply chain today with Acquis and transition to safer alternatives before enforcement deadlines take effect.