TSCA and Plastic Additives: 21 Additives Under EPA Action, Risk Evaluations and Reporting Duties

By PlasticAdditives.net Editorial Team. Every date and Federal Register citation on this page is checked against the EPA risk-evaluation list and the Federal Register; see our sourcing standards and fact-checking process. EPA risk-evaluation list checked: 25 September 2026. TSCA status verified: 18 October 2026. This page is a technical reference for formulators, compounders and their regulatory staff, not legal advice.

21 substances used as plastic additives are under a named EPA action under the Toxic Substances Control Act (TSCA), from the 5 phthalate plasticizers whose final risk evaluations were noticed on 6 January 2026 to the 2 flame retardants, decaBDE and PIP (3:1), that the US Environmental Protection Agency (EPA) has actually prohibited. A finding of unreasonable risk is not itself a restriction, so what does each of the 6 TSCA sections oblige a compounder to do?

6 TSCA sections reach a plastic additive, and each creates a different duty: section 6(a) evaluates an existing chemical and can then restrict it, section 6(h) prohibits a chemical EPA has designated persistent, bioaccumulative and toxic, section 5 gates a new additive or a new use, section 8(a) collects production and import volumes plus PFAS data, section 8(d) collects existing health and safety studies, and section 4 can require new testing. Only section 6 can take an additive off the US market; sections 5, 8 and 4 create paperwork, and most additives in a commercial compound meet only the paperwork.

This page maps those 6 sections against the additives each reaches, explains what Inventory listing and Active status mean, sets out the 11 risk evaluations with their Federal Register citations, lists all 21 affected substances with CAS numbers and dates, names the common additives under no EPA action, gives the dated decaBDE and PIP (3:1) deadlines, explains what happens between a finding and a rule, walks a formulation through a 7-step screen, describes the TSCA statement buyers ask for, and compares TSCA with REACH, Proposition 65, the CPSIA and FDA. Each of the 21 is matched to the family of plastic additives it belongs to, so a formulator can find the action that touches a specific compound without reading the Federal Register.

Table T1: The 6 TSCA sections that reach a plastic additive

A substance is counted once even when two sections reach it. Triphenyl phosphate is counted under section 6(a) although a section 5 significant new use rule has also been proposed for it. Three chemicals prohibited alongside decaBDE and PIP (3:1) under the same section 6(h) rules, 2,4,6-TTBP, PCTP and HCBD, are not plastic additives and are not counted: 2,4,6-TTBP is restricted as an oil, lubricant and fuel additive, PCTP is a rubber chemical, and HCBD is prohibited outright.

What Is TSCA, and Which Plastic Additives Does It Cover?#

The Toxic Substances Control Act, TSCA, is the US federal chemicals law that the Environmental Protection Agency uses to evaluate, restrict and collect data on industrial chemical substances, and a plastic additive comes under it as a chemical substance in commerce rather than as part of the plastic it ends up in. EPA administers TSCA through the 6 sections of Table T1, and every one of them acts on a substance rather than on a product. The statute separates existing chemicals, which already sit on the TSCA Inventory, from new chemicals, which do not, and it analyses each substance by condition of use: the manufacturing, processing, distribution, use and disposal activities EPA names in its own evaluation documents. So which plastic additives does that definition reach, and which does it not?

Why TSCA reaches the additive and not the finished plastic part#

TSCA regulates the additive as a chemical substance and regulates it by condition of use, which is why an EPA finding can land on a spray-applied sealant and leave the same plasticizer untouched in an extruded PVC profile. The unit of regulation is the substance plus the activity, not the article a consumer buys, so a compound is never evaluated as such: EPA evaluates each additive against the conditions of use it has defined for that additive.

One group of rules breaks that pattern. The section 6(h) rules on persistent, bioaccumulative and toxic chemicals reach articles directly: the PIP (3:1) rule at 40 CFR 751.407 prohibits distributing a PIP (3:1)-containing article after 31 October 2026, and the decaBDE rule at 40 CFR 751.405 sets a 0.1 wt% threshold for unintentional presence in an article. The European Union works the other way round, because REACH Annex XVII entry 51 limits DEHP, DBP, BBP and DIBP to 0.1 % by weight of the plasticised material in the article itself, in force since 7 July 2020, an article-level content limit on 4 substances that TSCA reaches only as substances under evaluation.

Which plastic additives fall outside TSCA#

Three groups of substances that sit next to plastic additives are outside this page: biocidal actives such as zinc pyrithione and DCOIT, which are regulated as pesticides for their antimicrobial use; monomers such as bisphenol A and phthalic anhydride, which are not additives; and food-contact uses of an additive, which are cleared under 21 CFR rather than under TSCA. The 3 categories, with the instances our knowledge base records, are listed below.

• Biocidal actives used as antimicrobial additives, namely zinc pyrithione, DCOIT, OIT and IPBC, which our knowledge base records with Chemical Data Reporting volumes rather than pesticide registrations
• Monomers and polymerisation reactants, namely bisphenol A, phthalic anhydride and vinyl chloride, which are raw materials rather than additives
• Food-contact uses of an additive, which run through 21 CFR and the Food Contact Notification route rather than any TSCA section

Does TSCA apply to imported plastic compounds and masterbatch?#

Yes: an imported compound, masterbatch or finished plastic part brings its additives into US commerce, and 2 TSCA rules say so explicitly. The PFAS reporting rule at 40 CFR 705 covers PFAS and PFAS-containing articles manufactured or imported since 1 January 2011. The PIP (3:1) rule prohibits distributing a PIP (3:1)-containing article after 31 October 2026, and it reaches an imported article as much as a domestic one.

6 TSCA Sections That Reach a Plastic Additive#

6 TSCA sections reach a plastic additive: section 6(a), which evaluates an existing chemical and can then restrict it; section 6(h), which prohibits a persistent, bioaccumulative and toxic chemical outright; section 5, which gates a new additive or a new use; section 8(a), which collects production volumes and PFAS data; section 8(d), which collects existing health and safety studies; and section 4, which can require new testing.

Section 6(a): Risk Evaluation and Risk Management for 11 Additives#

Section 6(a) is the only TSCA route that can take a plastic additive off the US market, and it runs in 5 stages: priority designation, scope, draft risk evaluation, final risk evaluation, then a risk management rule. EPA opens the process either by designating a High-Priority Substance, as it did for DEHP, DCHP, TBBPA and triphenyl phosphate in December 2019, or by accepting a manufacturer-requested risk evaluation, as it did for DINP and DIDP in the same month. EPA then publishes a final scope, which fixes the conditions of use the evaluation will cover, as it did for triphenyl phosphate in August 2020.

The next two stages produce the documents a compliance file cites. EPA issues a draft risk evaluation for public comment, as it did for TBBPA on 12 June 2026 with comments closing on 17 August 2026, and finalises the evaluation with a Federal Register notice of availability, as it did for the 5 phthalate plasticizers on 6 January 2026 at 91 FR 373. Risk management then follows as a separate rulemaking with its own proposal and effective dates.

That separation decides the 2026 compliance answer for the whole group. 9 of the 11 additives under section 6(a) have reached a final or revised unreasonable-risk determination, 1 sits at draft stage and 1 is still under evaluation, and not one of the resulting risk management rules carries a date, so the status of those 9 is "evaluated, not yet restricted" rather than cleared or restricted.

Section 6(h): PBT Prohibitions on 2 Flame Retardant Additives, decaBDE and PIP (3:1)#

Section 6(h) is the one place where TSCA prohibits a plastic additive outright, and only 2 of the 5 chemicals it covers are plastic additives: decaBDE, the brominated flame retardant at 40 CFR 751.405, and PIP (3:1), the organophosphate flame retardant and plasticizer at 40 CFR 751.407. EPA issued the original section 6(h) rules in January 2021 for 5 chemicals it had designated persistent, bioaccumulative and toxic, and published a revision on 19 November 2024 at 89 FR 91486 which took effect on 21 January 2025.

The revision added the two provisions a compounder reads first. It set a 0.1 wt% threshold for the unintentional presence of decaBDE and PIP (3:1), which separates a deliberate flame-retardant loading from trace carry-over, and it excluded recycled plastic: recycled plastic is excluded from the decaBDE prohibition where no decaBDE has been added to it, and recycled plastic made from PIP (3:1)-containing articles is excluded where no new PIP (3:1) has been added.

The other 3 chemicals in the same rules are not plastic additives, and their limits sit outside plastics for that reason: 2,4,6-TTBP is limited to 0.3 wt% in oil, lubricant and fuel additives, which is a non-plastics use even though the molecule is a hindered phenol related to the antioxidant family; PCTP is limited to 1 wt% and is a rubber chemical; and HCBD is prohibited. The furniture standards, cable requirements and national bans that sit alongside the US prohibitions are set out on flame retardant regulations.

Section 5: Premanufacture Notices, SNURs and the Clarifying Agent That Carries One#

Section 5 is the gate a genuinely new plastic additive passes through, and our knowledge base records 2 additives that came through it: RiKACLEAR PC1, the polypropylene clarifier now governed by the significant new use rule at 40 CFR 721.10695 from premanufacture notice P-08-179, and DINCH, whose US Inventory listing under CAS 474919-59-0 entered through a commenced premanufacture notice. EPA reviews the notice before manufacture begins, and a significant new use rule then fixes the conditions under which the substance may be used.

The DINCH entry carries the trap that costs importers the most time. DINCH is listed on the TSCA Inventory under the US CAS 474919-59-0, the branched and linear dinonyl ester of 1,2-cyclohexanedicarboxylic acid, and it is Active in the 2024 CDR TSCA Inventory (EPA Substance Registry Services). The European CAS 166412-78-8 that a supplier data sheet usually quotes is not itself an Inventory listing, so a European document is not evidence of US Inventory status for the same material.

A significant new use rule matters to a clarifier or a nucleator in one way: a use outside the notified conditions requires a fresh notice before it starts, so a compounder moving a trisamide clarifier into a new polymer checks the rule text and not only the Inventory. The trisamide and sorbitol classes are compared on clarifying agents for plastics.

Section 8(a): Chemical Data Reporting and PFAS Reporting for Fluoropolymer Processing Aids#

Section 8(a) touches more plastic additives than every other TSCA section put together, because Chemical Data Reporting captures production and import volumes for additives nobody is restricting: Irgafos 168 and Irganox 1010 each carry a US Chemical Data Reporting production and import volume of 40 to <55 million lb, for 2023 and for 2020-2023 respectively, and neither is under any EPA risk evaluation. Every additive above the reporting volume carries this duty, and our knowledge base holds CDR volumes for more than 25 stabilizers.

The second section 8(a) duty is separate and newer. EPA made the PFAS reporting rule final on 11 October 2023 at 40 CFR 705, covering PFAS and PFAS-containing articles manufactured or imported since 1 January 2011, and the final rule effective 13 April 2026 at 91 FR 18786 moved the submission period to open on 31 January 2027, or 60 days after the effective date of the forthcoming rule on the substantive requirements, whichever is earlier. The fluoropolymer and acrylic grades a formulation can choose between are on polymer processing aids.

Structure, not function, decides which processing aid falls inside that rule. The fluoroelastomer processing aid, a VDF-HFP copolymer with CAS 9011-17-0, is a PFAS under the section 8(a)(7) structural definition, and FDA authorises fluoropolymer processing aids at up to 0.2 wt% for the 65 to 71 % fluorine grade and up to 1.0 wt% for the grade with at least 87 % VDF under 21 CFR 177.1520. A film producer dosing one at 0.2 to 1.0 wt%, or importing a masterbatch containing one, therefore sits inside a reporting rule while no restriction applies to the additive, and the non-fluorinated routes are on PFAS-free processing aids.

The scope of that rule is still moving. EPA proposed exemptions in November 2025 for PFAS at or below 0.1 % in mixtures, imported articles, byproducts, impurities and research quantities, with comments closed on 29 December 2025; the exemptions are proposed, not in force. Reporting is not restriction, and the restriction landscape is mapped on PFAS restrictions and plastic additives.

Section 8(d): Health and Safety Data Reporting for DOTP and 3 Blowing and Crosslinking Additives#

Section 8(d) obliges a company to hand EPA the health and safety studies it already holds on a listed chemical, and 4 plastic additives in our knowledge base carry that duty: DOTP, which is named in 40 CFR 716.120, plus the blowing agents cyclopentane and OBSH and the silane-crosslinking catalyst dibutyltin dilaurate. Cyclopentane carries a combined section 8(a) and 8(d) duty and OBSH is recorded under a section 8(d) rule, so both sit among the chemical and physical blowing agents. Only DOTP carries a CFR citation in our knowledge base; for the other 3 the duty is recorded without one.

The DOTP listing is the one that gets misread commercially. DOTP, CAS 6422-86-2, is the most widely specified non-ortho-phthalate replacement for DEHP, it is on the TSCA Inventory and Active in the 2024 CDR TSCA Inventory (EPA Substance Registry Services), it is not a High-Priority Substance, and it is not undergoing a risk evaluation on EPA's list as checked on 25 September 2026. A section 8(d) listing is a data call, not a suspicion. Dibutyltin dilaurate carries the same duty as a tin catalyst for silane systems, and the routes it competes with are compared on crosslinking agents for polymers.

Section 4: Test Rules#

Section 4 lets EPA require new testing rather than rely on existing data, and our knowledge base records 1 plastic additive in that position: 2-ethylhexyl diphenyl phosphate, CAS 1241-94-7, a phosphate-ester plasticizer and flame retardant, against which a section 4 test rule is recorded as proposed. The record is a flag with no date, no Federal Register citation and no docket number, so this page states the status and no more. A proposed test rule creates no duty until it is final, which puts this additive at the opposite end of the scale from the section 6(h) prohibitions.

Is Your Additive on the TSCA Inventory? Active Status and CDR Volumes for Antioxidants and UV Stabilizers#

Every additive in routine commercial use in a US compound is already on the TSCA Inventory, so the question a formulator actually needs answered is not whether the additive is listed but whether the CAS number on the supplier's data sheet is the one that is listed and whether its commercial activity status is Active. TSCA treats a substance on the Inventory as an existing chemical and everything else as a new chemical needing a premanufacture notice.

Chemical Data Reporting is where the US additive industry becomes visible. Our knowledge base records US Chemical Data Reporting production and import volumes for more than 25 antioxidants and stabilizers, topped by Irgafos 168 and Irganox 1010 at 40 to <55 million lb each. The phenolic, phosphite and thioester classes behind those volumes are compared on antioxidants for plastics.

Table T5: US Chemical Data Reporting volumes for 10 plastic stabilizers

Volumes are EPA Chemical Data Reporting production and import volumes as recorded in our knowledge base through PubChem, which presents EPA data rather than publishing it. EPA reports them as bands, and the bands are reproduced exactly here, including the "less than" signs; a band is never midpointed and never converted into tonnes. Not one of these 10 stabilizers is under a TSCA risk evaluation, and 21 CFR 178.2010 authorises Irgafos 168 and Irganox 1076 by name for food contact, as set out on antioxidants and stabilizers for polymers. Our knowledge base records CDR volumes for more than 25 stabilizers; the 10 highest are shown.

The light-stabiliser side gives the same answer. Every mainstream hindered amine light stabiliser and benzotriazole or triazine UV absorber in our knowledge base is Inventory-listed and active, from Tinuvin P and 770 through Chimassorb 944 to the Cyasorb UV and Uvinul grades, with Tinuvin 622 a polymer carrying the CDR exemption flag XU. A complete UV package therefore creates reporting duties and nothing else, and absorber against radical scavenger selection is on UV stabilizers for plastics.

Two dual-CAS traps sit inside that portfolio. Chimassorb 944 is Inventory-listed under the US CAS 70624-18-9 and the EU CAS 71878-19-8 is not found in EPA Substance Registry Services; Cyasorb UV-3853 is listed under 167078-06-0 and the EU reaction-mass CAS 86403-32-9 is not found there either. "Not found in EPA Substance Registry Services" is a negative search result rather than a finding that the substance is unlisted, and in both cases the US listing runs under a different CAS number, so a European data sheet is not proof of US Inventory status. UV-328 diverges the other way, Inventory-active in the US while the EU phases it out at 100 mg/kg from 4 August 2025, 10 mg/kg from 2027 and 1 mg/kg from 2029 as a Stockholm Annex A persistent organic pollutant listed by decision SC-11/11 in 2023; the EU status of these molecules is on benzotriazole UV absorbers.

11 Plastic Additives With a TSCA Risk Evaluation#

11 plastic additives have a TSCA risk evaluation: 5 phthalate plasticizers whose final evaluations were noticed on 6 January 2026, the 2 high-molecular-weight phthalates DINP and DIDP whose manufacturer-requested evaluations were finalised a year earlier, and 4 flame retardants at three different stages, from a final evaluation for TCEP to an ongoing one for triphenyl phosphate. 7 of the 11 are phthalates, and 6 of those 7 also sit in EPA's phthalate cumulative risk analysis, so why did EPA split them across three separate processes? The reason is procedural: 2 evaluations were requested by the manufacturers in December 2019 and ran on their own schedule, while the other 5 came through High-Priority Substance designation.

5 Phthalate Plasticizers: the Final Risk Evaluations of 6 January 2026#

5 of the 11 are low-molecular-weight ortho-phthalate plasticizers, BBP, DBP, DCHP, DEHP and DIBP, whose final risk evaluations EPA released in December 2025 and noticed in the Federal Register on 6 January 2026 at 91 FR 373, under Federal Register document 2025-24290. EPA found unreasonable risk to workers from inhalation for all 5 and, for 4 of the 5, to aquatic organisms, and no unreasonable risk to consumers or to fenceline communities. Risk management under TSCA section 6(a) is to follow and remains pending.

Which conditions of use a finding names is what makes it usable, and that list has to be read in the risk evaluation itself rather than taken from a summary: per-substance condition-of-use counts for DEHP, DBP, BBP, DIBP and DCHP are not stated here, because the Federal Register notice of 6 January 2026 supports the finding itself rather than a count, and no count in our sources has been verified against the underlying EPA documents. For DCHP the finding is risk to workers from inhalation, with phthalate syndrome as the endpoint. What the named conditions have in common is open handling, so the risk sits in spray and open-transfer operations rather than melt compounding. The low and high molecular weight split that drives which phthalate goes where is on phthalate plasticizers.

The volume contrast inside the group changes how a finding reads. DEHP was produced at 100 to 250 million lb in 2015 and is the substitution-factor 1.00 reference against which every replacement plasticizer is rated, while DIBP runs at under 1 million lb a year, BBP at 10 to 50 million lb and DCHP at 0.5 to 1 million lb in the 2016 CDR. One notice therefore covers a commodity and a specialty grade at once.

What that notice does not change is the commercial position of the 5 substances. Each remains lawful to manufacture, import and compound in the United States, 2 of them, DEHP and DCHP, remain among the 8 ortho-phthalates FDA left authorised as food-contact plasticizers after the final rule of 20 May 2022 at 87 FR 31080, and no section 6(a) rule for any of the 5 carries a date. Flexible PVC carries 5 to 65 wt% plasticizer, so the quantities are large, and the endpoints behind the findings are on phthalates: health effects.

DINP and DIDP: the 2 Manufacturer-Requested Risk Evaluations on High-Molecular-Weight Plasticizers#

DINP and DIDP are the 2 plastic additives whose TSCA risk evaluations their own manufacturers asked for, in December 2019, and both were finalised a year before the other 5 phthalates: DIDP in December 2024, noticed on 6 January 2025 at 90 FR 638, and DINP in January 2025, noticed on 15 January 2025 at 90 FR 3828. EPA accepted both as manufacturer-requested risk evaluations, which changes who starts the process and not what EPA is required to find.

Both findings are narrow, and both are narrow in the same way. For DINP, EPA found unreasonable risk to workers from 4 conditions of use, all of them spray-applied adhesives, sealants, paints and coatings, which EPA puts at about 3 % of US volume; for DIDP, it found unreasonable risk to female workers of reproductive age from 6 of 49 conditions of use, again spray applications, with developmental toxicity as the key endpoint. Neither finding names a plastics compounding or converting operation, and neither names consumers, the general population or the environment. Every plasticizer class, its dosage range and the properties that separate a high-molecular-weight phthalate from a terephthalate or a trimellitate are compared on plasticizers for plastics.

The volumes put those percentages in proportion. DINP was reported at 200 to 500 million lb in the 2016 CDR, so the overwhelming majority of US DINP use was examined and found to pose no unreasonable risk, and the food-contact authorisation of up to 43 wt% of vinyl chloride polymers for limited food types under 21 CFR 178.3740 is untouched. The EU reaches both substances more narrowly than headlines suggest, since REACH Annex XVII entry 52 covers DINP and DIDP only in mouthable toys and childcare articles, and California reaches them by a third route again, with DINP listed for cancer since 20 December 2013 at a no-significant-risk level of 146 µg/day and DIDP for developmental toxicity since 20 April 2007.

4 Flame Retardants Under Risk Evaluation: TCEP, HBCD, TBBPA and Triphenyl Phosphate#

4 of the 11 are flame retardants, and each sits at a different stage: TCEP has a final risk evaluation from September 2024, HBCD has a final evaluation from September 2020 and a revised determination from June 2022, TBBPA has a draft from 12 June 2026, and triphenyl phosphate is still under evaluation. 4 of the 11 additives under section 6(a) do the same job in a formulation, which makes this group the clearest reformulation signal on the page.

TCEP, CAS 115-96-8, carries the only finding here that reaches consumers rather than only workers. EPA's final risk evaluation of September 2024, noticed on 26 September 2024, found unreasonable risk to workers, to consumers through articles such as foam seating, fabrics and wood products, and to aquatic species; the number of conditions of use behind each part of that finding is not stated here, because it is not verified in our sources. Risk management rulemaking is pending with no date. The EU reached the same substance nine years earlier, since TCEP has been a substance of very high concern since 13 January 2010 and sits on REACH Annex XIV at entry 13 with a sunset date of 21 August 2015. The mineral and phosphorus routes to the same UL 94 rating are compared on flame retardants for plastics.

HBCD is the completed case, and the one where the market moved before any rule did. EPA finalised its risk evaluation in September 2020, published a revised unreasonable-risk determination in June 2022 and has a risk management rule under development, while US manufacturers report complete replacement of HBCD in expanded and extruded polystyrene foam. HBCD has been a Stockholm Annex A persistent organic pollutant since decision SC-6/13 in 2013, which is how most of the world reached it; the US route ran through TSCA instead.

TBBPA is the live case and triphenyl phosphate the open one. EPA released a draft risk evaluation for TBBPA, CAS 79-94-7, on 12 June 2026, noticed it on 16 June 2026 under docket EPA-HQ-OPPT-2018-0462 and closed comments on 17 August 2026; the draft finds unreasonable risk to workers from inhalation under 3 conditions of use and to the environment through surface water under 2, none to consumers or the general population, with the final evaluation pending. TBBPA is reactive in FR-4 epoxy laminates and additive in ABS housings, and it is a substance of very high concern since 17 January 2023, harmonised as Carc. 1B from 1 September 2025 under Delegated Regulation (EU) 2024/197. Triphenyl phosphate, CAS 115-86-6, was designated a High-Priority Substance in December 2019, received its final scope in August 2020 and is still under evaluation with no finding, with a significant new use rule also proposed and a 2016 CDR volume of 1 to 10 million lb a year. The polymeric grades that took over from HBCD in foam are on brominated flame retardants.

Complete List of Plastic Additives Under TSCA Action, with CAS Numbers and Dates#

The complete list below gives all 21 plastic additives under a named TSCA action, with the CAS number, the additive family, the TSCA section that reaches it, the EPA action and its date, the Federal Register or CFR citation and the finding. The count follows one rule: it lists a substance used as a plastic additive for which our knowledge base records a named EPA action under TSCA section 4, 5, 6(a), 6(h), 8(a)(7) or 8(d) carrying a date, a Federal Register citation, a CFR citation or a premanufacture-notice number, counts a substance once even when two sections reach it, and excludes substances recorded only as Inventory-listed, only with a CDR volume, or only with an undated premanufacture-notice flag.

Table T2: All 21 plastic additives under a named TSCA action

COU means condition of use, EPA's unit of analysis in a risk evaluation, and a finding applies only to the conditions of use it names. A final risk evaluation is not a restriction: of the 21 additives in this table, only decaBDE and PIP (3:1) are under an operative TSCA prohibition. Rows 16 to 18 and rows 20 to 21 carry no Federal Register citation because our knowledge base records the duty without one. Three further chemicals prohibited under the same section 6(h) rules, 2,4,6-TTBP, PCTP and HCBD, and three additives recorded only with an undated premanufacture-notice flag, DEHCH, HCFO-1233zd(E) and HFO-1336mzz(Z), are excluded by the counting rule above.

Each of the 21 has a full regulatory matrix in the plastic additives database, which carries REACH, food-contact, Proposition 65 and POPs status alongside the TSCA record shown here.

Which Plastic Additives Are Not Under TSCA Action? Non-Phthalate Plasticizers, Stabilizers and Halogen-Free Flame Retardants#

The non-ortho-phthalate plasticizers that replaced DEHP carry no TSCA action at all: DOTP, DINCH and ATBC are each on the TSCA Inventory and Active in the 2024 CDR TSCA Inventory (EPA Substance Registry Services), none of the three has been designated a High-Priority Substance, and none of the three is undergoing a risk evaluation on EPA's list as checked on 25 September 2026. That is the answer a buyer asking about a DEHP replacement needs, and the full set of non-phthalate plasticizers is compared on that page.

Table T3: TSCA status of 8 common additives with no EPA action

"No TSCA record" means our knowledge base records no TSCA entry for that substance, not that EPA has cleared it. "None" in the risk-evaluation column reflects EPA's list of chemicals undergoing risk evaluation as checked on 25 September 2026.

The stabilizer package gives the same answer across every class. No antioxidant, no PVC heat stabilizer and no hindered amine light stabiliser in our knowledge base is under a TSCA risk evaluation on the list checked on 25 September 2026, which makes the stabilizer side the simplest part of a US compliance file. The calcium-zinc, organotin and remaining lead systems are compared on PVC heat stabilizers.

The flame-retardant package is where the asymmetry sits. 4 of the 11 additives under section 6(a) are flame retardants, while the mineral and phosphorus routes carry no TSCA action in our knowledge base, which changes a formulation's regulatory exposure rather than only its cost. The packages that deliver the same rating are on halogen-free flame retardants.

"No TSCA action" is not the same as "unregulated", and 3 named cases show why. UV-328 is Inventory-active in the US while the EU phases it out at 100, 10 and 1 mg/kg from 2025, 2027 and 2029 as a Stockholm Annex A pollutant. DOTP carries no risk evaluation but holds a section 8(d) data duty under 40 CFR 716.120. Azodicarbonamide carries no TSCA action while FDA has an open request for information on it, published 13 May 2026 at 91 FR 27060 under docket FDA-2026-N-4126, comments closed 13 July 2026 and the outcome pending. The actual bans and concentration limits, as opposed to findings and data calls, are mapped on phthalate restrictions worldwide.

What EPA Prohibits Today: the decaBDE and PIP (3:1) Deadlines#

2 plastic additives are prohibited under TSCA today, decaBDE and PIP (3:1), and the prohibition on distributing a PIP (3:1)-containing article takes effect after 31 October 2026, which is 13 days after this page was published. Both prohibitions came from section 6(h) designations rather than from risk evaluations, both sit in 40 CFR 751, and both still have deadlines running. The dates below are listed earliest first so that the next one due is easy to find.

Table T4: The operative TSCA prohibitions and their dates

Standing exclusions, not dates: for decaBDE, recycled plastic to which no decaBDE has been added, aerospace replacement parts to end of vehicle service life, and nuclear-plant wire and cable to end of service life. For PIP (3:1), circuit boards and wire harnesses, aviation and military hydraulic fluids, and extended dates for articles used in HVAC-R, power generation, laboratory, commercial electronic and semiconductor manufacturing equipment.

The recycled-plastic exclusion is written per substance rather than as a general principle, which is why a recyclate buyer needs to read it twice. Recycled plastic is excluded from the decaBDE prohibition where no decaBDE has been added to it, and recycled plastic made from PIP (3:1)-containing articles is excluded where no new PIP (3:1) has been added. A recyclate stream therefore does not become unlawful through legacy content alone, and the dates in Table T4 bite on new addition and on article distribution instead.

What a TSCA Risk Evaluation Means for a PVC or Polyolefin Compound: From Finding to Rule#

A final TSCA risk evaluation changes nothing in a PVC or polyolefin compound on the day EPA notices it: it creates no concentration limit, no labelling duty and no prohibition, and it obliges EPA, not the compounder, to act next. Flexible PVC carries 5 to 65 wt% plasticizer, which is why a PVC compounder reads these findings first, and the flexible and rigid packages they touch are set out on additives for PVC. What a finding starts, in order, is below.

1. Read which conditions of use the finding names, because melt compounding and extrusion are not among them for any of the 7 phthalates evaluated so far.
2. Check whether your own operation matches a named condition of use, which for a compounder means open handling of powder or liquid plasticizer rather than metering it into an extruder.
3. Expect a section 6(a) proposal, because EPA follows an unreasonable-risk finding with risk management, then read the proposal rather than the finding.
4. Tell your customer what the finding is, because a buyer who has read a headline will ask whether the additive is now illegal, and the answer in October 2026 is no.

One finding breaks the pattern. Of the 9 final or revised determinations covered here, only the TCEP finding of September 2024 reaches consumers, through foam seating, fabrics and wood products, and TCEP is a flexible polyurethane foam flame retardant rather than a thermoplastic additive.

A federal finding with no rule behind it still moves procurement, for jurisdictional rather than toxicological reasons. US state programmes restrict additives on their own timetables and act faster than a section 6(a) rulemaking, so a specification often changes because of a state restriction list before EPA proposes anything; that layer is mapped on US state laws on plastic additives.

How Do You Screen a Plastic Compound for TSCA? 7 Steps#

Screen a plastic compound for TSCA in 7 steps: list every intentionally added substance, resolve each trade name to the CAS number the US Inventory uses, check Inventory status, match the CAS numbers against the risk-evaluation list and the PBT rules, read the conditions of use, record the reporting duties, then write the result into a statement.

1. List every intentionally added substance in the formulation with its CAS number, including the carrier resin of each masterbatch and every component of a stabilizer blend.
2. Resolve each trade name to the CAS number the US Inventory uses with the plastic additive CAS number lookup, because a European data sheet can quote a CAS that is not an Inventory listing: DINCH is listed under 474919-59-0 and not 166412-78-8, Chimassorb 944 under 70624-18-9 and not 71878-19-8, and Cyasorb UV-3853 under 167078-06-0 and not 86403-32-9.
3. Check each CAS number against the TSCA Inventory and record its commercial activity status as Active or Inactive.
4. Match each CAS number against EPA's list of chemicals undergoing risk evaluation and against the section 6(h) PBT rules at 40 CFR 751, and record the date you checked the list.
5. Read the conditions of use in any finding that matches, because a finding on spray-applied coatings does not reach an extrusion line.
6. Record the reporting duties separately from the restriction duties: Chemical Data Reporting for volume, 40 CFR 705 for PFAS and PFAS-containing articles, 40 CFR 716.120 for section 8(d) studies.
7. Write the result, the list-check date and the supplier evidence into a statement your customer can file.

Step 4 should be repeated on a schedule, because EPA updates the risk-evaluation list and the PBT rules without notice. Running a whole formulation through the additive regulatory status checker is the fastest way to repeat steps 3 to 6 after each update, and it catches a listing that a manual pass over 30 line items can miss.

What Customers Ask Compounders For: the TSCA Statement#

A TSCA statement is not a document TSCA defines: it is a supply-chain declaration a compounder gives a converter or a brand owner, recording which Inventory CAS number each additive runs under, whether EPA is acting on any of them, and on what date the check was made. TSCA sets no format, prescribes no content and sets no threshold, so this section describes commercial practice between a compounder and its customer rather than a filing obligation. It is also a different document from the certification an importer gives US Customs, which this page does not cover.

Buyers typically ask the statement to record 5 things, each a field a compounder can evidence.

• The CAS number under which each additive is listed on the US Inventory, which is not always the CAS number on a European data sheet
• The commercial activity status of each additive, Active or Inactive, with the source of that status
• The date on which EPA's list of chemicals undergoing risk evaluation was checked
• Any section 6(h) prohibition that names an additive in the compound, with its operative date
• Any reporting duty that attaches, whether Chemical Data Reporting, 40 CFR 705 for PFAS, or 40 CFR 716.120 for section 8(d) studies

What the statement is not is a certificate, and the European contrast makes the difference concrete. A declaration of compliance (DoC) under Regulation (EU) No 10/2011 is a legally defined document with prescribed content, and a TSCA statement has no equivalent definition. Writing one does not make a compound "TSCA compliant" either, because TSCA imposes duties on activities rather than certifying products.

How TSCA Fits the Other Plastic Additive Regulations: REACH, Proposition 65, the CPSIA and FDA#

TSCA is the only one of these 5 rules that sets no number: REACH Annex XVII, the CPSIA and the FDA food-contact rules each fix a concentration or a use limit, Proposition 65 triggers a warning, and TSCA instead evaluates a substance by condition of use and then decides whether to make a rule at all. Every instrument that reaches a plastic additive is indexed under plastic additive regulations, and the comparison below takes its 5 rows from that index.

Table T6: TSCA against the other 4 rules that reach a plastic additive

The same low-molecular-weight ortho-phthalates appear in four of these five rules, and each rule reaches them differently. DEHP is restricted in every EU article at 0.1 %, limited to 0.1 % in US children's articles under 16 CFR 1307.3(a), still authorised by FDA for some food-contact uses, Proposition 65 listed since 1 January 1988, and the subject of a TSCA finding with no rule behind it.

The timing gap between the two largest systems is what a global compliance manager has to manage. The EU restricted DEHP, DBP, BBP and DIBP in every article at 0.1 % by weight of the plasticised material from 7 July 2020 under REACH Annex XVII entry 51, while EPA reached a final unreasonable-risk finding on the same 4 substances on 6 January 2026 with no rule yet, so one formulation can be unlawful in the EU and lawful in the US at the same moment. The EU registration, authorisation and restriction routes are on REACH and plastic additives.

A second structural difference explains why 2 additives here are reached by TSCA rather than by a treaty. The United States is not a Party to the Stockholm Convention, so decaBDE and HBCD, which the EU controls as persistent organic pollutants under Regulation (EU) 2019/1021, are reached in the US only through TSCA: decaBDE by a section 6(h) prohibition and HBCD by a risk evaluation with a rule still under development. The treaty route is set out on POPs in plastics.

What Changed Under TSCA, and What Changes Next#

The most recent TSCA action on a plastic additive is the draft risk evaluation for TBBPA, released on 12 June 2026 with comments closing on 17 August 2026, and the most recent final action is the notice of 6 January 2026 covering 5 phthalate plasticizers. The next operative deadline is the PIP (3:1) article-distribution prohibition after 31 October 2026, and the next scheduled reporting date is the opening of the section 8(a)(7) PFAS submission period on 31 January 2027 at the latest.

Table T7: TSCA change log for plastic additives

No forecast appears in that table: the only future-dated items this page states are the 5 rows marked Scheduled, because EPA's prioritisation pipeline is not part of our source library. The EPA risk-evaluation list behind every "none" and every "not undergoing a risk evaluation" on this page was checked on 25 September 2026, and the TSCA status of each additive was verified on 18 October 2026.

---

Is a Plastic Additive Banned in the US Once EPA Finds Unreasonable Risk?#

No: a TSCA finding of unreasonable risk is not a ban, and the only 2 plastic additives the US has actually prohibited, decaBDE and PIP (3:1), were never the subject of a risk evaluation at all but of a persistent, bioaccumulative and toxic designation under section 6(h). A finding obliges EPA to move to risk management under section 6(a), and not one of the risk management rules for the 11 evaluated additives carries a date. Until such a rule exists, every one of those additives remains lawful to manufacture, import, process and distribute in the United States. The health evidence that sits behind each finding, as opposed to the compliance position described here, is on toxic plastic additives.

What does TSCA regulate, and what does "TSCA compliant" mean?#

TSCA regulates industrial chemical substances in US commerce, which for a plastic compound means every intentionally added additive and not the compound itself, and there is no single status called "TSCA compliant": the phrase stands for a different duty under each of the 6 sections. A compound can be entirely in order under sections 5, 8 and 4 while one of its additives carries a section 6(a) unreasonable-risk finding, and nothing in that combination is a contradiction.

When a customer asks for a TSCA compliance declaration, what they usually want is the 5 facts listed in the TSCA statement section above, and the honest deliverable is a statement of status carrying a check date rather than a certificate.

What chemicals are subject to TSCA?#

TSCA covers industrial chemical substances manufactured, imported, processed or distributed in US commerce, which includes every plastic additive in a commercial compound, from an antioxidant reported at 40 to <55 million lb a year such as Irgafos 168 to a trisamide clarifier made at specialty volume. Three adjacent categories are handled elsewhere: a biocidal active is regulated as a pesticide for its antimicrobial use, a monomer such as bisphenol A or phthalic anhydride is a raw material rather than an additive, and a food-contact use of an additive is cleared under 21 CFR.

Is TSCA Title VI about plastic additives?#

No: TSCA Title VI covers formaldehyde emissions from composite wood products, which is outside the plastics-additive scope of this reference. That is why the phrase "TSCA Title VI compliant" appears on furniture, panel products and laminated flooring rather than on a plastic compound or a masterbatch, and why a buyer asking a compounder for Title VI documentation is asking the wrong supplier.

How TSCA Findings Changed How US Compounders Select Plastic Additives#

The US additives that carry no TSCA action are in large part the ones that replaced the additives that do: DOTP, DINCH and ATBC took over from the evaluated ortho-phthalates, polymeric brominated flame retardants replaced HBCD in expanded and extruded polystyrene foam according to US manufacturers, and the halogen-free routes carry no EPA action at all. No study in our source library measures the size of that shift, so this page names the substitutions and their direction rather than a percentage. The replacement logic itself, including when a substitute is technically interchangeable and when it forces a formulation change, is worked through on how to select plastic additives.

How TSCA Reaches Additives in Recycled Plastic#

TSCA reaches recycled plastic at exactly one point: the section 6(h) rules exclude recycled plastic from the decaBDE and PIP (3:1) prohibitions where no new decaBDE or PIP (3:1) has been added, which makes legacy content lawful and new addition unlawful. That exclusion is why a brominated flame retardant detected in a post-consumer stream is a specification question rather than a prohibition question, and what is actually present in such a stream is documented on legacy additives in recycled plastic.

The position for a recyclate buyer is the opposite of the one the EU persistent organic pollutant rules create: legacy brominated flame retardant in a recyclate stream does not make the stream unlawful under TSCA, while the section 8(a)(7) PFAS reporting rule does reach PFAS-containing articles imported since 1 January 2011, including parts made from imported recyclate. Restabilising such a stream is covered on additives for recycled plastics.