TCPP: Properties, Uses in Plastics and Regulatory Status

TCPP (tris(chloropropyl) phosphate, also abbreviated TCIPP; CAS 13674-84-5) is a chlorinated alkyl phosphate used as an additive flame retardant in rigid and flexible polyurethane foam, and it is the standard flame retardant in PU and PIR insulation board. Because TCPP carries both chlorine and phosphorus in one molecule, it acts in the flame and in the char at the same time, which raises the question of how much of each element it delivers.

TCPP is registered under REACH, is absent from the Candidate List of Substances of Very High Concern, and is not restricted under REACH Annex XVII, though the childcare-article restriction work that once covered it, TCEP, TCPP and TDCP together, has been on hold since 2019. In toys for children under 36 months, or toys intended to be placed in the mouth, TCPP is limited to 5 mg/kg under Commission Directive 2014/79/EU. TCPP is one of 56 flame retardant pages in our directory of plastic additives, each built to the same identity, dosage and regulatory fields.

This page sets out TCPP's identity and isomer status, its two-phase flame retardant mechanism, its physical and chemical properties, the polyurethane foam systems and use levels that carry it, its three plastics applications, its performance data against UL 94 and LOI benchmarks, the flame retardant packages it shares with triethyl phosphate, DMMP and expandable graphite, a dated regulatory matrix spanning REACH, the EU toy limit and US state rules, its safety profile status, how it compares with TCEP, TDCPP, TEP, DMMP, DMPP and expandable graphite, and the two producers that supply it.

What Is TCPP (Tris(chloropropyl) Phosphate)?#

TCPP is a phosphate triester carrying three chloropropyl groups, a chlorinated alkyl phosphate that delivers 9.5 % phosphorus and 32.5 % chlorine into a polyurethane formulation. The resulting molecule, C9H18Cl3O4P at 327.6 g/mol, functions as an additive flame retardant rather than a reactive one: it blends into the polyol side of a polyurethane formulation and is not bound into the polymer backbone. TCPP belongs to the organophosphate flame retardant (OPFR) class, and within that class it is grouped further as a chlorinated alkyl phosphate because chlorine sits on each of its three arms, alongside chemical cousins such as TCEP and TDCPP.

As a chlorinated phosphate ester, TCPP belongs to one of the two dominant halogen chemistries used in polyurethane foam; the hub on flame retardants for plastics compares all classes, from halogenated esters like TCPP to halogen-free phosphonates and mineral intumescents. Formulators choose TCPP as an additive flame retardant because it disperses into the liquid polyol blend before the foam cures, adding phosphorus and chlorine without changing the isocyanate chemistry that builds the polymer.

What does TCPP stand for?#

TCPP stands for tris(chloropropyl) phosphate, and the same product is sold and registered as TCIPP, tris(2-chloroisopropyl) phosphate and tris(1-chloro-2-propyl) phosphate. Suppliers and regulators use these variants interchangeably because each name describes the same three-armed chloropropyl ester registered under one identity, tris(2-chloro-1-methylethyl) phosphate, EC 237-158-7. A reader who searches "TCIPP" and a reader who searches "TCPP" reach the same CAS number, 13674-84-5.

Is TCPP a single substance or a mixture of isomers?#

TCPP is traded under one CAS number, 13674-84-5, while the commercial product is a mixture of chloropropyl isomers rather than a single pure ester. The substance is registered under REACH as tris(2-chloro-1-methylethyl) phosphate, EC 237-158-7, and that one registration covers the isomer mixture sold by every producer under this CAS number. The our sources behind this page records the commercial product as an isomer mixture, and the exact isomer naming within that mixture is still being verified, so this page does not print an isomer count or name individual isomers until that verification closes.

TCPP, TCP, TCEP and the TCPP porphyrin: which chemical is meant?#

Three other chemicals are regularly mistaken for the flame retardant TCPP: tricresyl phosphate (TCP), tris(2-chloroethyl) phosphate (TCEP) and, in older trade literature, triclosan. The aryl phosphate tricresyl phosphate is abbreviated TCP, one letter away, and is a different substance with a different function, covered on its own substance page under plasticizers. TCEP (CAS 115-96-8) carries two carbons per arm instead of TCPP's three, and unlike TCPP it is a Substance of Very High Concern listed on REACH Annex XIV.

Older trade usage sometimes abbreviated triclosan as "TCPP" (Markarian, Plastics, Additives and Compounding, 2006), a labelling shorthand that has nothing to do with the flame retardant and that current suppliers no longer use. Triphenyl phosphate (TPP) completes the set of phosphate-ester abbreviations that search results mix together, since it shares the same triester phosphate backbone as TCPP without the chlorine. A fourth, unrelated TCPP, tetrakis(4-carboxyphenyl)porphyrin, appears in metal-organic-framework chemistry and has no role in plastics.

How Does TCPP Work as a Flame Retardant?#

TCPP works in two phases at once: its chlorine releases hydrogen chloride that scavenges the H· and OH· radicals feeding the flame, while its phosphorus promotes char in the condensed phase. In the gas phase, the halogen mechanism common to chlorinated and brominated flame retardants releases HX (in TCPP's case, HCl), which scavenges the H· and OH· radicals that sustain combustion and converts them into a less reactive X· species, interrupting the radical chain reaction that keeps a flame burning.

In the condensed phase, the phosphorus in TCPP is associated with the modes of action documented for phosphorus flame retardants generally: it promotes char formation, intumescence and the build-up of an inorganic glass layer on the burning surface, each of which insulates the unburned polymer beneath it. In the gas phase, phosphorus flame retardants are also documented to contribute flame inhibition and a lower combustion efficiency, a process that carries a higher carbon monoxide yield as a documented consequence rather than as a TCPP-specific measurement.

The two modes of action of TCPP are listed below.

• Gas-phase radical scavenging: chlorine leaves the molecule as HCl and interrupts the H· and OH· radical chain that feeds the flame.
• Condensed-phase charring: phosphorus promotes char, intumescence and an inorganic glass layer that insulates the unburned polymer.

Both modes are set out with their reaction steps on how flame retardants work.

What Are the Physical and Chemical Properties of TCPP?#

TCPP is a clear, colourless, viscous liquid with a melting point of -42 °C (-43.6 °F), a density of 1.29 at 25 °C (77 °F) and a viscosity of 72 mPa·s at the same temperature.

The 5 % mass-loss temperature of 165 °C (329 °F) is a supplier thermogravimetric analysis (TGA) value for Fyrol PCF, and it sets the practical ceiling for processing and post-cure of a TCPP-containing foam. A widely published AI-generated overview on this topic prints the molecular formula C12H19ClO4P for TCPP, while PubChem CID 26176 gives C9H18Cl3O4P and a molecular weight of 327.6 g/mol, so the formula is worth checking against PubChem before copying it from a distributor or overview page. No boiling point, flash point, vapour pressure or water solubility value for TCPP is recorded in our sources.

Which Polymers Use TCPP, and at What Level?#

TCPP is used almost entirely in polyurethane foam, as an additive flame retardant blended into the polyol side rather than reacted into the polymer backbone. Our source library records TCPP in three polyurethane systems: rigid PU and PIR insulation foam, one-component and spray foam, and flexible PU foam, where it sits alongside triethyl phosphate (TEP), DMMP, expandable graphite and reactive phosphorus polyols in rigid systems, and alongside TDCPP (declining), melamine and expandable graphite in flexible systems. Our source library holds no verified TCPP dosage figure for any of these polymers, so this page states the role and the evidence rather than a level; for scale only, a related substance, DMPP, is recorded at 15 wt% in PUR in the ECHA plastic additives initiative mapping, a figure that belongs to DMPP, not to TCPP.

How are flame retardant levels expressed in a foam recipe? Polyurethane formulations are dosed in pphp, parts per hundred polyol, so every other component in the recipe is counted against 100 parts of polyol rather than against the finished foam. Thermoplastic recipes instead use PHR (parts per hundred resin), which counts each additive against 100 parts of resin, so a wt% conversion is needed before a TCPP loading level and a thermoplastic additive loading level can be compared directly.

TCPP in rigid PU and PIR insulation foam#

Rigid PU and PIR insulation board is the largest single use of TCPP, where it competes with triethyl phosphate, DMMP, expandable graphite and reactive phosphorus polyols in the same formulations. PIR foam in this application typically runs at an isocyanate index of 250 to 300, catalysed with a quaternary ammonium catalyst such as DABCO TMR-2 together with potassium octoate, and rigid PU foam blown with hydrofluoroolefins (HFOs) reaches a thermal conductivity of 17.1 to 21.1 mW/(m·K). The full rigid and flexible foam packages that TCPP appears in are compared on flame retardants for polyurethane foam.

TCPP in one-component and spray foam#

One-component foam, the canned sealing foam used around doors and windows, is a separate TCPP market from board stock, because it cures against ambient moisture in a sealed gap rather than on a laminator line. Our source library records this as a distinct application area but holds no TCPP level, can formulation or cure-time figure specific to it. EU chemicals law also treats one-component PU foam as a named product category in its own right, a regulatory fact addressed in the applications section below.

TCPP in flexible PU foam#

Flexible PU foam for furniture and bedding is the shrinking half of the TCPP market, because California TB 117-2013 replaced the open-flame foam test with a smoulder test on the cover fabric in 2014, and most foam now passes without any flame retardant. The standard does not ban flame retardants; it removed the open-flame ignition test that had driven their use in furniture foam, and SB 1019 adds a labelling duty for furniture made after 1 January 2015 that discloses whether flame retardant chemicals were added. TDCPP is recorded as declining in this application, while TCPP, reactive phosphorus polyols such as Exolit OP 560, melamine and expandable graphite make up the rest of the flexible-foam flame retardant set; melamine as a flame retardant is the nitrogen-based option recorded for the same flexible foam systems.

What Is TCPP Used For? Applications in Plastics#

TCPP is used in 3 plastics application areas: rigid PU and PIR insulation, one-component sealing foam, and flexible foam for furniture and bedding.

• Rigid PU and PIR insulation boards and spray-applied insulation
• One-component PU foam for sealing doors and windows
• Flexible PU foam for furniture, mattresses and bedding

Insulation boards and spray-applied insulation#

Insulation board and spray foam carry TCPP because building codes judge insulation by reaction-to-fire class, and an unmodified rigid PU foam does not reach the class its application needs. The fire standards named in the our sources behind rigid PU and PIR insulation include California TB 117-2013, BS 5852 and EN 13501-1, cited here by name only, since their pass/fail criteria are not verified for republication on this page. HFO-blown rigid foam in this application reaches a thermal conductivity of 17.1 to 21.1 mW/(m·K), the property that competes directly with the fire-performance requirement in a board's specification.

Furniture, mattresses and bedding foam#

Furniture, mattress and bedding foam is the application where TCPP meets the strictest US state rules, because California AB 2998 has banned covered flame retardants above 1,000 ppm in juvenile products, mattresses and upholstered furniture since 1 January 2020. The covered class under AB 2998 is halogenated and organophosphorus flame retardants, and TCPP is a chlorinated organophosphate flame retardant by class, so the rule reaches products containing it without naming it individually. Washington's Safer Products Cycle 1 restrictions, effective 1 January 2025, add a second state-level rule that covers flame retardants in recreational PU foam.

Door and window sealing foam#

Canned sealing foam for doors and windows is the third TCPP application, and EU chemicals law treats it as a product category of its own. The EU POPs Regulation (EU) 2019/1021 names one-component PU foam for door and window sealing as a distinct product category in its MCCP listing, with its own transitional exemption period, separate from board stock and separate from flexible furniture foam.

How Does TCPP Perform in Flame-Retardant Foam?#

TCPP delivers its flame retardancy through element loading: at 9.5 % phosphorus and 32.5 % chlorine, a formulator buys both radical scavenging and char formation from one liquid. What do the standard fire tests measure? UL 94 (and the equivalent IEC 60695-11-10) rates a material by vertical burn behaviour: the V-0 criteria require a single afterflame of 10 seconds or less, a total afterflame of 50 seconds or less over 10 applications, an afterglow of 30 seconds or less, and no flaming drips that ignite a cotton indicator below the sample. The V-0, V-1 and V-2 criteria in full are set out on UL 94 flammability ratings. No UL 94 rating, LOI value, heat release figure or smoke value specific to a TCPP-containing foam is recorded in our sources.

The limiting oxygen index (LOI) is the other standard indicator: measured under ISO 4589-2 or ASTM D2863, it reports the minimum oxygen concentration that sustains combustion, and both standards are explained in full on limiting oxygen index (LOI).

Two halogen-free comparison systems from recent literature illustrate what the surrounding chemistry can achieve, without representing TCPP performance: Węgrzyk et al. (Polymers, 2025) report that a viscoelastic PU foam combining expandable graphite, ammonium polyphosphate and a reactive phosphorus polyol reached an LOI of 28 to 31 %, a UL 94 V-0 rating, and a 92 % reduction in peak heat release rate. Kabir, Brehme and Schartel at BAM (Polymers, 2026) report that an expandable-graphite-rich coating on PU foam reached an LOI of 73 % and a MARHE of 18 kW/m², meeting railway HL3 fire limits.

How Does TCPP Interact with Other Flame Retardants and Additives?#

TCPP is normally one component of a flame retardant package rather than the whole of it: rigid formulations pair it with triethyl phosphate or DMMP for extra phosphorus, with expandable graphite for a physical char barrier, and with reactive phosphorus polyols that cannot migrate. The 3 partner types used with TCPP in polyurethane are listed below.

• Liquid phosphorus co-additives: triethyl phosphate (TEP) and DMMP, added for extra phosphorus content
• Physical intumescents: expandable graphite and ammonium polyphosphate, added for a char barrier
• Reactive phosphorus polyols: built into the polymer, so the phosphorus cannot migrate out of the foam

Expandable graphite expands from an onset of 140 to 230 °C, typically around 200 °C (392 °F), which is also roughly its processing ceiling of about 230 °C (446 °F), while ammonium polyphosphate's phase II form decomposes from about 240 °C (464 °F), a temperature spread that formulators use to sequence which intumescent activates first in a fire. Ammonium polyphosphate is the intumescent partner recorded alongside expandable graphite in these foam systems.

What Is the Regulatory Status of TCPP?#

TCPP is registered under REACH, is not a Substance of Very High Concern, is not restricted under REACH Annex XVII, and is limited to 5 mg/kg in toys for children under 36 months (status 23 September 2026).

Registration, evaluation and the restriction route that could still change TCPP's status are explained on REACH and plastic additives.

Furniture standards and the bans that follow them, including TB 117-2013 and the state rules above, are tracked in full on flame retardant regulations.

Is TCPP REACH registered, and is it an SVHC?#

Yes, TCPP is registered under REACH, and no, it is not a Substance of Very High Concern: it is absent from the Candidate List as checked on 22 September 2026. TCEP has been on the SVHC Candidate List since 13 January 2010 for reproductive toxicity under Article 57(c), and TCPP has never been added to it. This page prints the check date with every "not listed" answer rather than a permanent verdict, because the Candidate List is updated twice a year.

Is TCPP restricted under REACH Annex XVII?#

No, TCPP is not restricted under REACH Annex XVII, and the restriction work that would have changed that has been on hold since 2019. ECHA's 2018 screening report on TCEP, TCPP and TDCP identified a risk to children from these three chlorinated phosphates in flexible PU foam used in childcare articles and furniture, and the European Commission requested a restriction dossier in response. That dossier work was put on hold in 2019 pending new data, and ECHA's March 2023 flame retardants regulatory strategy placed organophosphorus flame retardants, including TCPP, in the group that still needs more data before a restriction proposal can move forward. The entries that do currently restrict plastic additives are listed on REACH Annex XVII restrictions.

Is TCPP allowed in toys and childcare articles?#

TCPP is allowed in toys only up to 5 mg/kg when the toy is intended for children under 36 months or is meant to be placed in the mouth, a limit Commission Directive 2014/79/EU sets jointly for TCEP, TCPP and TDCP. This is a content limit in the toy material itself, not a migration limit, and it does not convert into a ppm figure for a foam recipe. Childcare articles more broadly were the subject of the restriction work described above, which remains on hold. The migration and content limits that apply across the toy category sit on EU Toy Safety Regulation.

Is TCPP allowed in food-contact plastics?#

Our source library records no entry for TCPP in Annex I of Regulation (EU) No 10/2011, and its food-contact status is being verified. By contrast, TCEP is listed in EU 10/2011 as FCM substance 280 with a specific migration limit of "not detectable," a listing that does not extend to TCPP.

What is the US status of TCPP?#

The strongest US rules that reach TCPP are state rules written for the whole class of organophosphorus and halogenated flame retardants, not federal rules written for TCPP by name. California AB 2998 (from 1 January 2020), Washington's Safer Products Cycle 1 (from 1 January 2025) and New York's organohalogen ban in electronic display enclosures and stands (from 1 January 2024) each reach TCPP as a member of a regulated class rather than by CAS number. US state laws on plastic additives compares all three in full.

No TSCA record for TCPP is recorded in our sources. By contrast, TCEP, the chlorinated phosphate that TCPP replaced in most applications, received a final TSCA risk evaluation in September 2024 that found unreasonable risk to workers in 7 of 21 conditions of use, to consumers in 3, and to aquatic species. TCEP has carried a California Proposition 65 cancer listing since 1 April 1992 and TDCPP since 28 October 2011; TCPP's status against the current California Proposition 65 list has not been verified and is being checked rather than stated as an absence.

Is TCPP Safe? Health, Safety and Environmental Profile#

TCPP is an additive flame retardant, blended into the foam rather than bound into it, and that unbound state is the reason regulators have looked at children's exposure from flexible foam since 2018. Our sources hold no GHS or CLP classification record for TCPP, so this page states no hazard statement, no classification and no carcinogenicity verdict for TCPP. What our source library does record, what sits at the class level, and what remains open are listed below.

• What is known: TCPP is not a Substance of Very High Concern; ECHA's 2018 screening report identified a risk to children from TCEP, TCPP and TDCP together in flexible PU foam used in childcare articles and furniture.
• What is class-level: ECHA's March 2023 flame retardants strategy placed organophosphorus flame retardants, the class TCPP belongs to, in the group needing more data; a first ECHA OPFR investigation report is expected in December 2026 and a second in December 2027, reported here from a secondary source.
• What is open: TCPP carries no harmonised CLP classification record in our sources, and its hazard classification is under assessment rather than settled.

Because TCPP is not chemically bound to the polyurethane it flame-retards, reactive phosphorus polyols are the alternative recorded in our source library as removing the migration pathway entirely, since their phosphorus is built into the polymer rather than blended into it. The exposure studies behind the class-wide concern for chlorinated and organophosphorus flame retardants are summarised on flame retardants and human health.

The difference between a harmonised CLP entry, which applies to every user of a substance, and a registrant self-classification, which one or more companies declare without an EU-wide vote, is explained on CLP classification of plastic additives. This page will add a classification section once our sources carry a verified record.

What Are the Alternatives to TCPP?#

The 5 alternatives our source library records for TCPP are triethyl phosphate, DMMP, expandable graphite, TDCPP and reactive phosphorus polyols, and they split into liquid phosphorus esters, a physical intumescent, a legacy chlorinated ester and a bound-in option.

Hazard entries are the records held in our source library on 23 September 2026. An empty or "no classification record" cell means no record, not an absence of hazard.

Filter these same options by polymer and target fire rating in the flame retardant selector by polymer.

TCPP vs TCEP#

TCPP and TCEP differ by one carbon per arm: TCEP carries three chloroethyl groups, TCPP three chloropropyl groups, and that difference decides their legal status rather than their chemistry. TCEP (CAS 115-96-8, EC 204-118-5, C6H12Cl3O4P, MW 285.5) has been a Substance of Very High Concern since 13 January 2010 under Article 57(c) and has needed a REACH authorisation since its Annex XIV sunset date of 21 August 2015, while TCEP has carried a harmonised Carc. 2 H351 and Repr. 1B H360F classification throughout that period. TCPP has neither an SVHC listing nor an Annex XVII entry, and TCEP has not been produced in the EU since 2001, a substitution the market completed well before TCPP's current regulatory review began.

TCPP vs TDCPP#

TDCPP carries six chlorine atoms to TCPP's three, and that extra halogen comes with a harmonised Carc. 2 classification and a California Proposition 65 cancer listing dated 28 October 2011 that TCPP does not carry. TDCPP (CAS 13674-87-8, EC 237-159-2, C9H15Cl6O4P, MW 430.9) carries the harmonised CLP index 015-199-00-X for Carc. 2 H351 but is not an SVHC, and it has been detected in more than 96 % of US house-dust samples collected between 2002 and 2007 at a mean concentration of 1.8 ppm. TDCPP (tris(1,3-dichloro-2-propyl) phosphate) is recorded as a declining share of the flexible PU foam market for furniture, automotive interiors and baby products, the same application area where TCPP is gaining the volume TDCPP leaves behind.

TCPP vs TEP, DMMP and DMPP#

Triethyl phosphate, DMMP and DMPP are the halogen-free liquid phosphorus esters that compete with TCPP in rigid foam, and each buys phosphorus at a different price in handling terms. Triethyl phosphate (CAS 78-40-0, C6H15O4P, MW 182.15) doubles as a viscosity reducer in PU foam and unsaturated polyester resin, is registered under REACH, is not an SVHC, and carries only a harmonised Acute Tox. 4* H302 classification.

Among the three, DMMP (CAS 756-79-6, C3H9O3P, MW 124.08) delivers the highest phosphorus content, but its PubChem notifications include H340 from the majority of notifiers along with H361 and H318/H319, and it is a Chemical Weapons Convention Schedule 2 chemical, so buying it brings export controls and declaration duties that TCPP does not.

The fourth halogen-free option in this comparison, dimethyl propylphosphonate (DMPP) (CAS 18755-43-6, C5H13O3P, MW 152.13), is a REACH intermediate-use substance, not an SVHC and not listed in EU 10/2011 Annex I, and it carries the only PUR use level recorded in this directory, 15 wt%, from the archived ECHA plastic additives initiative mapping exercise.

TCPP vs expandable graphite and reactive phosphorus polyols#

Expandable graphite and reactive phosphorus polyols are the two halogen-free routes that replace TCPP rather than supplement it: the first works physically, the second is built into the polymer. Expandable graphite (CAS 12777-87-6, EC 235-819-4) expands from an onset of 140 to 230 °C, typically about 200 °C (392 °F), with a processing ceiling typically below 230 °C (446 °F), and polyurethane foam is its main commercial use. In one study, Węgrzyk et al. (Polymers, 2025) combined expandable graphite with ammonium polyphosphate and a reactive phosphorus polyol in a viscoelastic PU foam and reached an LOI of 28 to 31 %, a UL 94 V-0 rating and a 92 % reduction in peak heat release rate; in a separate study, 15 php expandable graphite with 30 php filler cut the peak heat release rate of a viscoelastic PU foam by 52 % (Polymers, 2024).

Reactive phosphorus polyols, such as Exolit OP 560, take a different route: they build phosphorus into the polyol backbone itself, so the flame retardant becomes part of the polymer rather than an additive that can migrate out of it, which is the property that TCPP, as an additive flame retardant, does not share.

Who Manufactures TCPP? Grades and Suppliers#

TCPP is sold under two trade names recorded in our substance directory: Fyrol PCF from ICL and Levagard PP from Lanxess. ICL, based in Israel, lists Fyrol PCF among its flame retardant product line, and it is the source of the 9.5 % phosphorus, 32.5 % chlorine and TGA specification used on this page. Lanxess, headquartered in Cologne, Germany, acquired Chemtura in a deal completed on 21 April 2017 and has held the LEVAGARD brand since. The global flame retardant market was worth an estimated 8.1 to 9.3 billion USD in 2025, a range that reflects differing analyst estimates rather than a single published figure.

Buyers should ask every supplier for the current safety data sheet, the CLP label in force and a statement of the phosphorus and chlorine content, because the classification of this substance is under review. More producers and their locations are listed in the directory of flame retardant manufacturers.

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How Do Chlorinated Phosphate Esters Fit into the Flame Retardant Family?#

TCPP is the working member of the chlorinated phosphate esters, a group that sits in two families at once: it is counted among the chlorinated flame retardants for its halogen and among the organophosphates for its phosphorus. The class members with their own pages in this directory are TCEP and TDCPP, each covered above for how they differ from TCPP in chemistry and in regulatory status.

The class is covered in full on chlorinated flame retardants, together with Dechlorane Plus and the chlorinated paraffins that share the halogen half of TCPP's dual classification.

ECHA's 2023 strategy treats organophosphorus flame retardants as a group still needing more data before any restriction proposal, a review status that covers TCPP alongside its relatives. The same substance is counted among the organophosphate flame retardants, beside TPP, RDP and BDP, for the phosphorus half of its identity.

The TCEP to TCPP substitution chain#

The chlorinated phosphate esters show a clean substitution chain: TCEP left the EU market first, TCPP took its volume, and TDCPP is now declining in flexible foam. TCEP became an SVHC on 13 January 2010, entered Annex XIV as entry 13 with a sunset date of 21 August 2015, and has not been produced in the EU since 2001. TCPP took the volume TCEP left behind and carries neither an SVHC listing nor an Annex XVII restriction, while the restriction work that once covered all three chlorinated phosphates together stopped in 2019.

Halogenated or halogen-free: where TCPP sits#

TCPP is a halogenated flame retardant, which decides whether a formulation can be sold into markets that specify halogen-free. The EU Ecodesign Regulation (EU) 2019/2021 bans all halogenated flame retardants from the enclosures and stands of electronic displays from 1 March 2021, a rule that reaches TCPP by class even though electronics enclosures are not among its recorded applications. The halogen-free options that appear in the same rigid and flexible PU foam formulations as TCPP are:

• Liquid phosphorus esters: triethyl phosphate and DMMP
• Physical and reactive intumescents: expandable graphite and ammonium polyphosphate
• Nitrogen and reactive options: melamine and reactive phosphorus polyols

The options that meet a halogen-free specification are listed in full on halogen-free flame retardants.

TCPP outside plastics#

Textile back-coatings and non-plastics uses of TCPP fall outside the scope of this reference, which covers TCPP as a plastics additive. Our sources record only polyurethane foam uses for TCPP in the plastics sense that this directory covers.

Is TCPP banned?#

No, TCPP is not banned: it is registered under REACH, is not on the Candidate List and is not restricted under Annex XVII, with a 5 mg/kg limit in toys for children under 36 months as the only substance-specific EU limit (status 23 September 2026). At the class level, US state rules including California AB 2998, Washington's Safer Products Cycle 1 and New York's organohalogen display ban do restrict the broader group of halogenated and organophosphorus flame retardants that TCPP belongs to, even though none of them name TCPP by CAS number.

Does TCPP migrate out of foam?#

TCPP is an additive flame retardant, so it is not chemically bound to the polyurethane and can leave the foam over time, which is why reactive phosphorus polyols are the recorded migration-free alternative. No migration rate, emission factor or dust concentration for TCPP is recorded in our sources; the mechanism for why unbound additives leave a polymer is explained on additive migration in plastics.

Does TCPP need an SDS?#

Yes: every supplier issues a safety data sheet for TCPP, and the label on it is the item to check right now, because the classification of this substance is under review in the EU. A current SDS from ICL or Lanxess is the fastest way to confirm the phosphorus and chlorine content and the label in force before ordering.

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