The U.S. Environmental Protection Agency (EPA) issued a new rule effective July 2024 that bans most industrial uses of methylene chloride and restricts manufacturing of the chemical. The rule impacts a wide range of industries and could represent a significant shift for some facilities subject to methylene chloride regulations.
In this article, we explore how the chemical has been regulated in the past, the implications of the rule, and the steps to stay compliant with the new EPA regulation.
What is Methylene Chloride and How Has it Been Regulated?
The EPA has determined that methylene chloride is a neurotoxicant and carcinogen. At the same time, the chemical has many industrial, commercial, research, and consumer uses, such as paint stripping, pharmaceutical manufacturing, and metal cleaning and degreasing.
Under the Toxic Substances Control Act (TSCA), the EPA must create rules that curb any “unreasonable risk of injury to health or the environment” that chemicals might pose. However, one major hurdle in TSCA previously required the EPA to demonstrate a scientific reason for concern before testing for that concern, thus limiting the EPA’s ability to evaluate toxicity to the extent that the U.S. Congress intended for the measure. Following an overhaul of TSCA in 2016, which removed this requirement, the EPA started reviewing the health risks of 10 chemicals, including methylene chloride.
From Targeted Regulation to a Blanket Ban
On March 15, 2019, the EPA issued a final rule to ban the immediate commercial use of methylene chloride in paint strippers. This was followed by a ban on all consumer use of methylene chloride with a compliance deadline of May 5, 2025.
The EPA’s new methylene chloride rule builds on these previous restrictions. It imposes a blanket ban on the chemical’s use and manufacture with most commercial applications prohibited after April 28, 2026. Methylene chloride may be used only for very specific furniture refinishing until May 8, 2029, with workplace protections. This use will be prohibited after that date.
The rule also aims to protect workers from methylene chloride exposure while on the job. It requires a workplace chemical protection program that includes inhalation exposure concentration limits and related exposure monitoring, as well as controls for 13 conditions of use for the chemical. The Occupational Safety and Health Administration (OSHA) already has methylene chloride regulations for the workplace. However, the exposure thresholds in the EPA’s new rule are much lower than OSHA’s.
While the new regulation restricts legal uses of methylene chloride, it also provides a time-limited exemption for critical or essential use of the chemical when technically or economically feasible alternatives aren’t available.
How to Stay Compliant
The rule rolls out methylene chloride restrictions in a staggered timeframe (Table 1). The first compliance date is February 3, 2025.
Table 1. Methylene Chloride Prohibition Timeframe Requirements
| Prohibition | Requirement | Compliance Date |
| Prohibition on distributing to retailers | Distributors cannot sell methylene chloride products to any retailers after February 3, 2025. See Unit IV and § 751.107(b)(1). | February 3, 2025 |
| Prohibition on distributing by retailers | Retailers cannot distribute methylene chloride products to any customer, including to commercial users, after May 5, 2025. See Unit IV and § 751.107(b)(2). | May 5, 2025 |
| Prohibition on manufacturing | After May 5, 2025, all persons are prohibited from manufacturing (including import) methylene chloride except for conditions of use that will continue under the WCPP. See Unit IV and § 751.107(b)(3). | May 5, 2025 |
| Prohibition on processing | After August 1, 2025, all persons are prohibited from processing methylene chloride, including any methylene chloride-containing products, except for conditions of use that will continue under the WCPP. See Unit IV and § 751.107(b)(4). | August 1, 2025 |
| Prohibition on all distributors other than retailers | After January 28, 2026, all persons are prohibited from distributing in commerce (including making available) methylene chloride, including any methylene chloride-containing products, except for conditions of use that will continue under the WCPP. See Unit IV and § 751.107(b)(5). | January 28, 2026 |
| Prohibition on industrial and commercial use | After April 28, 2026, all persons are prohibited from industrial or commercial use of methylene chloride, including any methylene chloride containing products, except for conditions of use that will continue under the WCPP. See Unit IV and § 751.107(b)(6). | April 28, 2026 |
| Prohibition with extended timeframe on industrial and commercial use for paint and coating removal for refinishing of wooden furniture, decorative pieces, and architectural fixtures of artistic, cultural, or historic significance | After May 8, 2029, all persons are prohibited from manufacturing (including import), processing, distribution in commerce, or use of methylene chloride, including any methylene chloride containing products, for industrial or commercial use for paint and coating removal for refinishing of wooden furniture, decorative pieces, and architectural fixtures of artistic, cultural, or historic significance, with interim requirements. See Unit IV and § 751.107(b)(8). | May 8, 2029 |
| Prohibition with extended timeframe on industrial or commercial use for adhesives and sealants in aircraft, space vehicle, and turbine applications for structural and safety critical non-structural applications | After May 8, 2029, all persons are prohibited from manufacturing (including import), processing, distribution in commerce, or use of methylene chloride, including any methylene chloride-containing products, for industrial or commercial use for adhesives and sealants in aircraft, space vehicle, and turbine applications for structural and safety critical non-structural applications. See Unit IV and § 751.107(b)(9). | May 8, 2029 |
Facilities should consider reviewing their current inventory to identify materials that contain methylene chloride. If they do find such materials, facilities should be careful to follow local, state, and federal regulations for the management and disposal of the chemical.
The EPA published a comprehensive compliance guide for the new methylene chloride rule. You can also contact Trihydro’s professionals with questions about the EPA’s methylene chloride directive and what steps you should be considering.
