If your company manufactures, imports, processes, or distributes electronic products or components in the United States, changes under the Toxic Substances Control Act (TSCA) can affect more than chemical handling at your own facilities.

They can reach into your supplier network, component materials, manufacturing processes, product formulations, documentation, and U.S. market access.

The U.S. Environmental Protection Agency (EPA) has taken significant action under TSCA Section 6(a) on chemicals including trichloroethylene (TCE), perchloroethylene (PCE), and carbon tetrachloride (CTC). EPA has also revised requirements for two of the five persistent, bioaccumulative, and toxic (PBT) chemicals regulated under TSCA Section 6(h): DecaBDE and PIP (3:1).

For electronics manufacturers, the challenge is not simply knowing that a chemical is regulated.

The real challenge is answering:

Where could a TSCA-restricted chemical enter our supply chain, which products or processes are affected, what restrictions apply, and what evidence do we need to demonstrate compliance?

That requires visibility beyond the finished product.

It requires a connected view of:

Supplier → Material → Component → Manufacturing Process → Product → U.S. Regulatory Requirement → Evidence

What Is TSCA and Why Does It Matter to Electronics Manufacturers?

The Toxic Substances Control Act (TSCA) is the U.S. federal framework governing the manufacture, import, processing, distribution, use, and disposal of many chemical substances.

EPA can use TSCA to:

• Evaluate chemical risks
• Restrict or prohibit certain uses
• Limit manufacturing or processing
• Regulate distribution in commerce
• Establish workplace protections
• Require recordkeeping and notifications
• Address unreasonable risks associated with chemical substances

For electronics companies, TSCA compliance can therefore extend beyond the chemicals directly purchased by the manufacturer.

A restricted chemical can enter the supply chain through:

• Plastics
• Flame retardants
• Wire and cable insulation
• Adhesives
• Sealants
• Lubricants
• Coatings
• Cleaning solvents
• Electronic components
• Circuit boards
• Manufacturing equipment
• Semiconductor processing
• Specialized industrial materials

This makes supply-chain chemical visibility a central part of TSCA compliance.

Regilient's TSCA compliance resources provide additional background on the regulation and its implications for manufacturers.

EPA’s Latest TSCA Restrictions: What Electronics Companies Need to Know

The regulatory landscape is not static.

Several major TSCA actions affecting TCE, PCE, CTC, DecaBDE and PIP (3:1) have been finalized, reconsidered, amended, or had compliance dates adjusted.

EPA's current PBT framework covers five chemicals: DecaBDE, PIP (3:1), 2,4,6-TTBP, HCBD, and PCTP.

TCE: What the TSCA Restrictions Mean for Electronics

What is TCE?

Trichloroethylene (TCE) is a volatile organic compound historically used in industrial and commercial applications, including solvent cleaning and degreasing.

For electronics manufacturing, the relevant concern is its potential use in:

• Industrial cleaning
• Degreasing
• Manufacturing processes
• Specialized processing operations
• Cleaning of equipment or components

EPA finalized its TSCA Section 6(a) risk management rule for TCE in December 2024. The rule prohibits most uses of TCE, including manufacture and processing for most commercial uses and all consumer products, with longer phase-out periods and stringent workplace controls for certain uses.

What changed?

The original rule established a broad prohibition structure, but subsequent legal and regulatory actions changed specific compliance timelines.

In September 2025, EPA extended the compliance date for two specific uses:

• TCE as a processing aid in nuclear-fuel manufacturing — extended to September 15, 2028
• Certain wastewater-disposal requirements — extended to December 18, 2026

EPA also maintains longer phase-out periods for a limited number of uses subject to workplace protections.

What does this mean for electronics manufacturers?

If TCE is used directly in your manufacturing process, the issue is immediate.

But even if your facility does not purchase TCE directly, you may need to investigate whether:

• Contract manufacturers use TCE
• Component suppliers use TCE
• Cleaning services use TCE
• Manufacturing equipment is operated with TCE-containing processes
• Imported components are produced using restricted chemical processes

The compliance question therefore becomes:

"Do we use TCE?"

and also:

"Could TCE enter our supply chain through a supplier or manufacturing process?"

PCE: EPA Restrictions on Perchloroethylene

What is PCE?

Perchloroethylene (PCE) is a solvent used in industrial and commercial applications, including cleaning, degreasing, vapor degreasing, adhesives and sealants.

EPA finalized its TSCA Section 6(a) rule for PCE in December 2024.

The final rule bans many uses and establishes workplace controls for certain uses that continue. EPA specifically identifies vapor degreasing and energized electrical cleaning among uses allowed to continue under specified controls.

This is particularly relevant to electronics because specialized electrical and electronic cleaning can involve PCE.

Current PCE compliance situation

The PCE regulatory picture is evolving.

In March 2026, EPA proposed extending certain Workplace Chemical Protection Program compliance dates for non-federal owners and operators.

The proposed dates include:

EPA states that existing deadlines remain effective until modified through rulemaking. The agency is also reconsidering the 2024 final rule.

What electronics manufacturers should do

Do not build your compliance program around an old "three-year phase-out" statement.

Instead, monitor:

• Current EPA rule status
• Applicable use
• Current compliance date
• Workplace controls
• Supplier use
• Process-specific exposure requirements
• Regulatory amendments

This is particularly important for companies operating:

• PCB manufacturing
• Semiconductor facilities
• Electronics cleaning operations
• Specialized electrical cleaning
• Precision component manufacturing

Carbon Tetrachloride: A Supply-Chain and Workplace-Control Issue

Carbon tetrachloride (CTC) is another chemical subject to EPA action under TSCA Section 6(a).

EPA finalized its CTC risk-management rule in December 2024. The rule prohibits some uses and requires protections for many continuing uses.

However, the CTC regulatory position has also evolved.

In 2025, EPA announced that it was reconsidering the final rule. In March 2026, EPA proposed extending certain compliance dates while it works to revise the rule.

Why this matters to electronics supply chains

CTC may not be a typical material in an electronic finished product.

The risk may instead exist within:

• Chemical manufacturing
• Specialized industrial processing
• Upstream suppliers
• Contract manufacturing
• Legacy manufacturing processes

Therefore, TSCA supply-chain assessment should distinguish between:

Product composition risk

and

Manufacturing-process chemical risk.

Both can matter.

TSCA Section 6(h): PBT Chemicals and Electronics

TSCA Section 6(h) requires EPA to take expedited action on specified persistent, bioaccumulative, and toxic (PBT) chemicals.

EPA's five PBT chemicals are:

1. Decabromodiphenyl ether (DecaBDE)
2. Phenol, isopropylated phosphate (3:1) — PIP (3:1)
3. 2,4,6-Tris(tert-butyl)phenol — 2,4,6-TTBP
4. Hexachlorobutadiene — HCBD
5. Pentachlorothiophenol — PCTP

EPA's current PBT page notes that the 2024 final rule revised the requirements for DecaBDE and PIP (3:1) and addressed implementation issues affecting multiple industries, including semiconductor production and electronic equipment.

This is highly relevant to electronics manufacturers.

PIP (3:1): A Major Electronics Supply-Chain Concern

What is PIP (3:1)?

Phenol, isopropylated phosphate (3:1) is used as:

• A plasticizer
• Flame retardant
• Anti-wear additive
• Anti-compressibility additive

It can occur in industrial coatings, adhesives, sealants, lubricants, greases and plastic articles.

The 2024 amendments are particularly important for electronics because EPA created or revised phase-out provisions affecting:

• Electronic equipment
• Manufacturing equipment
• Semiconductor manufacturing equipment
• Commercial electronic equipment
• Personal electronic equipment
• Laboratory equipment
• HVAC and water-heating equipment
• Power-generating equipment

EPA also established requirements involving customer notifications, worker protections and recordkeeping.

Why PIP 3:1 is difficult for electronics companies

PIP 3:1 may not appear as an obvious "chemical ingredient" in the finished product.

It may instead be present in:

• Plastic components
• Wire harnesses
• Circuit boards
• Coatings
• Adhesives
• Specialized equipment
• Manufacturing equipment

This makes supplier declarations and material disclosures critical.

A manufacturer may need to ask:

Does this component contain PIP (3:1)?

But also:

Is the component covered by a specific exclusion, phase-out provision, or compliance date?

PIP (3:1) and Circuit Boards: A Critical Distinction

The 2024 EPA rule specifically addressed certain uses involving circuit boards and wire harnesses.

EPA's current PBT summary identifies an exclusion for processing and distribution in commerce of PIP (3:1) and PIP-containing products for use in circuit boards and wire harnesses, as well as PIP-containing circuit boards and wire harnesses.

That means an electronics manufacturer should not simply implement a blanket rule:

"PIP 3:1 = prohibited."

The correct approach is:

Identify → Determine use → Check applicable exclusion/phase-out → Verify deadline → Document evidence

This distinction is critical for accurate supply-chain compliance.

DecaBDE: Flame Retardant Restrictions for Electronics

What is DecaBDE?

Decabromodiphenyl ether (DecaBDE) is a brominated flame retardant historically used in plastics and other materials.

EPA identifies uses involving:

• Plastic enclosures for televisions
• Computers
• Audio and video equipment
• Wire and cable
• Communication and electronic equipment
• Aerospace applications
• Automotive applications

EPA's 2021 rule prohibited manufacture, import, processing and distribution in commerce of DecaBDE and DecaBDE-containing products for all uses, subject to specified exemptions and phase-outs.

The 2024 amendments added further requirements, including:

• A 0.1% by-weight threshold for unintentional amounts in products and articles
• Worker-protection requirements
• Five-year recordkeeping
• Water-release restrictions
• Additional requirements for specified sectors and uses

Electronics supply-chain implication

If your product contains:

• Plastic housings
• Wire and cable
• Electronic enclosures
• Legacy flame-retardant materials
• Specialized components

you should determine whether DecaBDE is present and whether the material falls within a current exemption, phase-out, threshold or other provision.

The Five PBT Chemicals: Electronics Compliance Overview

The five substances were identified under TSCA Section 6(h) for expedited action to reduce exposures to the extent practicable.

Not all five have the same relevance to electronic products.

That is why a risk-based supply-chain assessment is preferable to treating every PBT substance identically.

What These TSCA Changes Mean for Electronics Supply Chains

The biggest impact of these rules is not necessarily the regulatory text itself.

It is the data problem they create for manufacturers.

A typical electronics manufacturer may have:

• Thousands of components
• Hundreds of suppliers
• Multiple contract manufacturers
• Global material sources
• Different manufacturing processes
• Multiple product configurations
• Legacy components
• Changing supplier declarations

Chemical information may be fragmented across:

• Supplier declarations
• SDS documents
• Material declarations
• FMDs
• Technical specifications
• Bills of materials
• Test reports
• Engineering documentation
• Procurement systems

The result is a fundamental question:

Can you trace a regulated chemical from the supplier and material level all the way to the finished product?

If the answer is no, TSCA compliance becomes reactive.

TSCA Compliance Requires More Than an SDS

A Safety Data Sheet can provide important information, but it may not provide the complete material-level information needed to determine product compliance.

For complex electronic products, manufacturers may need:

Supplier declarations

Ask suppliers to confirm whether specified TSCA substances are present or used.

Material composition

Understand which materials and homogeneous materials contain regulated substances.

Full Material Disclosure

Where appropriate, use structured Full Material Disclosure (FMD) to obtain more detailed material information.

Component-level mapping

Connect chemical information to actual component part numbers.

BOM-level assessment

Determine which products contain affected components.

Regulatory mapping

Map the chemical to the applicable TSCA restriction and use condition.

Evidence management

Retain the supplier documentation and supporting evidence behind the compliance decision.

How to Build a TSCA Electronics Supply-Chain Compliance Program

A practical program can be built around six steps.

1. Identify regulated chemicals

Create a controlled list of TSCA-restricted chemicals relevant to your products, processes and suppliers.

For the current regulatory environment, this should include the applicable TCE, PCE, CTC and PBT requirements.

2. Map chemicals to materials and components

Determine where these chemicals could occur.

For example:

PIP 3:1 → plastic → component → BOM → product

or:

PCE → manufacturing process → supplier → component → product

This distinction is important because not every TSCA risk is a finished-product composition issue.

3. Assess your suppliers

Ask suppliers targeted questions instead of sending generic compliance questionnaires.

For example:

• Does the supplied component contain PIP (3:1)?
• Does it contain DecaBDE?
• Is the component manufactured using a restricted TSCA chemical?
• Does an applicable exclusion or phase-out provision apply?
• What evidence supports the declaration?
• When was the information last updated?

4. Collect structured material data

Where supplier declarations are insufficient, request more detailed material information.

This can include:

• FMD
• Material declarations
• Chemical composition
• SDS
• Test reports
• Supplier certificates

Structured data makes it easier to screen large numbers of components.

5. Map regulatory status to products

A chemical finding is not the same thing as a product non-compliance finding.

You need to determine:

Chemical → Application → Component → Product → U.S. regulatory requirement

This allows compliance teams to distinguish between:

• Prohibited uses
• Permitted uses
• Excluded uses
• Phase-out uses
• Uses with additional controls
• Uses requiring further supplier evidence

6. Continuously monitor regulatory changes

This is essential because EPA actions can change compliance dates, exemptions, phase-outs and implementation requirements.

The current TCE, PCE and CTC landscape demonstrates why a static compliance spreadsheet can quickly become outdated.

TSCA Compliance Checklist for Electronics Manufacturers

Use this checklist to assess your current readiness:

If several answers are No, your organization may have a visibility gap rather than simply a documentation gap.

How Regilient Helps with TSCA Supply-Chain Compliance

Managing TSCA compliance across complex electronics supply chains can involve thousands of components and hundreds of suppliers.

Regilient's TSCA compliance software helps organizations centralize restricted-substance information and connect supplier evidence with products and compliance requirements.

Supplier data collection

Automate supplier outreach and follow-ups to collect current chemical and compliance declarations.

Material and component screening

Screen component and material information against restricted-substance requirements.

Regulatory mapping

Map chemical restrictions to components, BOMs and finished products.

Evidence management

Centralize supplier declarations, FMDs, supporting documents and compliance decisions.

Change monitoring

Identify affected products when supplier information, materials or regulatory requirements change.

Product-level reporting

Roll up component and material information into product-level compliance reports.

The objective is to create a traceable chain:

Supplier → Material → Component → BOM → Product → Regulation → Evidence

rather than maintaining disconnected spreadsheets and email records.

Why Electronics Manufacturers Need Continuous TSCA Monitoring

The regulatory environment is changing faster than traditional compliance workflows are designed to handle.

EPA's recent actions illustrate this clearly:

• TCE restrictions have undergone litigation and compliance-date changes.
• PCE compliance dates are being reconsidered and proposed for extension.
• CTC requirements are under reconsideration.
• PIP (3:1) requirements were revised to address supply-chain and sector-specific implementation issues.
• DecaBDE requirements were also revised in 2024.

For electronics manufacturers, this means regulatory monitoring cannot be separated from product compliance data.

When a regulation changes, the business needs to know:

Which suppliers, materials, components, products and manufacturing processes are affected?

That is the operational question compliance teams need to answer quickly.

Frequently Asked Questions About TSCA Compliance for Electronics

What is TSCA compliance?

TSCA compliance means meeting applicable U.S. requirements governing chemical substances under the Toxic Substances Control Act, including restrictions on manufacture, import, processing, distribution, use and disposal where applicable.

Does TSCA apply to electronics manufacturers?

Yes. TSCA can affect electronics manufacturers through chemicals used in products, components, materials and manufacturing processes. It can also affect companies that import or distribute products containing regulated chemical substances.

What are the latest TSCA restrictions affecting electronics?

Important current areas include EPA's Section 6(a) risk-management rules for TCE, PCE and CTC and Section 6(h) requirements for PBT chemicals including PIP (3:1) and DecaBDE.

Is TCE banned under TSCA?

EPA's final TCE rule prohibits most uses of TCE, including manufacture and processing for most commercial uses and all consumer products. Certain uses have longer phase-out periods and stringent workplace requirements, and EPA has subsequently modified specific compliance dates.

Is PCE banned under TSCA?

EPA's PCE rule prohibits many uses and establishes workplace controls for certain uses that continue. Some uses, including vapor degreasing and energized electrical cleaning, can continue under specified requirements. The agency is also reconsidering aspects of the 2024 rule.

Is carbon tetrachloride banned under TSCA?

Not universally. EPA's 2024 CTC rule prohibits certain uses and establishes workplace protections for many continuing uses. EPA is reconsidering the rule and has proposed extending certain compliance dates.

What are the five PBT chemicals regulated under TSCA Section 6(h)?

The five are:

• DecaBDE
• PIP (3:1)
• 2,4,6-TTBP
• HCBD
• PCTP

EPA has established restrictions to reduce exposure to these chemicals to the extent practicable.

Why is PIP 3:1 important for electronics?

PIP (3:1) can be associated with plastics, coatings, lubricants and other materials, and EPA's revised requirements specifically address certain uses involving electronic equipment, circuit boards, wire harnesses and semiconductor/manufacturing equipment.

Why is DecaBDE important for electronics?

DecaBDE has historically been used as a flame retardant in plastic enclosures, wire and cables and electronic equipment. EPA restricts manufacture, import, processing and distribution in commerce of DecaBDE and products containing it, subject to specified exemptions and phase-outs.

Is an SDS enough for TSCA compliance?

Not necessarily. An SDS can be an important source of chemical information, but electronics manufacturers may require additional supplier declarations, material disclosures, FMDs, component information and regulatory applicability evidence.

How can manufacturers identify TSCA-restricted chemicals in their supply chain?

Start by mapping regulated substances to suppliers, materials, components and manufacturing processes. Then collect supplier declarations and material data and connect that information to BOMs and finished products.

How does compliance software help with TSCA?

Compliance software can automate supplier data collection, screen material and component information, map regulatory requirements, track evidence and roll up compliance information from components to products.

The Bottom Line: TSCA Compliance Is Becoming a Supply-Chain Data Problem

For electronics manufacturers, TSCA compliance is no longer simply a matter of knowing which chemicals EPA regulates.

The harder question is:

Can you prove where those chemicals are—or are not—across your supply chain?

TCE, PCE and CTC demonstrate how process chemicals can create regulatory exposure.

PIP (3:1) and DecaBDE demonstrate how restricted substances can enter through materials, components and electronic equipment.

The compliance model therefore needs to move from:

Supplier declaration → Spreadsheet → Manual review

to:

Supplier → Material → Component → BOM → Product → Regulation → Evidence → Continuous monitoring

Companies that build this traceability into their compliance process can respond faster when EPA changes restrictions, suppliers update declarations or product designs change.

Is your electronics supply chain ready for changing TSCA requirements?

Explore Regilient TSCA Compliance Software to centralize supplier declarations, material information, restricted-substance screening and product-level compliance evidence.

Need help assessing your TSCA exposure?

Speak with Regilient's compliance experts to assess your electronics supply chain and build a more traceable chemical compliance process.

Related TSCA Resources

• What Is TSCA?
• EPA and Its Purpose
• TSCA 6(h) PBT Compliance Guide
• TSCA Compliance Software
• Full Material Disclosure (FMD)